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ORBIX Marketing Inc.

Privacy
Policy

ORBIX MARKETING INC. (“ORBIX”, “we”, “us”, “our”) is a corporation incorporated in Canada under Ontario Corporation Number 1001571962, with its office at 67 Yonge Street, Suite 701, Toronto, Ontario, M5E 1J8. This Privacy Policy explains how we handle Personal Information in connection with our Website and Services, consistent with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and applicable provincial privacy legislation.

01

Who we are

ORBIX MARKETING INC. provides business-to-business marketing services — including digital marketing support, social media management and content, campaign planning and execution, paid-media implementation, analytics and reporting, dashboard configuration, and market research — to business customers only. We do not provide services to consumers.

Contact: ceo@orbixit.website · 67 Yonge Street, Suite 701, Toronto, Ontario, M5E 1J8, Canada

02

Our approach to Personal Information

We are committed to data minimization. We do not collect, compile, or maintain databases of Personal Information about visitors to our Website, and we do not buy, sell, enrich, broker, or otherwise reuse Personal Information for our own commercial purposes.

The only Personal Information we ever handle as an accountable organization is whatever you choose to include in a message you send us — for example, your name and email address in an enquiry. We use that information for a single purpose: to read and respond to your message. We do not add it to a marketing list, we do not use it to profile or track you, and we do not use it to contact you for any unrelated reason.

03

Website enquiries

Our Website includes a contact form and may offer an audit or enquiry form. Anything submitted through these reaches us as an email. We use that email only to respond to your specific enquiry. We do not retain such messages beyond the short period reasonably necessary to handle the conversation and to meet any administrative, tax, or legal requirement, after which they are deleted in the ordinary course. We do not collect or store this information for any other purpose.

04

Consent and electronic messages (CASL)

We respect Canada’s Anti-Spam Legislation (CASL). We do not send unsolicited commercial electronic messages. If we ever send you a commercial electronic message, it will identify us, include our contact details, and provide a working unsubscribe option, and you may withdraw your consent at any time.

05

When we act for clients (service-provider role)

When a client retains us and gives us access to its own systems, platforms, accounts, or data, we act only as a service provider, following the client’s documented instructions. The client remains the organization accountable for that Personal Information under PIPEDA and is responsible for the purposes of collection, the consents obtained, the privacy notices given to individuals, the selection of audiences and recipients, the retention periods, and all other obligations of an accountable organization.

We do not independently determine the purposes or means of processing client Personal Information, and we do not sell, enrich, share, or reuse it for anything other than delivering the agreed Services. Where appropriate, the parties enter into a written data processing arrangement or include equivalent terms in the relevant Service Order.

06

Cookies and analytics

We keep any use of cookies and analytics on our Website to what is necessary for the Website to function and to understand aggregate usage. We do not use this information to identify individual visitors or to build personal profiles.

07

Where information is held and security

Any information we receive may be stored or processed in Canada or, where we use reputable service providers, in another jurisdiction; in that case it may be subject to the laws of that jurisdiction. We apply appropriate physical, organizational, and technological safeguards to protect information against unauthorized access, use, loss, or disclosure, and we limit access within our business to those who need it.

In the unlikely event of a breach of security safeguards involving Personal Information that creates a real risk of significant harm, we will report and notify as required under PIPEDA and keep records of the breach.

08

Your rights

Subject to applicable law, you may ask to access or correct the Personal Information we hold about you in connection with an enquiry you have sent us. Please email ceo@orbixit.website and we will respond within a reasonable time. Where Personal Information is handled in connection with client Services and we act only as a service provider, requests should be directed to the relevant client, which is the accountable organization.

If you have a concern about how we handle Personal Information, you may contact us first, and you also have the right to make a complaint to the Office of the Privacy Commissioner of Canada.

09

Additional information for individuals in the EU, EEA and the United Kingdom (GDPR)

Our Website is available worldwide, so visitors and enquirers may be located in the European Economic Area (EEA) or the United Kingdom. Where the EU General Data Protection Regulation (EU GDPR) or the UK GDPR applies to how we handle your personal data as a controller, the following additional information applies to you, together with the rest of this Policy.

Legal bases. When we act as a controller, we rely on these legal bases: our legitimate interests in receiving and managing the business enquiries you send us; the performance of, or steps to enter into, a contract with you or the organisation you represent; your consent, where we ask for it (which you can withdraw at any time); and compliance with our legal obligations.

Your rights. Subject to the conditions in applicable law, you have the right to access your personal data; to have it corrected or erased; to restrict or object to its processing; to receive it in a portable format; and, where we rely on consent, to withdraw that consent at any time. To exercise these rights, email ceo@orbixit.website, and we will respond within the period required by law (generally one month).

International transfers. We are based in Canada, and the service providers we use may store or process data in Canada or other countries. Where we transfer personal data from the EEA or the United Kingdom to a country not recognised as providing an adequate level of protection, we use an approved safeguard, such as the European Commission’s Standard Contractual Clauses and, for UK data, the International Data Transfer Addendum, and we take additional measures where needed. You can ask us for more information about these safeguards.

Complaints and representative. If you are in the EEA or the UK and think we have not handled your personal data properly, please contact us first. You also have the right to complain to your local data protection supervisory authority — in the United Kingdom, the Information Commissioner’s Office (ICO). Where we are required to appoint an EU or UK representative under Article 27, their contact details are available on request.

10

Links to other websites

Our Website may link to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their own policies.

11

Changes to this Policy

We may update this Privacy Policy from time to time. The current version is always the one published on our Website.