Cosmina Buiga
Operating under Nextech Software Inc.
Effective Date: January 1, 2025
Last Updated: January 1, 2025
INTRODUCTION
This Privacy Policy describes how Cosmina Buiga , operating under Nextech Software Inc. ("we," "us," or "our"), collects, uses, discloses, and protects your personal information when you use our website, services, or interact with us in any way.
Our Commitment: We are committed to protecting your privacy and handling your personal information in accordance with applicable privacy laws, including:
- Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
- United States federal and state privacy laws
- European Union General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
CONTACT INFORMATION
Data Controller/Privacy Officer:Cosmina Buiga
Operating under Nextech Software Inc.
Toronto, Ontario, Canada
Contact Information:
For privacy-related inquiries, complaints, or to exercise your rights, please contact us using the information above.
INFORMATION WE COLLECT
PERSONAL INFORMATION
We collect personal information that you voluntarily provide to us, including:
Contact Information:
- Full name
- Business title and role
- Company name and industry
- Email address
- Phone number
- Business address
- LinkedIn profile (if provided)
Professional Information:
- Company size (revenue and employee count)
- Technology challenges and requirements
- Project details and timelines
- Budget ranges and investment capacity
- Previous consulting experiences
Communication Records:
- Email correspondence
- Phone call records and notes
- Meeting recordings (with consent)
- Consultation notes and assessments
- Support ticket information
Technical Information:
- IP address and location data
- Browser type and version
- Device information
- Website usage patterns
- Referral sources
- Cookies and tracking data
AUTOMATICALLY COLLECTED INFORMATION
Website Analytics:
- Pages visited and time spent
- Click patterns and user behavior
- Search terms used on our site
- Download and form completion data
- Session duration and frequency
Marketing Data:
- Email open and click rates
- Resource download history
- Webinar attendance records
- Social media engagement
- Lead scoring and qualification data
HOW WE USE YOUR INFORMATION
PRIMARY PURPOSES
Service Delivery:
- Providing consulting services and assessments
- Delivering requested resources and materials
- Scheduling and conducting consultations
- Project management and communication
- Invoice generation and payment processing
Business Communications:
- Responding to inquiries and requests
- Sending service-related notifications
- Providing project updates and reports
- Delivering technical support
- Processing feedback and complaints
Marketing and Business Development:
- Sending newsletters and educational content
- Promoting relevant services and resources
- Conducting market research and surveys
- Analyzing service effectiveness
- Improving our website and offerings
LEGAL BASIS FOR PROCESSING (GDPR)
- Consent: For marketing communications and non-essential cookies
- Contract Performance: For service delivery and client communications
- Legitimate Interest: For business development, analytics, and fraud prevention
- Legal Obligation: For tax reporting, record keeping, and compliance
INFORMATION SHARING AND DISCLOSURE
WE DO NOT SELL YOUR PERSONAL INFORMATION
We do not sell, rent, or trade your personal information to third parties for monetary consideration.
LIMITED SHARING FOR BUSINESS PURPOSES
Service Providers:
We may share your information with trusted third-party service providers who assist us in:
Technology Services:
- Website hosting and maintenance (e.g., AWS, GoDaddy)
- Email marketing platforms (e.g., HubSpot, Mailchimp)
- Customer relationship management (e.g., Salesforce, Apollo)
- Video conferencing services (e.g., Zoom, Microsoft Teams)
- File storage and backup services (e.g., Google Drive, Dropbox)
Professional Services:
- Accounting and tax preparation
- Legal counsel and compliance
- Insurance providers
- Banking and payment processing
Business Partners:
- Subcontractors for specific project work (with client consent)
- Strategic partners for joint service delivery
- Industry associations and professional organizations
Legal Requirements:
We may disclose your information when required by law, including:
- Court orders or legal subpoenas
- Government investigations or regulatory requests
- Protection of our legal rights and property
- Prevention of fraud or illegal activities
- Emergency situations involving personal safety
INTERNATIONAL TRANSFERS
Cross-Border Data Transfers:
As a Canadian company serving clients internationally, we may transfer your personal information across borders, including:
- United States (for technology services and business operations)
- European Union (for European clients and service providers)
- Other jurisdictions where our clients or partners operate
Safeguards for International Transfers:
- GDPR Adequacy Decisions: We rely on European Commission adequacy decisions where available
