Privacy Policy

Canada East Supply and Distribution Inc. (“CESD,” “we,” “us” or “our”) respects your privacy and is committed to protecting the personal information in its custody or control.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information across the CESD website portfolio.

1. About this Privacy Policy

This Privacy Policy applies to the following websites operated by Canada East Supply and Distribution Inc.:

• cesdinc.ca;
• cesdev.ca;
• livestockequipment.ca; and
• stocktanks.ca.

These websites support different business activities:

• CESD Inc. provides corporate information, company communications, career information and access to the CESD operating portfolio.
• CESDevelopment provides technology services, Odoo-related development, apps, Care Plans, subscriptions, project services and technical support.
• Livestock Equipment Canada provides livestock equipment, products, quotations, ecommerce services, delivery and customer support.
• Stock Tanks Canada provides stock tanks, related products, quotations, ecommerce services, pickup, delivery, freight coordination and customer support.

Not every activity described in this Privacy Policy applies to every website or visitor. The personal information collected depends on the website, service and way in which you interact with CESD.

This Privacy Policy is intended to reflect applicable Canadian privacy requirements, including the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).

2. Accountability

Canada East Supply and Distribution Inc. is responsible for personal information under its control, including personal information processed on its behalf by service providers.

CESD has designated responsibility for overseeing its privacy practices and responding to privacy questions, access requests, correction requests, withdrawals of consent and complaints.

Privacy inquiries may be directed to:

Privacy Officer

Canada East Supply and Distribution Inc.

2942 Cockshutt Road

Waterford, Ontario N0E 1Y0

Canada

Telephone: 519-443-6464

You may also use the Contact Us page on the website you are visiting.

3. When this Privacy Policy applies

This Privacy Policy applies when you:

• visit or use a CESD website;
• create or use a customer or portal account;
• request product, service or company information;
• request a quotation or project estimate;
• purchase a product, app, subscription, Care Plan or service;
• arrange shipping, freight, delivery or customer pickup;
• submit a project request, support request or service inquiry;
• communicate with customer service or technical support;
• apply for employment or submit career information;
• subscribe to marketing communications;
• submit a review, photograph, testimonial or other content;
• attend a meeting or consultation;
• interact with CESD through email, telephone, forms or another business channel; or
• otherwise establish or maintain a relationship with CESD.

This Privacy Policy does not apply to independently operated third-party websites or services, even when a CESD website links to them.

4. What personal information is

Personal information is information about an identifiable individual.

It may include:

• a person’s name;
• address;
• telephone number;
• email address;
• account information;
• purchasing history;
• payment-related information;
• employment or application information;
• project or support information associated with an individual;
• online identifiers; and
• information associated with a device, account or website interaction.

Personal information does not generally include information that has been anonymized so that it can no longer reasonably identify an individual.

It also does not generally include business contact information used solely to communicate with someone in relation to their employment, business or profession, where permitted by law.

5. Personal information we collect

Depending on how you interact with CESD, we may collect the following information.

Contact and identification information

• Name;
• billing address;
• shipping, delivery or service address;
• email address;
• telephone number;
• company or organization name;
• job title or business role; and
• other information you provide when contacting us.

Account information

• Customer or portal account details;
• username or login information;
• saved addresses;
• shopping-cart or wishlist information;
• order, subscription or service history;
• communication preferences; and
• account settings.

We do not ask you to provide your account password to our staff. Passwords are managed through the applicable website or account system.

Order and transaction information

• Products, apps, subscriptions or services purchased or requested;
• order and quotation numbers;
• purchase and renewal dates;
• prices, taxes and payment status;
• delivery, freight or pickup instructions;
• delivery or service-location information;
• returns, refunds, exchanges and warranty information; and
• communications concerning a quotation, order or transaction.

Payment-related information

Payments may be processed by third-party payment processors or financial institutions. These providers may collect and process payment-card, banking or other payment information according to their own privacy and security practices.

CESD does not intentionally store complete payment-card numbers or card security codes on its own systems unless expressly required and supported by an approved secure payment process.

We may receive limited transaction information, such as:

• payment status;
• payment method;
• transaction identifiers;
• invoice information; and
• limited payment-card details made available by the payment provider.

Communications and customer-service information

We may collect information contained in:

• contact forms;
• emails;
• telephone conversations;
• quotation requests;
• product or service inquiries;
• customer-service requests;
• complaints;
• return or refund requests;
• warranty requests;
• technical-support requests; and
• other communications with CESD.

Development, project and technical-support information

When you request technology services, development work, an app, a subscription, a Care Plan, system review or technical support, we may collect:

• project requirements;
• business-process information;
• technical descriptions;
• system configuration information;
• error reports;
• screenshots;
• documents or files you choose to provide;
• support history;
• project communications;
• names and contact information for project participants; and
• other information reasonably required to assess, deliver or support the requested service.

Do not provide passwords, access credentials or unnecessary personal information through an ordinary contact form or unprotected email.

If system access or sensitive technical information is required for an approved service, CESD will determine an appropriate method for providing that information.

Corporate and business-inquiry information

When you contact CESD Inc. concerning the company, its operations, commercial relationships or other corporate matters, we may collect:

• your name and contact information;
• company or organization;
• professional role;
• nature of the inquiry;
• correspondence; and
• information reasonably required to evaluate or respond to the matter.

Employment and recruitment information

If you apply for employment or submit career information, we may collect:

• name and contact information;
• résumé or curriculum vitae;
• employment and education history;
• qualifications, skills and certifications;
• references, where requested;
• availability;
• information provided during interviews or communications; and
• other information reasonably related to evaluating an application.

Please do not submit sensitive information that is not reasonably required for the application process.

Website and technical information

When you visit a CESD website, CESD or its service providers may automatically collect information such as:

• Internet Protocol address;
• browser type and version;
• device type;
• operating system;
• referring website;
• pages viewed;
• links selected;
• dates and times of visits;
• account, shopping-cart and website-session information;
• approximate location derived from an IP address; and
• website performance, diagnostic, security and fraud-prevention information.

Marketing information

If you subscribe to promotional communications, we may collect:

• your name and email address;
• company or customer relationship;
• communication preferences;
• the date, time and method of consent; and
• information about interactions with our communications, where supported and lawfully enabled.

Reviews, photographs and submitted content

If you submit a review, photograph, video, testimonial or other content, we may collect:

• the submitted content;
• your name;
• contact information;
• product, project or service information associated with the submission; and
• any other personal information included with it.

Do not submit content containing another identifiable person unless you have their permission to do so.

Any licence, ownership or promotional-use terms applying to submitted content will be addressed through the applicable submission terms, website terms or another agreement.

6. How we collect personal information

We may collect personal information:

• directly from you;
• through a CESD website;
• through customer or portal accounts;
• through forms, email, telephone or meetings;
• during purchases, quotations, projects, deliveries, pickups, returns or warranty requests;
• during app, subscription, Care Plan, development or support relationships;
• through employment applications and recruitment communications;
• from payment processors, financial institutions, carriers, delivery providers or service providers involved in completing your transaction;
• from manufacturers, suppliers, dealers or business partners involved in responding to your request;
• through cookies and similar technologies;
• from publicly available sources where permitted by law; and
• from another person or organization with your consent or other lawful authority.

7. Why we collect and use personal information

We may collect and use personal information to:

• provide products, apps, subscriptions and services;
• respond to corporate, product, service or employment inquiries;
• prepare quotations, estimates and proposals;
• create and manage customer or portal accounts;
• process and confirm orders, subscriptions and payments;
• arrange pickup, shipping, freight and delivery;
• provide development, implementation, maintenance and technical-support services;
• evaluate project requirements and communicate with project participants;
• administer Care Plans, service relationships and renewals;
• evaluate employment applications and communicate with applicants;
• process returns, refunds, exchanges and warranty matters;
• provide customer service and respond to complaints;
• maintain transaction, tax, accounting, project and business records;
• administer approved discounts, promotions, reviews or content submissions;
• operate, maintain, secure, troubleshoot and improve our websites and systems;
• remember shopping-cart contents, account settings and website preferences;
• understand website use and performance where appropriate;
• prevent fraud, misuse, security threats and unlawful activity;
• protect our customers, personnel, websites, systems and business;
• establish, exercise or defend legal rights;
• comply with applicable laws, court orders, regulatory requirements and lawful government requests;
• send marketing communications where we have the consent or other legal authority required to do so; and
• fulfil other purposes that we explain when the information is collected or to which you consent.

We limit the collection of personal information to what is reasonably necessary for the identified purposes.

We will not use personal information for a materially different purpose without identifying that purpose and obtaining consent where required by law.

