Cookie Policy

1. General Provisions

This Cookie Policy explains how the Operator uses cookies, pixels, tags, local storage, software development kits, and similar technologies on the Site.

This Policy applies to all users who access or use the Site from Canada. It must be read together with the Privacy Policy and any applicable Terms of Use.

For the purposes of this Policy, “cookies” means small text files or similar technologies placed on a user’s browser or device when the user visits the Site.

The Operator processes information collected through cookies in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”), Canada’s Anti-Spam Legislation, S.C. 2010, c. 23 (“CASL”), and, where applicable, substantially similar provincial privacy legislation.

2. Operator Information

For the purposes of this Cookie Policy, references to “Operator”, “we”, “us”, or “our” mean the entity responsible for operating the Site and determining the purposes for which cookies and similar technologies are used.

Contact details for privacy-related requests:

Users may contact the Privacy Officer regarding cookie preferences, withdrawal of consent, or questions about this Policy.

3. Legal Basis for Using Cookies

The Operator uses cookies and similar technologies only where permitted under applicable Canadian law.

Depending on the type of cookie and the information collected, cookies may be used on the basis of:

– the user’s express consent;

– the user’s implied consent where permitted by law;

– the necessity of providing a requested service;

– the Operator’s legitimate business purposes, provided that such purposes are reasonable and consistent with applicable privacy obligations;

– compliance with legal, regulatory, security, fraud prevention, or record-keeping obligations.

Where cookies collect information that identifies, relates to, or may reasonably be associated with an identifiable individual, that information is treated as personal information under applicable Canadian privacy law.

4. Categories of Cookies Used

The Site may use the following categories of cookies.

5. Strictly Necessary Cookies

Strictly necessary cookies are essential for the Site to function properly. Without these cookies, certain services cannot be provided.

These cookies may be used to:

– maintain a secure user session;

– authenticate account access;

– prevent fraudulent or unauthorized activity;

– remember privacy and cookie consent choices;

– support payment, account verification, and compliance functions;

– balance traffic and maintain Site availability;

– identify technical errors affecting security or functionality.

Strictly necessary cookies do not require consent where they are required to provide a service requested by the user or to maintain the integrity and security of the Site.

6. Analytics and Performance Cookies

Analytics and performance cookies help the Operator understand how the Site is used and whether technical changes are required.

These cookies may collect information such as:

– pages visited;

– approximate time spent on the Site;

– browser type and version;

– device type;

– general location derived from IP address;

– error messages;

– referral source;

– interaction events.

Where analytics data can identify or reasonably be associated with an individual, it is handled as personal information. The Operator uses reasonable safeguards and, where appropriate, aggregation or de-identification to reduce privacy risks.

7. Advertising and Measurement Cookies

Advertising and measurement cookies may be used to assess the effectiveness of communications and prevent repetitive or irrelevant messages.

These cookies may process information relating to:

– interactions with advertising content;

– frequency of content display;

– referral activity;

– device or browser identifiers;

– general engagement metrics.

The Operator does not use advertising or measurement cookies for purposes that are prohibited by applicable Canadian law. Where required, these cookies are used only after the user provides valid consent.

8. Third-Party Technologies

The Site may allow selected third-party service providers to place or read cookies and similar technologies. These providers may assist with:

– hosting and infrastructure;

– analytics;

– fraud prevention;

– cybersecurity;

– payment processing support;

– identity verification support;

– customer support tools;

– regulatory compliance functions.

Third-party providers are permitted to process information only for authorized purposes and subject to contractual, confidentiality, and security obligations. However, third-party providers may also be subject to their own privacy and cookie policies when they act as independent controllers or organizations responsible for their own processing activities.

The Operator takes reasonable steps to ensure that service providers comply with applicable Canadian privacy requirements.

9. Information Collected Through Cookies

Cookies may collect or store the following types of information:

– IP address;

– device identifiers;

– browser type and settings;

– operating system;

– language preferences;

– session identifiers;

– login status;

– cookie consent choices;

– pages viewed;

– date and time of access;

– interaction data;

– approximate geographic location;

– security and fraud detection signals.

The specific information collected depends on the user’s device, browser settings, consent choices, and use of the Site.

