1.0 Introduction

ZeroTek Inc. (“ZeroTek”, “we”, “us”, “our“) has created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our ZeroTek Website located at www.zerotek.com/ (the “Website”) and through the provision of our Services (as identified on our Website) to our ZeroTek partners (“Partners”) and their customers (“Customers”).

The privacy of our ZeroTek Partners and their Customers is of great importance to us. By visiting our Website or using our Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

2.0 What does this privacy policy cover?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals and information which can be used to identify an individual (“Personal Information”). Personal Information may be collected about visitors to the Website, our ZeroTek Partners and their Customers.

This Privacy Policy does not apply to the practices of companies that we do not own or control, including those practices of our Partners. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.

For more information about ZeroTek security practices, compliance standards, and subprocessors, please visit the ZeroTek Trust Center.

3.0 Collection and use of personal information

3.1 Partner Information. When you register for the Services, inquire about engaging ZeroTek or otherwise correspond with ZeroTek by phone, email, or other means, ZeroTek collects certain Personal Information from you (collectively, “Partner Information”). In particular, ZeroTek may collect your name, company name, email address, phone number, business address and/or billing information, such as credit card number and billing address.

ZeroTek uses the Partner Information to:

• provide, operate, maintain and improve the Services;
• send technical notices, updates, security alerts and support and administrative messages;
• provide and deliver the Services and features you request, process and complete transactions, and send you related information, including confirmations and invoices;
• respond to comments, questions, and requests and provide customer service and support;
• communicate with you about services, features, surveys, newsletters, offers, promotions, and events, and provide other news or information about us and our select Partners;
• bill our ZeroTek Partners; and
• for other purposes which we will notify you about and seek your consent.

3.2 Partner Customers and End Users. ZeroTek provides identity and SaaS management for our Partners as part of the Services. In doing so, we may collect Personal Information about our Partner’s Customers (and their individual end users) from our Partners or their Customers directly, including first and last name, role within company, name of company, manager name, business phone number and email, office address, as well as preferences such as language and time zone. We use this Personal Information to provide the Services, including reporting and notifications.

In addition, ZeroTek also tracks login times and IP addresses for individuals who use the Services for audit, security, utilization and other functions incorporated in the Services.

3.3 Prospective Partners. ZeroTek may collect Personal Information of individuals who are prospective Partners, including name, company and company contact information (phone number and email address). ZeroTek uses this Personal Information for sales prospecting purposes and may contact prospects in accordance with applicable anti-spam laws.

3.4 Website Visitors. We collect a limited amount of Personal Information from our Website Users which we use to help us to improve your experience when using our website and to help us manage the services we provide. When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this as “Device Information”.

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.

The Website uses “cookies” to collect information and improve our products and services. A cookie is a small data file that is stored on your device. Cookies cannot be used to see any other data on your computer, nor can they determine your email address or identity.

We use “persistent cookies” as part of our authentication, security and session management to the ZeroTek services. We use “session cookies” to enable certain features of our service, to better understand how you interact with our service and to monitor aggregate usage and web traffic routing on our service.

We may use third-party ad companies (such as Google, Facebook, and RB2B) to help provide some of our advertising services. These third parties may place cookies on your computer and collect data about your online activities across websites or online services when you are logged into the third-party service, including for targeted advertising. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page.

RB2B Marketing Practices

When you visit or log in to our Website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email address. We (or service providers acting on our behalf) may then use this information to send communications and marketing to those associated email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

For more information on your choices regarding third-party analytics and marketing tools, please visit the links below:

• Facebook
• Google

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal.

4.0 Storage location and transfer of personal information

ZeroTek processes and stores its data, including Personal Information, on servers located in Canada, the United States, UK, Australia and Europe. ZeroTek also transfers data to the third-party service providers listed as subprocessors in our ZeroTek Trust Center.

By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada, the United States, UK, Australia and Europe. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those jurisdictions under lawful access regimes or court order.

5.0 Disclosure of personal information with third parties

5.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage includes third party companies and individuals employed by us to facilitate our services, including the provision of database management, payment processing and customer relationship management tools, including the subprocessors.

5.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

5.3 With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

5.4 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, our ZeroTek, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

• satisfy any applicable law, regulation, legal process or governmental request;
• enforce our contracts or user agreement, including investigation of potential violations hereof; and
• detect, prevent, or otherwise address fraud, security or technical issues.

The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

6.0 Retention

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

7.0 Residents of the European Economic Area (EEA)

If you are a resident of the EEA or the United Kingdom, you have certain data protection rights. ZeroTek takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from ZeroTek’s systems, please contact us using the contact information set out below. Note that where we act as a data processor on behalf of ZeroTek customers, you will be required to contact the data controller directly to exercise your rights.

In certain circumstances, where we act as data controller, you have the following data protection rights:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority.  If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

8.0 California residents

For more details about the Personal Information We have collected over the last 12 months, please see the section “Collection and Use of Personal Information” above. We collect this Personal Information for commercial purposes described above. ZeroTek does not sell (as that term is defined in the CCPA) the Personal Information we collect.

Subject to certain limitations, the California Consumer Privacy Act provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights. ZeroTek does not sell (as that term is defined in the CCPA) the Personal Information we collect.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information listed below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

9.0 Access, correction and accuracy (All users)

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another Partner or individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

10.0 Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

11.0 Additional information

Questions regarding this Privacy Policy or ZeroTek’s privacy practices should be directed to our Privacy Officer:

Privacy Officer
ZeroTek
2 Lakeview Terrace, Ottawa, ON
Email Address: privacy@zerotek.com

Effective Date: January 8, 2026