8. Consent and your choices

We obtain consent where required by law.

Consent may be express or implied depending on:

• the nature and sensitivity of the information;
• the purpose for which it is collected, used or disclosed;
• the reasonable expectations of the individual; and
• the surrounding circumstances.

For example, when you provide an address to purchase a product, you consent to our use of that address and its disclosure to the parties reasonably required to process and deliver the order.

When you provide project information for a requested service, you consent to its use for evaluating, delivering and supporting that service.

You may withdraw consent to certain uses of personal information by contacting our Privacy Officer.

Withdrawal of consent will not affect collection, use or disclosure that occurred before the withdrawal.

Your ability to withdraw consent may be limited where information is reasonably required to:

• complete an order, project or requested service;
• maintain legally required transaction, tax or accounting records;
• administer a subscription, return, refund, warranty or legal claim;
• maintain essential security or fraud-prevention measures;
• enforce an agreement; or
• satisfy another legal or contractual obligation.

If withdrawing consent prevents CESD from providing a product or service, we will explain the consequences where appropriate.

9. Marketing communications

CESD may send promotional emails or other commercial electronic messages only where permitted by Canada’s Anti-Spam Legislation (“CASL”) and other applicable laws.

Where required, we will:

• obtain valid consent;
• identify the sender;
• provide required contact information; and
• include a working unsubscribe mechanism.

You may unsubscribe by using the unsubscribe link included in a marketing message or by contacting CESD.

Unsubscribing from marketing communications will not prevent CESD from sending transactional or service-related communications, such as:

• order confirmations;
• invoices;
• delivery updates;
• quotation responses;
• account or security notices;
• subscription or Care Plan notices;
• project communications;
• technical-support messages;
• warranty communications; and
• product or safety information.

10. Cookies and similar technologies

CESD websites use cookies and similar technologies to support website operation, security, accounts, shopping carts, checkout, preferences and other requested functions.

Optional cookies or similar technologies may also support analytics, marketing, advertising or third-party website features where those services are enabled.

Odoo’s native Cookie Bar allows visitors to select:

• Only essentials; or
• I agree.

Supported optional third-party tracking configured through Odoo’s cookie controls is intended to remain blocked unless the visitor selects I agree.

Your cookie choice may apply separately to each CESD website, browser or device.

For more information about:

• essential cookies;
• optional cookies;
• website-specific cookie use;
• third-party services;
• consent choices; and
• changing or withdrawing a cookie choice,

please review our Cookie Policy.

11. When we disclose personal information

CESD does not sell or rent personal information.

We may disclose personal information where reasonably necessary for the purposes described in this Privacy Policy, including to:

• payment processors and financial institutions;
• delivery companies, carriers, drivers, freight brokers and logistics providers;
• website, ecommerce, hosting, cloud-storage and information-technology providers;
• email, communications, analytics, security and fraud-prevention providers;
• development, software, infrastructure and technical-support providers;
• manufacturers, suppliers, dealers or service providers assisting with an order, project, product inquiry, return or warranty claim;
• professional advisers, including accountants, insurers, auditors, consultants and legal advisers;
• government, regulatory, law-enforcement or judicial authorities where required or permitted by law; and
• a purchaser, successor, lender or adviser involved in a proposed or completed business transaction such as a sale, financing, merger, reorganization or transfer of assets.

Service providers are authorized to use personal information only as necessary to provide their services or as otherwise permitted by law.

CESD remains responsible for personal information under its control and uses contractual or other reasonable measures to require service providers to protect it appropriately.

12. Processing and storage outside Canada

Some service providers may process or store personal information outside Ontario or outside Canada.

When personal information is processed or stored in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or government authorities in accordance with those laws.

CESD remains responsible for personal information under its control and uses contractual or other reasonable measures to require service providers to provide an appropriate level of protection.

You may contact our Privacy Officer for additional information about our use of service providers outside Canada.

13. Retention of personal information

CESD retains personal information only for as long as reasonably necessary to:

• fulfil the purposes for which it was collected;
• complete transactions, projects and requested services;
• maintain customer, subscription, Care Plan or support relationships;
• administer returns, warranties, disputes or legal claims;
• meet tax, accounting, employment, regulatory, insurance and recordkeeping requirements;
• prevent fraud and maintain security; and
• enforce agreements and legal rights.

