Privacy Policy

TINSE inc is responsible for all personal information under its control. We have designated a Privacy Officer accountable for our compliance with PIPEDA and this policy.

• Privacy Officer: Chief Executive Officer, TINSE inc
• Email: contact@tinse.ca
• Phone: +1 (289) 499-8040
• Address: 7700 Hurontario Street NE, Suite 303a, Brampton, Ontario, L6Y 4M3, Canada

When personal information is transferred to third-party service providers, we use contractual or other means to ensure a comparable level of protection is maintained.

Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) is built on ten principles. TINSE inc adheres to all ten:

We collect only the personal information necessary to deliver our services. This includes:

• Contact Information: Name, email address, phone number, company name, and job title — when you submit a form, request a quote, or contact us.
• Project Information: Business requirements, technical specifications, and materials you share during an engagement.
• Billing Information: Invoicing details such as company name and address. Full payment card details are processed by PCI-DSS compliant third-party processors — we do not store card numbers.
• Usage Data: IP address, browser type, operating system, and pages visited — collected automatically via cookies and analytics tools.
• Communications: Records of emails, meeting notes, and correspondence related to your enquiry or project.
• Employment Information: Name, contact details, work history, and references — for job applicants only, handled separately and confidentially.

We identify the purposes for collecting personal information at or before the time of collection. Your information is used for the following purposes:

• Service Delivery: To provide software development, mobile app, ERP, and web design services as engaged.
• Client Communication: To respond to enquiries, provide project updates, and deliver customer support.
• Proposals & Contracts: To prepare quotations, service agreements, and statements of work.
• Billing & Payments: To issue invoices, process payments, and maintain accounting records as required by law.
• Marketing Communications: To send newsletters or service updates — only with your express or implied consent under CASL.
• Website Analytics: To understand how visitors use our site and improve our content and user experience.
• Legal Compliance: To meet obligations under applicable Canadian federal and provincial law.
• Recruitment: To evaluate applications for employment at TINSE inc.

We will not use your personal information for any new purpose without first identifying that purpose and obtaining your consent where required.

We obtain meaningful consent for the collection, use, and disclosure of your personal information:

• Express Consent: Required for sensitive information, secondary uses, or marketing emails. Given verbally, in writing, or electronically.
• Implied Consent: May apply for non-sensitive information in the context of an obvious business relationship — e.g., when you submit a contact form, you implicitly consent to us using your details to respond.
• Withdrawal of Consent: You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Contact our Privacy Officer at contact@tinse.ca.

TINSE inc collects only the personal information that is necessary for identified purposes, by fair and lawful means. We do not collect information indiscriminately or beyond what is required to deliver our services.

Where possible, we offer the option to interact with us anonymously or using a pseudonym, unless identification is required by law or by the nature of the service requested.

We do not sell, rent, or trade personal information. We disclose it only as follows:

• Service Providers: Trusted vendors (cloud hosting, payment processors, analytics) who operate under contractual confidentiality obligations.
• Project Partners: Only information necessary to complete a client project, with appropriate safeguards in place.
• Legal Obligations: When required by Canadian law, a court order, or a government authority with lawful authority to compel disclosure.
• Business Transfers: In the event of a merger or acquisition, personal information may transfer as part of the transaction — with advance notice provided.

Retention periods:

• Client project records: minimum 7 years (Income Tax Act compliance).
• Marketing contact lists: until consent is withdrawn.
• Job applicant records: 1 year after the hiring decision, unless consent is given for longer retention.
• Website analytics: anonymised per our analytics provider's retention policy.

When information is no longer required, it is securely destroyed or permanently anonymised.

We take reasonable steps to ensure that personal information we use is accurate, complete, and up to date — particularly when used to make decisions about you or shared with third parties.

If you become aware of inaccuracies in the personal information we hold, please contact our Privacy Officer and we will correct it promptly.