10. Purposes of Cookie Use

The Operator may use cookies and similar technologies for the following purposes:

– to operate and maintain the Site;

– to provide secure account access;

– to verify user sessions;

– to detect and prevent fraud, misuse, and unauthorized activity;

– to comply with legal and regulatory obligations;

– to remember user preferences;

– to improve Site performance and reliability;

– to diagnose technical issues;

– to measure usage and functionality;

– to support responsible account and risk controls;

– to manage consent records;

– to provide communications where legally permitted.

Cookies are not used for purposes incompatible with this Policy or applicable Canadian privacy law.

11. Consent Management

When required by law, the Operator obtains consent before placing or accessing non-essential cookies.

Consent may be requested through:

– a cookie banner;

– a preference centre;

– browser or device settings;

– account privacy settings, where available;

– other clear consent mechanisms.

Users may accept, reject, or modify non-essential cookie choices where such options are made available. Refusing non-essential cookies will not prevent access to the Site, although some features may operate with reduced functionality.

The Operator maintains records of cookie consent where required for compliance purposes.

12. Withdrawal of Consent

Users may withdraw consent for non-essential cookies at any time.

Consent may be withdrawn by:

– using the cookie preference centre, where available;

– adjusting browser settings to block or delete cookies;

– using device-level privacy controls;

– contacting the Privacy Officer.

Withdrawal of consent does not affect the lawfulness of cookie use that occurred before withdrawal.

If cookies are deleted or browser settings are reset, the Site may request cookie preferences again during a later visit.

13. Browser and Device Controls

Most browsers allow users to control cookies through settings. Depending on the browser, users may be able to:

– block all cookies;

– block third-party cookies;

– delete existing cookies;

– receive alerts before cookies are placed;

– limit tracking technologies;

– manage site-specific permissions.

Users should consult the settings or help section of their browser or device for instructions.

Blocking all cookies may affect the operation of the Site. Strictly necessary functions, including login, account security, and session continuity, may not work correctly if essential cookies are disabled through browser controls.

14. Do Not Track and Global Privacy Signals

Some browsers or devices may transmit “Do Not Track” or similar privacy signals. Canadian law does not currently establish a single mandatory technical standard requiring all websites to respond to such signals in the same manner.

Where legally required or technically feasible, the Operator may consider recognized privacy signals as part of the user’s cookie preferences. The availability and effect of such signals may depend on the user’s browser, device, and Site functionality.

15. Cookie Retention Periods

Cookies remain on a user’s device for different periods depending on their purpose.

The Operator retains cookie-related information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by applicable law.

16. Cross-Border Processing

Some service providers may process cookie-related information outside the user’s province or outside Canada.

Where cross-border processing occurs, the information may be subject to the laws of the jurisdiction in which it is processed. The Operator uses contractual and organizational safeguards designed to protect personal information in accordance with applicable Canadian privacy requirements.

Users may contact the Privacy Officer to request further information about the use of service providers outside Canada.

17. Safeguards

The Operator applies reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of information collected through cookies.

Such safeguards may include:

– access controls;

– encryption or secure transmission where appropriate;

– monitoring for unauthorized access;

– vendor due diligence;

– contractual confidentiality obligations;

– retention controls;

– audit and compliance measures.

No method of electronic transmission or storage is completely secure. The Operator takes reasonable measures to reduce privacy and security risks but cannot guarantee absolute security.

18. User Rights

Subject to applicable Canadian privacy law, users may have the right to:

– request access to personal information collected through cookies;

– request correction of inaccurate personal information;

– withdraw consent for non-essential cookies;

– ask questions about cookie practices;

– request information about service providers processing personal information;

– submit a privacy complaint to the Operator.

Requests may be sent to the Privacy Officer using the contact details stated in this Policy.

The Operator may need to verify the identity of the requester before responding to certain requests.

19. Complaints

Users may submit complaints regarding cookie practices or the handling of personal information to the Privacy Officer.

The Operator will review complaints in a reasonable manner and respond within a timeframe consistent with applicable Canadian privacy obligations.

If a user is not satisfied with the response, the user may have the right to contact the Office of the Privacy Commissioner of Canada or, where applicable, a provincial privacy regulator.

20. Changes to This Cookie Policy

The Operator may amend this Cookie Policy from time to time to reflect changes in technology, legal requirements, regulatory guidance, or Site operations.

Where changes are material, the Operator may provide notice through the Site or request renewed consent where required by law.

Continued use of the Site after an updated Policy becomes effective constitutes acknowledgment of the updated terms, except where express consent is required by applicable law.

21. Contact

Questions, requests, or complaints concerning this Cookie Policy may be directed to: