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PRIVACY POLICY

PRIVACY POLICY
(“Policy”)
SPRAY-NET GROUP OF COMPANIES
(“Spray-Net”)

Last Update: September, 2024

Introduction and Scope of Policy

At Spray-Net Inc. (‘’we’’, ‘’our’’ or ‘’Company’’), we respect your privacy and take your privacy and the protection of your personal information seriously. This policy describes the types of information we may collect from you or that you may provide to us when you visit our franchise website www.spraynetfranchise.com (“Website“) and/or when you use the Company’s services (“Services”). This policy summarizes our practices for collecting, using, maintaining, protecting, and disclosing that information.

For the purposes of this policy, “Personal Information” means any information about an identifiable individual, such as the first and last name, phone number, address, state or province, ZIP or postal code, city, cookies, comments, including information that can be used alone or with other information to identify, contact or locate a single individual. In general, Personal Information does not include business contact information, such as name, title or business contact information.

This policy applies to information we collect:

    • On this Website;
    • In email, text, and other commercial electronic messages (CEMs) between you and us;
    • When you contact our customer support (via chat, email, SMS, or telephone); or
    • When you communicate with us on social media platforms (such as Facebook, Instagram).

This policy does not apply to third-party websites or third-party services which may be accessed by clicking on links appearing on such websites, and Company is not responsible for such third-party websites or services. If you follow a link to a third-party website, that third party will have its own privacy policies which you should review before submitting any personal information. Please read this policy carefully. If you do not agree with this policy, your choice is not to use our Website and not to use our Services. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website and the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. What type of information we collect

We collect several information about you including:

    • Information by which you may be personally identified, and which may include sensible information, such as name, postal address, email address, telephone number, information relating to your franchise inquiry (such as available capital, timeline to ownership) and information about any of your purchase(s) you may submit in connection with the use of our Services (“Personal Information’’);
    • Information that is about you but individually does not identity you, such as ZIP code; and/or
    • Information about your internet connection, the equipment you use to access our Website, and usage details; such as your computer’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date or your visit, the time spent on those pages, unique device identifiers and other diagnostic data including information collected through cookies, web beacons, and other tracking technologies (“Usage Data’’).

2. How we collect your information

We collect your information:

    • Directly from you when you provide it to us (via our Website, SMS, telephone, email or chat);
    • Automatically as you navigate through the site or use our mobile application. Information collected automatically may include Usage Data. For more information in this regard, please refer to section “How we use “cookies” and other tracking technologies” of this policy.

For example, the information we collect may include:

    • Information that you provide by filling in forms on our Website. This includes information provided at the time of filling in your basic information for more information about our franchise opportunity, when you register to receive our newsletter, when you download a resource off of our website, when you post or upload material or when you are interacting with us, for instance when you make an inquiry through our Website and/ or when you request further services.
    • We may also ask you for information when you enter a contest or our referral program sponsored by us, and when you report a problem with our Website or contact our customer support (via telephone, email or chat). When you use our chat services, we will also collect your messaging content.
    • Your responses to surveys that we might ask you to complete for research purposes.
    • When you apply for a position with the Company (and if you chose to provide your information), we may collect the information you have included in your resume and in certain circumstances, personal information required in the context of a background check (such as employment records, credit and/or criminal records).

3. Why do we need to collect and process your information?

For specific purposes and legitimate interests

We process your information as required to perform the Services requested or where we need to have access to your Personal Information to provide you with the Services. We also process your information for legitimate interests. These legitimate interests may include:

    •  Preventing risk of fraud;
    • Properly administer the Services and manage our relationship with you;
    • Answering questions or providing other types of support;
    • Confirm your identity and the accuracy of information provided;
    • Testing out features or additional services;
    • Assisting with marketing, advertising, or other communications.

For marketing purposes

We may use the Personal Information you provide to us to market and promote the Services and other offerings. If you have consented to receive such communication, we may send you newsletters, electronic messages (such as emails, SMS messages, news, updates and/or other written communications about the Company’s services). For example, we may use your Personal Information, such as your email or physical address, to send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business. We use this information to promote the use of our Services to you and share promotions, including targeted advertising, in accordance with your communication preferences.

We may also reach out to you via telephone to ask about other products or services you may be interested in. If you have a call scheduled with one of our representatives, we may record and transcribe the call. You will be notified prior to the recording that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.

With your express consent

We may also collect and use your Personal Information where you have provided your express consent. In particular, for example, where you direct us to transfer information to a third party, or where we receive your data from a third party, and it already comes with consent you have provided to that third party or where we are required by law to ask for your consent.

 

4. Electronic Communications and Notifications

You may receive the following types of electronic communications and notifications from the Company:

Electronic Notifications

Communication sent to confirm a transaction in connection with the Services or to send you information you have requested. This includes sending you our franchise kit, confirmations of meetings and/or calls with members of our team, reminders of upcoming calls/meetings, customer satisfaction survey and information about any incident regarding the security of your information or in order to comply with legal obligations, as applicable.

