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Privacy Policy

A legal disclaimer

Privacy Policy for Your Fractional CIO

Effective Date: December 2025

 

Your Fractional CIO (“we”, “us”, “our”) is committed to protecting the privacy of individuals who interact with us, including customers, visitors, and suppliers, in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial privacy statutes.

 

This Privacy Policy describes how we collect, use, disclose, and safeguard personal information and outlines the rights of individuals regarding their personal data.

1. Definition of Personal Information

For the purposes of this policy, personal information means any information about an identifiable individual, excluding business contact information (e.g., professional email, work phone).

 

2. Accountability

Appointing a Privacy Officer

We have appointed a Privacy Officer responsible for overseeing our compliance with this policy and applicable Canadian privacy laws.

Privacy Officer Contact: info@yourfractionalcio.ca
 

3. Identifying Purposes for Collection

Explaining Why Personal Information Is Collected

We collect personal information only for specific, legitimate business purposes, including but not limited to:

  • To provide products or services you request;

  • To communicate with you regarding your account or transactions;

  • To respond to your inquiries or support requests;

  • To process payments and send invoices;

  • To improve our products, services, and website;

  • To comply with legal and regulatory requirements.

We will identify these purposes at or before the time of collection.

 

4. Consent

Obtain Meaningful Consent

We obtain consent from individuals for the collection, use, and disclosure of their personal information:

  • Express consent for sensitive information (e.g., business or financial data);

  • Implied consent where appropriate (e.g., using a service implies consent to necessary data processing for that service).

Consent may be provided verbally, in writing, electronically, or through other affirmative action.

 

5. Limiting Collection

Collecting Only Necessary Information

We limit our collection of personal information to what is necessary to fulfill the identified purposes. We do not collect information indiscriminately or without a clear business need.

 

6. Limiting Use, Disclosure & Retention

Use and Disclosure

We use and disclose personal information only for the purposes for which it was collected unless:

  • The individual consents to a new use;

  • It is required or permitted by law;

  • The disclosure is to our service providers under confidentiality agreements.

Retention

We retain personal information only as long as required to fulfil the purposes identified and as required by law. Once no longer needed, we securely destroy or anonymize the information.

 

7. Accuracy

Ensuring Accuracy of Personal Information

We make reasonable efforts to keep personal information accurate, complete, and up-to-date, especially if it is used to make decisions about you or to provide services.

 

8. Safeguards

Protecting Data

We protect personal information through appropriate physical, organizational, and technological safeguards, including but not limited to:

  • Limited access controls;

  • Encryption where appropriate;

  • Secure storage systems;

  • Staff training on privacy obligations.

We regularly review our safeguards to respond to new threats.

 

9. Openness

Be Transparent

We are open about our privacy practices, including:

  • The contact information of our Privacy Officer;

  • The purposes for which information is collected, used, and disclosed;

  • The types of personal information we hold.

This policy is available on our website and upon request.

 

10. Individual Access

Responding to Access Requests

Upon request, we provide individuals with access to their personal information and explain how it is used and disclosed. We will:

  • Confirm whether we hold personal information about the requester;

  • Provide access unless prohibited by law;

  • Explain any reasons for denial of access.

Requests should be directed to our Privacy Officer.

 

11. Challenging Compliance

Handling Complaints

If you have questions, concerns, or believe we have violated this policy, you may contact our Privacy Officer. We will:

  • Investigate complaints;

  • Communicate outcomes to the complainant;

  • Take corrective action when appropriate.

If unresolved, individuals may file a complaint with the Office of the Privacy Commissioner of Canada or the relevant provincial privacy authority.

 

12. Online Tracking and Third-Party Services

Website Data

We may automatically collect certain information when you visit our website (e.g., IP addresses, browser type), and we may use tracking technologies (e.g., cookies) to improve user experience.

Users may manage cookie preferences through their browser settings.

We may share aggregated or de-identified data with third parties but do not sell personal information.

 

13. Changes to This Privacy Policy

We may update this policy periodically. Updates become effective when posted on our website with the effective date updated accordingly. We encourage you to review this policy regularly.

 

14. Contact Information

For questions about this policy or to make a privacy request submit an email to info@yourfractionalcio.ca

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