- Standard Contractual Clauses: We use approved contractual clauses for transfers to non-adequate countries
- Privacy Shield and Successor Frameworks: We work with US companies that participate in recognized privacy frameworks
- Due Diligence: We assess the privacy practices of all international service providers
DATA RETENTION
RETENTION PERIODS
Active Client Information:
- During engagement: Throughout the duration of our business relationship
- Post-engagement: 7 years after project completion (for tax and legal requirements)
- Contract records: 7 years after contract termination
Marketing and Lead Information:
- Email subscribers: Until unsubscribe or 3 years of inactivity
- Website visitors: Analytics data retained for 2 years
- Inactive prospects: 3 years from last interaction
Legal and Compliance Records:
- Financial records: 7 years (Canadian tax requirements)
- Employment records: As required by applicable labor laws
- Legal documents: As required by limitation periods
SECURE DELETION
When retention periods expire, we securely delete or anonymize personal information using industry-standard methods, including:
- Secure overwriting of digital storage
- Physical destruction of paper records
- Anonymization of analytics data
- Verification of deletion completion
YOUR PRIVACY RIGHTS
RIGHTS UNDER CANADIAN LAW (PIPEDA)
Access Rights:
- Request information about what personal information we have about you
- Receive a copy of your personal information in our possession
- Learn how your information has been used and disclosed
Correction Rights:
- Request correction of inaccurate or incomplete information
- Provide updated information for our records
- Challenge the accuracy of information we hold
Withdrawal of Consent:
- Withdraw consent for marketing communications
- Opt out of non-essential data collection
- Request limitation of processing activities
RIGHTS UNDER EUROPEAN LAW (GDPR)
Enhanced Rights for EU Residents:
- Right of Access: Detailed information about processing activities
- Right to Rectification: Correction of inaccurate information
- Right to Erasure ("Right to be Forgotten"): Deletion under specific circumstances
- Right to Restrict Processing: Limitation of processing activities
- Right to Data Portability: Receive your data in a structured format
- Right to Object: Object to processing based on legitimate interests
- Rights Related to Automated Decision-Making: Protection from solely automated decisions
RIGHTS UNDER US LAW
California Consumer Privacy Act (CCPA) Rights:
- Right to Know: What personal information is collected and how it's used
- Right to Delete: Request deletion of personal information
- Right to Opt-Out: Opt out of the sale of personal information (we don't sell data)
- Right to Non-Discrimination: Equal service regardless of privacy choices
Other US State Rights:
We comply with applicable state privacy laws, including Virginia's Consumer Data Protection Act (CDPA) and Colorado Privacy Act (CPA).
HOW TO EXERCISE YOUR RIGHTS
Contact Methods:
Verification Process:
To protect your privacy, we may need to verify your identity before fulfilling requests:
- Email verification for simple requests
- Additional documentation for sensitive requests
- Phone verification for urgent matters
Response Timeline:
- Canadian requests: 30 days (extendable to 60 days if complex)
- EU requests: 1 month (extendable to 3 months if complex)
- US requests: 45 days (extendable to 90 days with notice)
COOKIES AND TRACKING TECHNOLOGIES
TYPES OF COOKIES WE USE
Essential Cookies:
- Session management: Maintain your session during site visits
- Security: Protect against cross-site request forgery
- Accessibility: Remember accessibility preferences
- Load balancing: Distribute traffic across servers
Analytics Cookies:
- Google Analytics: Website usage patterns and performance
- Hotjar: User behavior analysis and heatmaps
- Custom analytics: Form completion and conversion tracking
Marketing Cookies:
- LinkedIn Insight Tag: Professional audience targeting
- Facebook Pixel: Social media advertising effectiveness
- Email tracking: Newsletter and campaign performance
- Retargeting pixels: Relevant advertising delivery
Functionality Cookies:
- Preferences: Remember your communication preferences
- Language settings: Display content in preferred language
- Form data: Save form progress during completion
COOKIE CONSENT MANAGEMENT
Consent Banner:
We use a cookie consent banner that allows you to:
- Accept all cookies
- Reject non-essential cookies
- Customize cookie preferences
- Learn more about each cookie type
Managing Cookie Preferences:
- Browser settings: Control cookies through your browser
- Opt-out tools: Use industry opt-out mechanisms
- Privacy settings: Update preferences at any time
- Cookie policy: Detailed information about all cookies used
DATA SECURITY
TECHNICAL SAFEGUARDS
Encryption:
- Data in transit: TLS 1.3 encryption for all data transmission
- Data at rest: AES-256 encryption for stored data
- Database encryption: Encrypted database storage
