Last Updated: July 22, 2024, and effective from that date.

Startup Canada (“we”, “us”, “our”) respects individual privacy and recognizes the need for appropriate protection and management of your personal information. This Privacy Notice outlines how we collect, store, use and disclose personal information of users of our website, startupcan.ca (the “Website”) and the personal information of individuals who participate in our programs (also referred to as “programming” or “activities”).

Please be aware that this Privacy Notice is subject to change and we advise you to check back here from time to time. If we change the way we collect, use, disclose or otherwise process your Personal Information, we will update this Privacy Notice and when required, we will notify you. These changes will take effect immediately upon posting. Where required by law, we may seek your prior consent.

In this Privacy Notice, Personal Information means any information that can be used to identify you, either alone or in combination with other information (“Personal Information”).

Links to Third-Party Websites found on our Website

While we do provide you with links to third-party websites as a service, we are not responsible for the content, applications or data collection practices of any such third party pages or sites that you may access from time to time. Clicking on those links may allow the third-party to collect or share Personal Information about you. Before visiting or submitting any information on those third-party sites, please review and understand their privacy policies since they differ from site to site.

What Personal Information We Collect About You and for Which Purposes

We might collect Personal Information when you make submissions on our Website, when you contact us via email, by phone, or through contact forms on our website, when you register for and/or participate in our programming, activities or events.

Personal Information collected directly from you:

Purpose for Collection and Uses	Types of Personal Information Collected
You subscribe to e-mails from Startup Canada, such as newsletter services or mailing lists.	First and last name, e-mail address.
You make a submission on the “Contact Us” page.	First and last name, e-mail address, and any personal information you enter in the “Message” field.
You register to access the Business Owners Toolkit.	First and last name, e-mail address, phone number, company name, job title, business address, identity and self-identification (such as gender and immigration status), industry, type of business, and any optional questions you provide answers to.
You register and/or participate in paid events and programming.	First and last name, e-mail address, phone number, company name, job title, business address, identity and self-identification, industry, type of business, total annual sales, number of employees, number of years in business, export status. payment card information, billing information. We gather this information through third party event management systems and payment platforms (e.g. Pheedloop for event management and Stripe for payment).
You register for and/or participate in other Startup Canada programming.	First and last name, e-mail address, phone number, company name, job title, business address, identity and self-identification, industry, type of business, total annual sales, number of employees, number of years in business, export status.

Personal Information Collected Through “Cookies”:

In general, you can visit our Website without telling us who you are or submitting any Personal Information. However, our Websites use a technology called “cookies”. A cookie is an element of data that our Website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies for authentication purposes and to collect: the city and country from which you are visiting our website, the browser type you are using to visit our website, and the device type. We use this information to provide you with a better browsing experience while visiting our Website, to help us understand activity on our Website, to personalize the Website according to your preferences, and to monitor and improve our services and our Website. We may also use this information to promote our services through marketing and advertising.

You may set your web browser settings to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take full advantage of all of the features of our Website.

How We Use Your Personal Information:

In addition to the uses listed above, we may also use your Personal Information for the following purposes:

• To provide our programming and make the Website available to you;
• To communicate with you about the Website and our programming;
• To provide customer service and to respond to inquiries;
• In aggregate form, in order to fulfill our internal business purposes such as reviewing trends on  our Website usage, to inform our programming practices, and to maintain statistics about the success of Startup Canada, among other things;
• To comply with our regulatory and legal obligations;
• To detect, prevent or investigate security breaches or fraud and to protect our business, including to enforce ours or others’ legal rights or to comply with applicable laws; and
• For any other purposes for which you provide consent.

In the course of our activities and for the same purposes as those listed in this Privacy Notice, your Personal Information can be accessed by, or transferred to certain recipients on a need-to-know basis to assist us with such purposes on our behalf. For example:

• our personnel as well as our contractors;
• our suppliers and services providers providing us with services associated with providing our products and services to you, such as our third-party event management platform and payment processing providers;
• our systems providers that provide us with IT solutions, including web service providers, web hosting, cloud service providers, database providers, analytics services such as Google Analytics; and
• our professional advisors, including accountants and lawyers, as part of requesting advice or as part of a business transaction involving part of our business or its assets.

