Privacy Notice

Effective Date: 08th January 2025

ThruLiquid (“us”, “we”, or “our”) operates the www.thruliquid.com website. This page informs you of our policies regarding the collection, use, and disclosure of PII (Personally Identifiable Information) and the choices you have associated with that data while using the ThruLiquid website/service.

We use your data to provide and improve the user experience. By using the website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this privacy policy, terms used in this privacy policy have the same meanings as in our terms and conditions accessible from www.thruliquid.com.

01. TO WHOM DOES THIS PRIVACY NOTICE APPLY

This notice applies to the processing of PII collected by us when you:

1. Visit our website.
2. Visit our office.
3. Receive communications from us as part of business development initiatives (prospective client).
4. Are our vendor.
5. Are a job applicant.

02. INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our service to you.

02.1 Types of Data Collected

02.1.1. Personally Identifiable Information (PII)

While using our website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“PII”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Cookies and Usage Data
• Resumes

While visiting our office premises, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“PII”) such as Name, National ID (if applicable), and phone number. If you are a vendor, we might retain the contact information of the point-of-contact from your side to establish seamless communication.

02.1.2. Usage Data

We may also collect information on how the website is accessed and used (“Usage Data”). This usage data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our website you visit, the time and date of your visit, and the time spent on those pages.

02.1.3. Information That We Collect from Third Parties

From time to time, we may receive PII about you from third-party sources such as databases and social media platforms, but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your PII to us.

The types of information we obtain from such third parties might include your name, e-mail address, company name, postal address, location, designation, and telephone number. We use this information to maintain and improve customer support, improve the accuracy of records we hold about you, and for our sales & marketing purposes.

03. USE OF DATA

ThruLiquid uses the collected data for various purposes:

• To provide, maintain, monitor the usage, analyze, and improve the website
• To notify you about changes to our website
• To detect, prevent, and address any issues
• To reach out to you for business development activities
• To reach out to you for services-related activities
• To reach out to you for job opportunities

04. TRANSFER OF DATA

Your information, including PII, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction.

Your consent to this privacy notice followed by your submission of such information represents your agreement to that transfer.

ThruLiquid will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice, and no transfer of your PII will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

05. DISCLOSURE OF DATA

05.1. Legal Requirements

ThruLiquid may disclose your PII in the good faith belief that such action is necessary to:

1. Comply with a legal obligation
2. Protect and defend the rights or property of ThruLiquid
3. Prevent or investigate possible wrongdoing in connection with the website
4. Protect the personal safety of users of our service or the public
5. Protect against legal liability

05.2. Your Rights

You can modify or withdraw your consent/object to our processing of your PII. You have the right to access any PII that ThruLiquid processes about you and to request information about:

• What PII we hold about you
• The purposes of the processing
• The categories of PII concerned
• The recipients to whom the PII has been or will be disclosed
• How long we intend to store your PII
• If we did not collect the data directly from you, information about the source
• If we perform any automated decision-making using the PII (currently, we do not perform any automated decision-making based on the PII we collect)

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information, and we will strive to do so as quickly as possible unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request the erasure of your PII or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. Requests to access, change, or remove your information will be handled within thirty (30) days. Please write to privacy@thruliquid.com for any requests.

06. SECURITY OF DATA

ThruLiquid understands the significance of your privacy and takes every reasonable measure and precaution to protect and secure your PII. We work hard to protect you and your information from unauthorized access, alteration, disclosure, or destruction, and have several layers of security measures in place, including:

• Encryption of data during transit (HTTPS)
• Encryption of data at rest
• Restricted access to only authorized personnel post an authentication process
• Implementation of anti-malware software
• Network protection through firewalls
• Data loss prevention solution

However, no method of transmission over the internet or method of electronic storage is 100% secure. If you believe your PII has been compromised, please contact us as set forth in the “Contact Us” section.

If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

07. DISPOSAL OF DATA

All PII we collect is disposed of securely as per ThruLiquid’s data retention policy.

08. LEGAL BASIS OF PROCESSING WE RELY ON

As noted in the ‘Use of Data’ section of this notice, we occasionally process your PII:

• If you have expressed consent or by providing us PII through other means (e.g., office premises, conference events, job applications, etc.).
• If you have expressed consent by signing a contract with us.
• Based on our Legitimate Interest or on your Consent to send you promotional and marketing communications.
• To respond to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, police request, or other legal process served on us.

09. SERVICE PROVIDER

We may employ third-party companies and individuals to facilitate our service (“Service Providers”), to perform service-related services, or to assist us in analyzing how our service is used. These third parties have access to your PII only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

09.1. Analytics

We may use third-party service providers to monitor and analyze the use of our service.

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 website. 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 your activity on the website made available to Google Analytics by installing the Google Analytics opt-out browser add-on. This 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: https://policies.google.com/privacy?hl=en.

10. LINKS TO OTHER SITES

Our service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy notice of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11. CHILDREN’S PRIVACY

Our service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with PII, please contact us. If we become aware that we have collected PII from children without verification of parental consent, we take steps to remove that information from our servers.

12. CHANGES TO THIS PRIVACY NOTICE

We may update our privacy notice from time to time. We will notify you of any changes by posting the new privacy notice on this page.

We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective, and will update the “effective date” at the top of this privacy notice. You are advised to review this privacy notice periodically for any changes. Changes to this privacy notice are effective when they are posted on this page.

13. CONTACT US

If you have any questions about this privacy notice, please contact us:

• By email: privacy@thruliquid.com

By post:Data Protection Officer,
ThruLiquid4230 Sherwoodtowne Blvd, Mississauga, ON L4Z 2G6