- Backup encryption: Encrypted backup and disaster recovery
Access Controls:
- Multi-factor authentication: Required for all system access
- Role-based permissions: Least privilege access principles
- Regular access reviews: Quarterly access audits
- Secure authentication: Strong password requirements
Network Security:
- Firewalls: Advanced threat protection
- Intrusion detection: Real-time security monitoring
- Vulnerability scanning: Regular security assessments
- Secure hosting: SOC 2 compliant hosting providers
ORGANIZATIONAL SAFEGUARDS
Privacy Training:
- Staff training: Regular privacy and security training
- Awareness programs: Ongoing security awareness
- Incident response: Trained incident response team
- Compliance monitoring: Regular compliance assessments
Vendor Management:
- Due diligence: Security assessments for all vendors
- Contractual protections: Data processing agreements
- Regular audits: Ongoing vendor security reviews
- Incident notification: Vendor breach notification requirements
DATA BREACH RESPONSE
Incident Response Plan:
- Detection and Assessment: Immediate threat evaluation
- Containment: Stop ongoing unauthorized access
- Investigation: Determine scope and cause of breach
- Notification: Notify authorities and affected individuals
- Recovery: Restore normal operations
- Lessons Learned: Improve security based on findings
Notification Timeline:
- Regulatory authorities: Within 72 hours (GDPR), as required by other laws
- Affected individuals: Without undue delay, as legally required
- Clients and partners: As contractually required
- Insurance providers: As required by insurance policies
CHILDREN'S PRIVACY
AGE RESTRICTIONS
Our services are not directed to children under 16 years of age (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children.
If We Learn of Child Data Collection:
- Immediately delete the child's personal information
- Notify parents/guardians if contact information is available
- Implement additional safeguards to prevent future collection
- Review and update age verification procedures
Parental Rights:
Parents and guardians may:
- Request access to their child's information
- Request deletion of their child's information
- Object to processing of their child's information
- Contact us with concerns about child privacy
THIRD-PARTY WEBSITES AND SERVICES
EXTERNAL LINKS
Our website may contain links to third-party websites, including:
- Industry resources: Professional associations and publications
- Technology vendors: Software and service providers
- Social media platforms: LinkedIn, Twitter, YouTube
- Educational content: Webinars, whitepapers, case studies
Third-Party Privacy Practices:
- We are not responsible for third-party privacy practices
- We encourage you to review third-party privacy policies
- Third-party data collection is governed by their policies
- We may receive analytics data from third-party platforms
SOCIAL MEDIA INTEGRATION
Social Media Plugins:
- LinkedIn: Professional networking and content sharing
- Twitter: Industry news and thought leadership
- YouTube: Educational videos and webinars
Social Media Data:
- Social media interactions are governed by platform privacy policies
- We may receive aggregated analytics data
- Direct messages and comments may be stored
- Social media advertising uses platform targeting
MARKETING COMMUNICATIONS
EMAIL MARKETING
Consent and Opt-In:
- Double opt-in: Confirmation required for newsletter subscriptions
- Clear consent: Explicit consent for marketing communications
- Purpose specification: Clear explanation of communication types
- Easy unsubscribe: One-click unsubscribe in every email
Marketing Communication Types:
- Newsletters: Industry insights and company updates
- Educational content: Whitepapers, webinars, and resources
- Service announcements: New services and capabilities
- Event invitations: Workshops, conferences, and networking
Personalization and Segmentation:
- Interest-based: Content relevant to your industry and role
- Behavior-based: Based on website and email interactions
- Preference-based: Frequency and content type preferences
- Geographic: Location-relevant content and events
DIRECT MARKETING COMPLIANCE
Canadian Anti-Spam Legislation (CASL):
- Explicit or implied consent for commercial electronic messages
- Clear identification of sender and contact information
- Unsubscribe mechanism in every message
- Consent records maintained for three years
US CAN-SPAM Act:
- Truthful header information and subject lines
- Clear identification as advertising when applicable
- Valid physical postal address in every email
- Honor unsubscribe requests within 10 business days
EU ePrivacy Directive:
- Prior consent for electronic marketing
- Clear and specific consent requests
- Easy withdrawal of consent
- Respect for Do Not Call registries
BUSINESS TRANSFERS
MERGER, ACQUISITION, OR SALE
In the event of a merger, acquisition, bankruptcy, or sale of all or part of our assets, your personal information may be transferred to the successor entity, subject to the following protections:
