PRIVACY POLICY

Groomer Growth Co

Effective Date: March 18, 2026

1. Introduction

2608341 ONTARIO INC., operating as Groomer Growth Co ("we," "us," or "our"), is committed to protecting the privacy of our clients and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our website at https://groomergrowthco.ca or subscribe to our Services.

This Policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario privacy laws. By using our Services, you consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you sign up for a free trial, create an account, or subscribe to our Services, we may collect:

Full name

Business name and address

Email address

Phone number

Billing address

Payment information (processed securely via Stripe — we do not store card numbers)

Business details (services offered, service area, scheduling preferences)

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain technical information, including:

IP address

Browser type and version

Pages visited and time spent on the site

Referring URL

Device type and operating system

We may use cookies and similar tracking technologies to collect this information. You can control cookie preferences through your browser settings.

2.3 Information from Third Parties

We receive information from third-party service providers that help us deliver the Services, including Stripe (payment processing) and our platform infrastructure provider. This information is limited to what is necessary to provide the Services.

2.4 Future Analytics

We may in the future implement analytics and advertising tools such as Google Analytics or Facebook Pixel. If we do, we will update this Privacy Policy and provide you with appropriate notice and consent mechanisms prior to deployment.

3. How We Use Your Information

We use the information we collect for the following purposes:

To create and manage your client sub-account

To deliver and operate the Services you have subscribed to

To process payments and manage billing

To communicate with you regarding your account, subscription, and support requests

To send you product updates, service announcements, or marketing communications (you may opt out at any time)

To improve and optimize our platform and Services

To comply with applicable laws and legal obligations

To prevent fraud and ensure the security of our platform

4. Legal Basis for Processing

We process your personal information on the following legal grounds:

Contractual necessity — to fulfill our obligations to you as a subscriber

Legitimate interests — to operate and improve our business, prevent fraud, and communicate with you

Consent — for optional marketing communications and for any data uses requiring your consent

Legal obligation — to comply with applicable Canadian and Ontario laws

5. Sharing of Your Information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information in the following limited circumstances:

5.1 Service Providers

We share information with trusted third-party vendors who assist us in providing the Services, including:

Stripe — payment processing

Platform and cloud hosting providers

AI and communication infrastructure providers

These providers are contractually required to protect your information and use it only for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required to do so by law, court order, or government authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Groomer Growth Co, our users, or the public.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our business, your personal information may be transferred to the acquiring entity. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

6. Data Retention

We retain your personal information for as long as your subscription is active and for a reasonable period thereafter to comply with our legal obligations, resolve disputes, and enforce our agreements.

Upon cancellation of your subscription, we will retain your account data for up to 90 days to allow for account reactivation, after which we will delete or anonymize it, unless we are required to retain it longer by law.

7. Data Security

We implement commercially reasonable technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

Encrypted data transmission (SSL/TLS)

Secure payment processing through Stripe (PCI-DSS compliant)

Access controls and user authentication

Regular review of our security practices

Despite these measures, no method of data transmission or storage is completely secure. We cannot guarantee absolute security of your information.

8. Your Privacy Rights

Under PIPEDA and applicable Ontario law, you have the right to:

Access the personal information we hold about you

Request correction of inaccurate or incomplete information

Withdraw consent for certain data processing activities

Request deletion of your personal information, subject to legal retention obligations

File a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe we have violated your privacy rights

To exercise any of these rights, please contact us at: [email protected]

We will respond to your request within 30 days. We may need to verify your identity before processing your request.

9. Children's Privacy

Our Services are intended for businesses and individuals who are 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

10. Cookies and Tracking Technologies

Our website may use cookies and similar technologies to enhance your browsing experience, remember your preferences, and analyze site traffic.

Types of cookies we may use:

Strictly necessary cookies — required for the website to function properly

Analytics cookies — help us understand how visitors use our site (subject to consent)

Marketing cookies — may be used in the future for advertising purposes (we will update this Policy and obtain consent prior to use)

You can control or disable cookies through your browser settings. Note that disabling certain cookies may affect the functionality of our website.

11. Third-Party Links

Our website or platform may contain links to third-party websites or integrations. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

12. International Data Transfers

Our services and infrastructure may involve the processing of your data in jurisdictions outside of Canada, including the United States. We take reasonable steps to ensure that international transfers of personal information are subject to appropriate safeguards consistent with Canadian privacy law.

13. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. If we make material changes, we will notify you by email or by posting a notice on our website with at least 14 days advance notice.

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically.

14. Contact Us & How to File a Complaint

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

2608341 ONTARIO INC. d.b.a. Groomer Growth Co

Email: [email protected]

Phone: +1 343-308-4823

Website: https://groomergrowthco.ca

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

Website: https://www.priv.gc.ca

Toll-free: 1-800-282-1376

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