Commercial Electronic Messages (“CEM”)

You may receive CEMs from the Company about promotional opportunities related to our Services, if we have your express or implied consent to send you such CEMs. You can validate the status of your consent by contacting us. Please refer to section “How to contact us” of this policy. Note that the Company will have a legal basis (i.e. your implied consent) to send you CEMs if: (i) you have business relationship with us or had a business relationship which terminated less than two (2) years ago; or (ii) you sent an inquiry to us within the last six (6) months or you have provided your electronic address to us (via the Website or otherwise). Unless specific laws require us to obtain your express consent, we will use your Usage Data to make and recommendations to you about Services that may be of interest to you.

As per the applicable laws, you may unsubscribe from these promotional communications at any time by either:
(i) clicking on the unsubscribe link at the bottom of each CEMs we may send to you; or
(ii) contacting us by email marketing@spray-net.com

Please note that even if you unsubscribe, we may still need to contact you when i) required by law, or ii) we need to inform you about critical issues related to the Services you have requested, or iii) to provide you with important information about your account, as applicable.

 

5. How do we share your information?

We may disclose your information when required by law. We may also share your personal information with third parties including, for purposes related to the Services. If you submit an employment application, we may share your information with one of our employees, as needed to evaluate your candidacy and on a need-to-know basis.

For example, we may share your information to third parties, as required to perform the Services, and as per below:

    • Authorized employees, agents and representatives;
    • People who are legally authorized to have access to your Personal Information;
      Services Providers who require this information to perform their services for us (for example data processing, programming, data storage, market research, identification, payment processing).

We may disclose your information to a third party in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business. However, in the event the transaction is completed, your Personal Information will remain protected by applicable privacy laws.

 

6. Where do we host/process your information?

In order to provide you with the Services, Personal Information may be hosted and/or processed on servers operated by our business partners located in jurisdictions other than your province, territory or country of residence, including outside the province of Quebec (Canada) and outside the United States.

Whenever Personal Information is transferred to a location outside of these jurisdictions (as applicable), your Personal Information may be subject to the laws of these countries. We take appropriate contractual steps to protect your information when we send your information across borders. By submitting your Personal Information or using the Services, you consent to this transfer, storage, use, or processing.

 

7. How long do we keep your information?

We keep your Personal Information only for as long as necessary to fulfill the purposes for which we have collected it. We will also retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, tax purposes). If you stop using our Services or if you delete your account with us, we will delete your information or store your information in an aggregated and anonymized format. In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information for longer period as it can no longer be associated with you.

 

8. How do we protect your information?

We use commercially reasonable administrative, technical and physical safeguards to ensure the security and integrity of our platform and Services and regularly assess the security of our data storage, and systems that process information collected. All information you provide to us is stored is stored on secured locations and on servers controlled by the Company or its Service Providers, located either at our facilities or at the facilities of our Service Providers, in Canada, US or Europe.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Website or Services (including to log in to your account), you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Please also ensure that while using our Services, you are in a safe and private environment where the confidentiality of your personal information and your privacy are adequately protected. We are not responsible for circumvention of any privacy settings or security measures contained on our Services sites. The Company declines all liability if the Personal Information is subject to unauthorized use or access. In the event there is a security incident involving your Personal Information, as collected by us and under our control, we will notify you as per applicable privacy laws.

 

9. How we use “cookies” and other tracking technologies?

We use cookies and similar tracking technologies to track the activity on our Website. Cookies (‘’Cookies’’) are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services or our Website.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

When visitors leave comments on the Website we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Google Ads (AdWords): Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

Meta (formerly Facebook): Meta’s remarketing service is provided by Meta Platforms, Inc. You can learn more about interest-based advertising from Meta by visiting this page.

To opt-out from Meta’s interest-based ads, follow these instructions from Meta. Meta adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Meta and other participating companies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada in Canada, or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings. For more information on the privacy practices of Meta, please visit Meta’s Data Policy.

 

10. Children and Personal Information

This Website is not intended for use by children and we do not knowingly collect data relating to children. If we become aware that we are holding any information about children under the age of 18, we will take any actions necessary to comply with data protection legislation, including deleting the information. If you become aware that your child has provided their Personal Information to us, without your consent, please let us know as soon as possible by emailing marketing@spray-net.com so that we can take appropriate action.

 

11. Your rights over your information

Subject to certain exceptions, and depending on where you live, you may have some or all of the following rights:

    • Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose about you, and information about our data practices.
    • Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
    • Right to Request Deletion: The right to request that we delete Personal Information that we have collected about you.

To exercise your rights, please submit a request marketing@spray-net.com.

Please note that to protect your information and the integrity of our Services, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as your email address or a government-issued ID number.

 

12. How to contact us?

If you would like to ask about or have concerns about how we process your Personal Information, or if you want to make a request relating to your Personal Information please contact our Privacy Officer as per below:

Privacy Officer
Email address: support.it@spray-net.com
Mailing address: 1490 rue de Coulomb, Boucherville, Québec, J4B 7M2