Effective date: October 20, 2026 

This Privacy Policy explains how 807447 Ontario Limited, operating as Hurtle Canada ("Hurtle Canada", "we", "us"), collects, uses, discloses and protects personal information when you visit hurtle.ca (the "Site"), buy from us, or contact us. We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector (as amended by Law 25), and other applicable provincial privacy laws. 

1. Who is responsible 

We are responsible for the personal information we control. Our person in charge of the protection of personal information (Privacy Officer) is: 

Chani Pluczenik, Brand Manager, Privacy Officer 

807447 Ontario Limited 

970 Lawrence Avenue West, Suite 209, Toronto, Ontario M6A 3B6, Canada Email: contact@hurtle.ca (Attn: Privacy Officer) 

Phone: 782-822-0729 

2. Information we collect 

• Contact and account information: name, email, phone number, billing and shipping address, account login. 
• Order information: products bought, order history, returns, warranty registrations and claims, and proof of purchase. 
• Payment information: processed by our payment providers. We do not store full card numbers. 
• Communications: messages, chats, reviews, photos or videos you send us (for example for a warranty claim). 
• Device and usage information: IP address, browser and device type, pages viewed, referring site, and approximate location derived from your IP address. This is collected through cookies and similar technologies, as described in section 7. 

We collect information from you directly, automatically when you use the Site, and from service providers such as payment, shipping and fraud-prevention partners. 

3. Why we use it 

• To process and deliver orders, handle returns, refunds and warranty claims, and provide customer service. 
• To create and manage your account. 
• To send transactional messages (order confirmations, shipping updates, product safety notices or recalls). 
• To send marketing emails or text messages, only with your consent (see section 8).
  To measure and improve the Site, and, with your consent, to show you relevant advertising. 
• To prevent fraud, secure the Site, and meet legal, tax and accounting obligations.

We collect only the information needed for these purposes. We will ask for your consent before using your information for a new purpose. 

4. Consent 

By placing an order or creating an account, you consent to the use of your information to fulfil that request. We ask for express consent for marketing messages and for non-essential cookies. You may withdraw consent at any time, subject to legal or contractual limits, by contacting our Privacy Officer, unsubscribing from a message, or changing your cookie preferences. Withdrawing consent may mean we cannot provide certain services. 

5. Who we share it with 

We do not sell your personal information. We share it only as needed with: 
Service providers acting on our behalf under contract, including Shopify (e-commerce platform), payment processing (Shopify Payments, including Shop Pay, Visa, Mastercard and American Express), shipping carriers and our Canadian fulfilment warehouse, email and SMS providers (for example Klaviyo), customer service tools, and analytics and advertising partners (for example Google, Meta and TikTok, only where you have accepted those cookies). 

• Affiliated companies that help us operate the Hurtle brand, for the purposes in this Policy. 
• Authorities or others when the law requires it, or to protect rights, safety or property.
  A buyer or successor in a business transaction, under confidentiality obligations. 

6. Storage outside Canada and outside Quebec 

Some of our service providers, including Shopify, store or process information outside Canada (mainly in the United States) and outside Quebec. Your information may then be accessible to courts, law enforcement and national security authorities of those countries. Before transferring personal information outside Quebec, we assess whether it will receive adequate protection, and we use contracts to protect it. 

7. Cookies and tracking technologies 

We use strictly necessary cookies to run the Site (for example the cart and checkout). Analytics, personalization and advertising cookies and pixels, including technologies that can identify, locate or profile you, are turned off by default. They are activated only if you choose to allow them in our cookie banner. You can change your choice at any time through the "Cookie Preferences" link in the footer, and you can block cookies in your browser settings. 

8. Marketing messages 

We send promotional emails and text messages only with your express consent, in line with Canada's Anti-Spam Legislation (CASL). Every message identifies us, includes our mailing address, and has an unsubscribe link (for texts, reply STOP). We process unsubscribe requests within 10 business days. You will still receive transactional messages about your orders.

9. How long we keep it 

We keep personal information only as long as needed for the purposes above. Order and tax records are generally kept for 7 years. Warranty records are kept for the warranty period plus 1 year. Marketing data is kept until you unsubscribe or 3 years after your last interaction. When information is no longer needed, we destroy it or anonymize it securely. 

10. How we protect it 

We use reasonable physical, organizational and technical safeguards, such as encryption in transit, access controls and staff confidentiality obligations. If a confidentiality incident (privacy breach) creates a risk of serious harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada and/or Quebec's Commission d'accès à l'information, as required by law. 

11. Your rights 

Subject to legal exceptions, you may: 

• access the personal information we hold about you, and ask how it has been used and disclosed; 
• correct inaccurate or incomplete information; 
• withdraw your consent; 
• ask us to stop disseminating your information, or to de-index any hyperlink attached to your name, where Quebec law gives you that right; 
• receive computerized personal information you provided to us in a structured, commonly used technological format (Quebec); 
• be informed when a decision about you is made exclusively by automated processing. We do not currently make such decisions. 

To make a request, contact our Privacy Officer at contact@hurtle.ca (Attn: Privacy Officer). We may need to verify your identity. We will respond within 30 days, at no cost. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca), Quebec's Commission d'accès à l'information (cai.gouv.qc.ca), or the privacy commissioner of your province (for example Alberta or British Columbia). 

12. Children 

Some Hurtle products are made for children, but the Site and our purchasing process are intended for adults who have reached the age of majority in their province. We do not knowingly collect personal information from minors. In Quebec, we do not collect information from a child under 14 without a parent's or guardian's consent. If you believe a child has given us information, contact us and we will delete it. 

13. Changes to this Policy 

We may update this Policy. The effective date at the top shows the latest version. We will notify you of significant changes by posting a notice on the Site or by email.

14. Contact 

Privacy Officer: Chani Pluczenik, Brand Manager · contact@hurtle.ca (Attn: Privacy Officer) · 782-822-0729 · 970 Lawrence Avenue West, Suite 209, Toronto, Ontario M6A 3B6, Canada