Privacy Policy

Last Updated: January 2026

1. Introduction

Nullgrid Infrastructure Inc. ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise process personal information in connection with our website, products, and services (collectively, the "Services"). This policy applies to all information collected through our Services, regardless of how the information is collected.

We are a Canadian company registered under the laws of Canada. Our address is 161 Bay St., Toronto, ON M5J 2S1, Canada. Our VAT Number is 829501742 RT 0001. This Privacy Policy complies with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and similar provincial legislation.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide to us, including:

• Account Information: When you create an account, we collect your name, email address, phone number, company name, job title, password, and other profile information.
• Communication Data: When you contact us via email, phone, or contact forms, we collect the content of your messages, your contact information, and any attachments.
• Payment Information: When you make purchases, we collect billing address, payment method, and transaction history. Payment processing is handled by third-party providers who comply with PCI-DSS standards.
• Service Usage Data: Information about how you use our Services, including features accessed, configuration preferences, and performance metrics.

2.2 Information Collected Automatically

We automatically collect certain information about your device and usage patterns:

• Device Information: Device type, operating system, browser type, IP address, and mobile device identifiers.
• Usage Information: Pages visited, features used, content viewed, duration of visits, and referring/exit pages.
• Cookies and Similar Technologies: We use cookies, web beacons, pixels, and similar tracking technologies to enhance your experience and analyze usage patterns.
• Location Data: We may collect location information based on IP address or device settings with your consent.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Business partners and service providers
• Payment processors and financial institutions
• Analytics providers and data brokers
• Publicly available sources
• Social media platforms (if you link your account)

3. How We Use Your Information

We use the information we collect for the following purposes:

• Providing, operating, and maintaining our Services
• Authenticating users and creating accounts
• Processing payments and transactions
• Sending transactional communications and service updates
• Responding to inquiries and providing customer support
• Improving and optimizing our Services
• Conducting analytics and usage monitoring
• Detecting, preventing, and addressing fraud and abuse
• Ensuring security and compliance with laws
• Marketing purposes (with your consent)
• Conducting surveys and collecting feedback

4. Legal Bases for Processing

Under Canadian privacy laws, we process your personal information based on the following grounds:

• Performance of Contract: Processing necessary to fulfill our agreement with you.
• Consent: Where you have explicitly consented to processing for specific purposes.
• Legal Obligation: Where required by applicable law or regulation.
• Legitimate Interests: Processing for our legitimate business interests, properly balanced against your rights.

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

We may share your information with third-party service providers who perform services on our behalf, including cloud infrastructure providers, payment processors, analytics providers, customer support platforms, and marketing service providers. These providers are contractually obligated to use your information only as necessary to provide services to us and must maintain appropriate security measures.

5.2 Business Partners

We may share aggregated or anonymized information with business partners for analytical, marketing, or operational purposes. We will not share personally identifiable information with business partners without your consent, except as required by law.

5.3 Legal Requirements

We may disclose your information when required by law, regulation, court order, or government request, or to protect our legal rights, privacy, safety, or property.

5.4 Business Transfers

If Nullgrid Infrastructure Inc. is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction, your information may be transferred as part of that transaction.

5.5 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified information with third parties without restriction, as this information cannot reasonably identify you.

6. Data Retention

We retain personal information for as long as necessary to provide our Services, fulfill the purposes for which it was collected, and comply with applicable legal obligations. Retention periods vary depending on the type of information and context of processing:

• Account information is retained for the duration of your account and for 2 years after account closure.
• Transaction records are retained for 7 years to comply with tax and legal requirements.
• Marketing communications data is retained until you unsubscribe.
• Usage logs are typically retained for 12 months.

You may request deletion of your personal information at any time, subject to legal and contractual obligations that may require us to retain certain data.

7. Data Security

Nullgrid Infrastructure Inc. implements comprehensive technical, organizational, and administrative security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)
• Secure password policies and multi-factor authentication
• Regular security audits and penetration testing
• Access controls and role-based permissions
• Network segmentation and firewalls
• Employee training on data protection and confidentiality
• Incident response and breach notification procedures

While we implement robust security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you use our Services at your own risk.

8. Your Privacy Rights

Under applicable Canadian privacy laws, you have the following rights concerning your personal information:

8.1 Right of Access

You have the right to request confirmation of whether we hold personal information about you and to access that information.

8.2 Right of Correction

You have the right to request correction of inaccurate, incomplete, or outdated personal information.

8.3 Right of Deletion

You have the right to request deletion of your personal information, subject to legal and contractual obligations that may require us to retain certain data.

8.4 Right to Opt-Out

You have the right to opt out of certain processing activities, including marketing communications. You can unsubscribe from marketing emails using the unsubscribe link in our messages.

8.5 Right of Portability

You have the right to request a portable copy of your personal information in a structured, commonly-used, machine-readable format.

8.6 Right to Withdraw Consent

Where we rely on your consent for processing, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of prior processing.

To exercise any of these rights, please contact us using the information provided in Section 11 below. We will respond to your request within 30 days or as otherwise required by law.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and provide personalized content. We use the following types of cookies:

• Essential Cookies: Required for basic website functionality and security.
• Performance Cookies: Help us understand how visitors use our website.
• Functional Cookies: Remember your preferences and settings.
• Marketing Cookies: Used for targeted advertising and tracking (requires consent).

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or alert you when cookies are being sent. For more information, visit www.aboutcookies.org.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information and terminate the child's account.

11. Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about our privacy practices, please contact us:

We will respond to your inquiry within 30 days or as otherwise required by applicable law. If you are not satisfied with our response, you may lodge a complaint with the relevant data protection authority in your jurisdiction.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated Privacy Policy on our website with a new "Last Updated" date. Your continued use of our Services following the posting of revised Privacy Policy means that you accept and agree to the changes.

13. International Data Transfers

Nullgrid Infrastructure Inc. operates primarily in Canada. However, if we transfer personal information internationally, we implement appropriate safeguards to ensure that such transfers comply with applicable privacy laws, including the use of Standard Contractual Clauses, Binding Corporate Rules, or other legally recognized mechanisms.

14. Additional Information by Jurisdiction

14.1 Canada (PIPEDA)

If you are a Canadian resident, your personal information is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws. You have the right to access your personal information, request corrections, and lodge complaints with the appropriate privacy commissioner.

14.2 Ontario

If you are an Ontario resident, you are also protected under the Freedom of Information and Protection of Privacy Act (FIPPA) if applicable. You may file a complaint with the Information and Privacy Commissioner of Ontario (IPC) if you believe your privacy rights have been violated.

15. Compliance and Accountability

Nullgrid Infrastructure Inc. is committed to maintaining compliance with all applicable privacy laws and regulations. We have implemented privacy by design principles, conduct regular privacy impact assessments, and maintain detailed records of our processing activities. Our Data Protection Officer oversees privacy compliance and can be reached at the contact information provided in Section 11.

16. Third-Party Links

Our Services may contain links to third-party websites and applications that are not operated by Nullgrid Infrastructure Inc. This Privacy Policy applies only to information collected through our Services. We are not responsible for the privacy practices of third-party websites or applications, and we encourage you to review their privacy policies before providing personal information.

17. Your Acknowledgment

By accessing and using Nullgrid Infrastructure Inc.'s Services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.