Privacy Policy

Effective Date: May 14^th, 2025
Last Updated: April 8^th, 2026

At Clariti Group, we are committed to protecting the privacy and personal information of our clients, partners, employees, and website visitors. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws in Canada.

1. Scope and Application

This policy applies to all personal information collected, used, or disclosed by Clariti Group in the course of our commercial activities, including through our website, services, and business operations.

2. Accountability

Clariti Group has appointed a Privacy Officer who is responsible for ensuring our compliance with this policy and applicable privacy legislation.
For inquiries, requests, or complaints related to privacy, please contact:
Privacy Officer
Email: tara@claritigroup.ca
Phone: 613.656.0410

3. Collection and Use of Personal Information

We collect personal information only for identified and legitimate purposes, including:

• Providing and improving our services
• Responding to inquiries or service requests
• Marketing and communication (with consent)
• Employment and HR purposes
• Legal, regulatory, or security obligations

Personal information may include names, contact details, resumes, billing information, or other information voluntarily provided by individuals.

4. Consent

We obtain informed consent for the collection, use, and disclosure of personal information, except where otherwise permitted or required by law. Consent may be implied or expressed, and may be withdrawn at any time with reasonable notice, subject to legal or contractual restrictions.

5. Data Subject Rights

Under PIPEDA, individuals have the following rights:

• Access: You may request a copy of your personal information in our possession.
• Correction: You may request corrections to any inaccurate or incomplete information.
• Deletion: You may request the deletion of your personal information, provided it is no longer required for legal or business purposes.

Requests can be submitted to our Privacy Officer. We will respond within 30 days, subject to applicable exceptions.

6. Retention and Secure Deletion

We retain personal information only as long as necessary to fulfill the purposes for which it was collected or as required by law.

• Defined Retention Periods: Personal information is retained according to internal schedules, typically no longer than [e.g., 7 years for client files].
• Secure Deletion Procedures: Information no longer required is securely deleted or anonymized using industry best practices, including digital data wiping and secure document destruction.

7. Cross-Border Data Transfers

Clariti Group may transfer personal information to third-party service providers or partners located outside Canada (e.g., cloud hosting, analytics, customer support). In such cases:

• We ensure that personal information is protected through contractual safeguards, including Standard Contractual Clauses or confidentiality agreements.
• These transfers may be subject to foreign laws and government access.
• Despite the geographic location of processing, we remain accountable for personal information and ensure that it receives a comparable level of protection.

8. Safeguards

We implement physical, technical, and administrative safeguards to protect personal information from loss, theft, unauthorized access, disclosure, copying, use, or modification. These include:

• Data encryption
• Access controls
• Regular staff training
• Secure disposal procedures

9. Privacy Breach Response

1. Incident Identification, Reporting and Logging
All employees, contractors, and service providers are required to promptly report any suspected or actual privacy incident involving personal information.
Reported incidents are documented and logged in a centralized incident register. Each record includes, at minimum:
• the date and time the incident was identified and reported
• a description of the incident and the information involved
• the individuals or systems affected
• initial containment actions taken
We maintain these records to support investigation, compliance obligations, and ongoing risk management.
2. Roles and Responsibilities
We maintain clear roles and responsibilities for managing privacy incidents, including:
• Privacy Officer (or designate): Responsible for overseeing incident response, determining whether a breach has occurred, assessing risk, and coordinating notifications
• Leadership: Provides oversight and ensures appropriate resources and escalation
• Employees and Contractors: Responsible for immediate reporting of incidents and supporting containment and investigation efforts
All personnel are expected to cooperate fully in incident response activities.
3. Notification of Privacy Breaches
Where a privacy breach involving personal information is confirmed, we will assess whether the breach creates a real risk of significant harm to affected individuals.
Where required, or where we determine it is appropriate, we will notify affected individuals as soon as feasible. Notifications will include:
• a description of the breach and when it occurred (if known)
• the type of personal information involved
• steps we have taken to mitigate harm
• steps individuals can take to protect themselves
• contact information for further inquiries
We will also notify regulators or other authorities where required by applicable law.
4. Review and Continuous Improvement
All privacy incidents and breaches are reviewed to identify root causes, trends, and opportunities for improvement.
Based on these reviews, we implement corrective actions, which may include:
• updates to policies, procedures, and safeguards
• additional employee training and awareness
• system or process improvements

10. Third-Party Services

Our website or services may contain links to third-party websites. This Privacy Policy does not apply to external sites. We recommend reviewing the privacy policies of those sites before submitting personal information.

Policy Updates

This policy may be updated from time to time to reflect legal changes or operational needs. We encourage you to review it periodically. Continued use of our services after any modifications constitutes your acceptance of the revised policy.

Contact Us

If you have any questions, concerns, or wish to exercise your privacy rights, please contact:

Privacy Officer
Tara Azulay
Email: tara@claritigroup.ca
Phone: 613.656.0410
Website: https://www.claritigroup.ca