Your Personal Information will remain protected in accordance with this Privacy Notice. Prior to any transfer of Personal Information, we ensure to have agreements in place with third-party service providers to ensure the protection of Personal Information, as required by law.

How We May Disclose Your Personal Information

We may disclose your Personal Information to third parties under the following circumstances:

• Personal Information you have given us express permission to disclose to a specific third party. For example, we may share your name and business information with one of our partners. When you give us your permission to disclose your personal information to these third parties, your information is subject to the policies and practices of these third parties. We encourage you to review their privacy policies before agreeing to disclose your information to them;
• In response to a search warrant or other legally valid inquiry, request or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by law;
• If the disclosure is necessary or appropriate for the establishment, exercise or defence of legal claims, to protect our rights or those or our employees, contractors and/or customers, to prevent actual or suspect loss or harm to persons or property or to resolve a dispute between us; or
• in connection with business transaction (e.g. a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings)) involving all or part of our business.

How We Store and Protect Your Personal Information

We have physical, technological, and organizational safeguards in place to protect the Personal Information we hold about you. For example, we restrict access to your Personal Information by personnel and others on a need-to-know basis. We employ tools such as multi-factor authentication, up-to-date security software, to protect your Personal Information from loss, theft, or any unauthorized access, disclosure, or use.

We retain your Personal Information for as long as reasonably necessary for the purposes that we collected it for. In some cases, we may be legally obligated to store your Personal Information for longer periods of time. Unless otherwise required or authorized by law, we will destroy any Personal Information we hold about you when the purpose for which it was collected is fulfilled.

International Transfers of Personal Information

The Personal Information we collect may be processed by us and our service providers on servers located inside and outside of Canada. For example, we use Google Drive as our data storage service provider, which stores the data that we collect and retain in the [NTD: insert data region].

Please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is stored, including lawful access. If your Personal Information is transferred outside of Canada, we will take steps to ensure your information is adequately protected in accordance with applicable privacy laws.

Your Privacy Rights

You may choose to exercise any of the following rights related to your Personal Information. Some of these rights will be subject to specific requirements or limitations under applicable law:

• Rights of access and correction:  At any time, you may request access to any of your Personal Information that we hold, subject to limited exceptions prescribed by law, such as any Personal Information about another individual that cannot be separated from yours, any information subject to solicitor-client privilege, commercially confidential information, information that may threaten life or security of an individual, or information collected for purposes related to an investigation of a breach of an agreement or contravention of law. You may request information on the types of Personal Information we hold about you, what it is being used for, and with whom it has been shared. You may also request the correction of any inaccurate, outdated or incomplete information related to you.
• Right to opt-out: At any time, you may “opt-out” or withdraw your consent to the collection, use, disclosure or any other form of processing of your Personal Information, subject to contractual or legal restrictions. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to provide you with a particular product or service.
• Unsubscribe from email marketing: You may remove yourself from our contact lists by following the unsubscribe instructions in each of the e-mails. You may also remove yourself from our list by contacting us as set out in the “Contact Us” section below.

Whenever we process Personal Information, we take reasonable steps to keep Personal Information accurate and up-to-date as necessary for the purposes identified when it was collected.

If you wish to exercise any of these rights, please contact us at the contact information found in the section “Contact Us” below. We may not accommodate a request if we believe it would violate any law or legal requirement. If we cannot accommodate a request, we will provide you with a justification.

We may request certain Personal Information for the purposes of verifying your identity when requesting access to or correction of your Personal Information.

Children’s Privacy

Our Website and our activities are not directed at children. We do not knowingly collect any Personal Information about children on our Website or for the purposes mentioned in this Privacy Notice. If Personal Information about children has been mistakenly provided to us and you would like to request that such Personal Information be removed, please refer to our “Contact Us” section.

Contact Us

If you have any questions or comments regarding our Privacy Notice, if you would like to exercise the privacy rights above, or have if you have any concerns regarding our privacy practices, please reach out to our Privacy Officer at hello@startupcan.ca or 56 Sparks Street, Unit 300, Ottawa, Ontario, K1P 5A9.