Retention periods vary depending on:

• the type and sensitivity of the information;
• the reason it was collected;
• the length of the customer, employment, project or service relationship;
• legal and contractual requirements;
• security and fraud-prevention needs; and
• whether the information is connected to a dispute or claim.

When personal information is no longer reasonably required, CESD will securely delete, destroy or anonymize it, subject to legal, technical and operational limitations.

Information contained in backups may remain until those backups are securely overwritten or deleted through normal retention processes.

14. Safeguards

CESD uses reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the personal information in its custody or control.

These safeguards may include:

• access controls;
• account authentication;
• secure hosting and payment processing;
• software and system maintenance;
• encryption where appropriate;
• staff access limitations;
• internal privacy and security procedures;
• secure disposal methods;
• backup and recovery practices; and
• contractual protections with service providers.

No website, electronic transmission or storage system can be guaranteed to be completely secure.

You are responsible for protecting your account credentials and should contact CESD promptly if you believe your account or personal information has been compromised.

Do not send passwords, financial information or other sensitive information through an ordinary contact form or unprotected email unless CESD has specifically instructed you to do so.

15. Privacy and security incidents

If a breach of security safeguards involving personal information occurs, CESD will assess the incident and take appropriate steps in accordance with applicable law.

Where required by PIPEDA, CESD will:

• report a breach that creates a real risk of significant harm to the Office of the Privacy Commissioner of Canada;
• notify affected individuals; and
• maintain legally required records of privacy breaches.

CESD may also notify other organizations or government institutions where permitted or required by law and where doing so may reduce the risk of harm.

16. Accuracy, access and correction

CESD takes reasonable steps to keep personal information as accurate, complete and current as necessary for the purposes for which it is used.

You are responsible for providing accurate information and notifying us when your contact, account, delivery, project or other relevant information changes.

You may request:

• confirmation of whether CESD holds personal information about you;
• information about how that information has been used;
• information about parties to whom it has been disclosed;
• access to personal information held about you; and
• correction of inaccurate or incomplete information.

To make a request, contact our Privacy Officer.

CESD may need to verify your identity before processing a request. Information collected for identity verification will be used only for that purpose.

Access may be limited or refused where permitted or required by law, including where disclosure would reveal:

• personal information about another person;
• confidential commercial information;
• information protected by legal privilege;
• security-sensitive information; or
• information that cannot legally be disclosed.

If CESD refuses all or part of a request, we will explain the reason, subject to applicable legal restrictions.

If a disagreement about the accuracy or completeness of information cannot be resolved, CESD will record the substance of the unresolved challenge where appropriate.

17. Children’s privacy

CESD websites, products and services are intended primarily for adults and businesses and are not directed to children under 13.

CESD does not knowingly collect personal information from a child who is unable to provide meaningful consent without appropriate consent from a parent or guardian.

If you believe a child has provided personal information to CESD without appropriate consent, contact our Privacy Officer so we can review and address the matter.

CESD does not knowingly use children’s personal information for behavioural advertising.

18. Third-party websites and services

CESD websites may contain links to websites or services operated by:

• manufacturers;
• suppliers;
• payment providers;
• carriers;
• social-media services;
• technology providers; or
• other third parties.

CESD is not responsible for the privacy, security or content practices of independently operated third-party websites or services.

A link from a CESD website does not mean that the third party’s privacy practices are controlled or approved by CESD.

We encourage you to review the privacy policy of any third-party website or service before providing personal information.

19. Changes to this Privacy Policy

CESD may update this Privacy Policy to reflect changes to:

• our websites;
• business activities;
• products and services;
• technology;
• service providers;
• privacy practices; or
• legal obligations.

The revised policy will be posted with an updated Last updated date.

If a change materially affects how CESD collects, uses or discloses personal information, we will provide additional notice and obtain consent where required before the new practice begins.

20. Questions and complaints

If you have a question, access request, correction request, concern or complaint about CESD’s privacy practices, contact:

Privacy Officer

Canada East Supply and Distribution Inc.

2942 Cockshutt Road

Waterford, Ontario N0E 1Y0

Canada

Telephone: 519-443-6464

You may also use the Contact Us page on the website you are visiting.

CESD will investigate privacy complaints and respond within a reasonable period.

If a complaint is found to be justified, CESD will take appropriate measures, which may include correcting information or changing its policies or practices.

If you are not satisfied with CESD’s response, you may contact:

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H3

Canada

Website: priv.gc.ca