Notice and Consent:
- Advance notice: Notification before transfer completion
- Consent requirements: Additional consent if practices change significantly
- Opt-out opportunity: Right to object to transfer in applicable jurisdictions
- Continued protection: Successor bound by this privacy policy
Due Diligence:
- Privacy assessment: Evaluation of successor's privacy practices
- Contractual protections: Data protection requirements in transfer agreements
- Transition planning: Secure data transfer procedures
- Compliance verification: Ensuring continued regulatory compliance
UPDATES TO THIS PRIVACY POLICY
POLICY CHANGES
Notification of Changes:
- Email notification: For material changes affecting your rights
- Website notice: Prominent notice on our website
- Effective date: Clear indication of when changes take effect
- Version history: Previous versions available upon request
Types of Changes:
- Legal compliance: Updates required by new laws or regulations
- Service changes: Modifications to our services or practices
- Clarifications: Improvements to policy clarity and understanding
- Contact updates: Changes to contact information or procedures
Your Options:
- Review changes: Take time to understand new terms
- Contact us: Ask questions about changes
- Exercise rights: Update preferences or withdraw consent
- Opt out: Choose not to continue using our services
REGULATORY COMPLIANCE
PRIVACY AUTHORITIES
Canadian Privacy Commissioner:
European Data Protection Authorities:
- EU Data Protection Board: edpb.europa.eu
- Local supervisory authorities: Contact information varies by member state
US Privacy Regulators:
- Federal Trade Commission: www.ftc.gov
- State attorneys general: Contact information varies by state
- California Privacy Protection Agency: cppa.ca.gov
COMPLAINT PROCEDURES
Internal Complaint Process:
- Contact our privacy officer: communications@nextechsoftware.ca
- Provide details: Specific concerns and desired resolution
- Investigation: We will investigate and respond within 30 days
- Resolution: We will work with you to resolve the issue
External Complaints:
If you're not satisfied with our response, you may file a complaint with:
- Your local privacy authority
- The privacy commissioner in your jurisdiction
- Industry-specific regulators
- Consumer protection agencies
SPECIAL PROVISIONS
CALIFORNIA RESIDENTS
CCPA Consumer Rights:
- Right to Know: Categories and specific pieces of personal information
- Right to Delete: Request deletion of personal information
- Right to Opt-Out: We don't sell personal information
- Right to Non-Discrimination: Equal service regardless of privacy choices
Shine the Light Law:
California residents may request information about sharing of personal information with third parties for marketing purposes.
EUROPEAN UNION RESIDENTS
GDPR Additional Protections:
- Data Protection Officer: Available for privacy questions
- Legal basis: Specific legal basis for each processing activity
- Data minimization: We collect only necessary information
- Purpose limitation: Data used only for stated purposes
Cross-Border Transfers:
- Adequacy decisions: Transfers to countries with adequate protection
- Standard contractual clauses: EU-approved transfer mechanisms
- Binding corporate rules: Internal data transfer policies
NEVADA RESIDENTS
Nevada residents have the right to opt out of the sale of certain personal information. We do not sell personal information as defined by Nevada law.
DEFINITIONS
Personal Information:
Information that identifies, relates to, describes, or could reasonably be linked with a particular individual or household.
Processing:
Any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.
Controller:
The entity that determines the purposes and means of processing personal data.
Processor:
The entity that processes personal data on behalf of the controller.
Consent:
Freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data.
Data Subject:
An identified or identifiable natural person whose personal data is processed.
CONTACT US
For any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Primary Contact:Cosmina Buiga Consulting
Privacy Officer
Email: communications@nextechsoftware.ca
Phone: (647) 2955516
European Representative (if applicable):[EU Representative Name and Address]
Response Time: We will respond to privacy inquiries within 30 days of receipt.
© 2025 Nextech Software Inc. All rights reserved.
This Privacy Policy was last updated on January 1, 2025. Please check this page periodically for updates.
PRIVACY POLICY SUMMARY
What We Collect: Contact information, professional details, and website usage data
How We Use It: Service delivery, communications, and business improvement
Who We Share With: Service providers only, never sold to third parties
Your Rights: Access, correction, deletion, and communication preferences
Contact: communications@nextechsoftware.ca for all privacy questions
This summary is for convenience only. Please read the full policy above for complete details.