We protect personal information with security safeguards appropriate to its sensitivity, including:

• Encryption: SSL/TLS encryption for all data in transit to and from our website and systems.
• Access Controls: Role-based access ensuring only authorised TINSE inc personnel can access personal information on a need-to-know basis.
• Data Storage: Personal information is stored on secure servers located in Canada where reasonably possible.
• Vendor Agreements: Third-party processors are bound by contractual data protection obligations.
• Security Reviews: We periodically review and update our security practices to address new risks.
• Staff Training: Employees who handle personal information are trained on privacy obligations and internal security policies.

No method of electronic transmission or storage is completely secure. While we use commercially reasonable means to protect your information, we cannot guarantee absolute security.

TINSE inc makes our privacy policies and practices readily available. This Privacy Policy is publicly accessible at tinse.ca/privacy-policy.html. Upon request, our Privacy Officer can provide information about the types of personal information we hold, the purposes for which it is used, and how to access your information or challenge our compliance.

Under PIPEDA and applicable Canadian privacy law, you have the following rights:

Canada's Anti-Spam Legislation (CASL) governs all commercial electronic messages (CEMs) we send. TINSE inc complies fully:

• Express Consent: We obtain express consent before sending marketing emails, newsletters, or promotional messages. Consent records are maintained.
• Implied Consent: We may contact existing clients within 2 years of a transaction or enquirers within 6 months of their request, under CASL's implied consent provisions.
• Identification: Every CEM clearly identifies TINSE inc as sender, with our mailing address and contact information.
• Unsubscribe Mechanism: Every marketing email includes a clearly visible unsubscribe link. All requests are honoured within 10 business days.
• No Purchased Lists: We do not purchase, rent, or use email lists obtained from third parties.

• Essential Cookies: Required for the website to function. Cannot be disabled without affecting site functionality.
• Analytics Cookies: Collect anonymised data about site usage (e.g., Google Analytics). No personally identifiable information is stored.
• Preference Cookies: Remember your settings to personalise your visit.

You may control cookies through your browser settings. Disabling non-essential cookies will not affect your ability to use our services.

Our website may contain links to third-party websites provided for convenience only. TINSE inc has no control over and is not responsible for the privacy practices or content of those sites. We recommend reviewing the privacy policy of any third-party website before submitting personal information.

Our services are directed to businesses and individuals who are 18 years of age or older. We do not knowingly collect personal information from minors under 18. If you believe we have inadvertently collected information from a minor, please notify our Privacy Officer at contact@tinse.ca immediately and we will delete that information promptly.

Under PIPEDA's mandatory breach reporting requirements, if TINSE inc experiences a breach of security safeguards involving personal information that poses a real risk of significant harm, we will:

• Notify the OPC: Report the breach to the Office of the Privacy Commissioner of Canada as soon as feasible.
• Notify Affected Individuals: Inform affected individuals directly and promptly so they can take protective steps.
• Notify Other Organisations: Where required, notify organisations that may be able to reduce the risk of harm to affected individuals.
• Maintain Breach Records: Keep a record of all breaches involving personal information, available to the OPC upon request.

Breach notifications will describe: what happened, the type of information involved, steps taken to reduce risk, and how affected individuals can contact us for more information.

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or applicable law. Material changes will be communicated by updating the "Last Updated" date, emailing active clients where changes are significant, and displaying a notice on our website. Your continued use of our website or services after a change constitutes acceptance of the revised policy.

If you believe TINSE inc has not complied with this policy or your rights under PIPEDA, please first contact our Privacy Officer. We will investigate and respond within 30 calendar days. If you are not satisfied with our response, you may file a complaint with:

• Office of the Privacy Commissioner of Canada (OPC): priv.gc.ca | Toll-free: 1-800-282-1376

• Organisation: TINSE inc
• Address: 7700 Hurontario Street NE, Suite 303a, Brampton, Ontario, L6Y 4M3, Canada
• Email: contact@tinse.ca
• Phone: +1 (289) 499-8040
• Business Hours: Monday – Friday, 9:00 AM – 6:00 PM EST