Privacy Policy

PRIVACY POLICY LAST UPDATED: May 15, 2026

Protecting your privacy is important to us.

We pledge to respect your privacy, to be transparent about our data practices, to keep your data safe, and to only collect data that helps us deliver and improve our Services.

With this in mind, we're providing this Privacy Notice to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Notice does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Our CEO serves as our Data Protection Officer.

In this Privacy Notice:

• We'll refer to 17075855 Canada Inc as "Junction" or "we" or "us". We'll refer to our website as the Site.

• We'll refer to the suite of software-as-a-service (SaaS) products and digital services we provide individually and collectively as the "Services".

• We'll refer to you, the person or entity accessing our Site or using our Services, as "you" or "your" or (if you are a purchaser of our Services), our "customer".

By providing information to us or by using our Site and/or our applications, and submitting or otherwise providing information, you agree that we may collect, use and disclose your information according to the terms of this Privacy Notice.

Notes on Applicable Law

Junction is subject to the Personal Information Protection and Electronic Documents Act ("PIPEDA"). Junction relies on PIPEDA and Canada's partial adequacy status where applicable. For information related to citizens of the State of California or of the European Union, please see the sections below dedicated to those topics.

What is Personal Information?

Personal information is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.

Personal Information does not include "aggregated and de-identified" or other non-personally identifiable information. Aggregated and de-identified information is information that we collect about a group of individuals that is not personally identifiable or from which individual identities are removed.

What Information Do We Collect?

We limit our collection of Personal Information to that which is necessary for its intended purpose. For example, we collect personal information related to your user account so that we can provide our customers with the software capabilities and information services necessary to utilize our SaaS platform efficiently, and bill our customers accurately for the products and services we provide to them.

We may collect the following types of Personal Information from you:

• Your first and last name, username, and email address.

• Your company's name.

• Your (and/or your company's) physical address.

• Your business tax identification number (where applicable for verification or billing).

• We may also collect information about your use of our Site and our Services. That information could include the date, time and type of your activity on the Site, digital device information such as your device type, mobile device advertising identifier, MAC address, Internet Protocol (IP) address, browser type, user settings, operating system, and internet activity information about how your device has interacted with our Site or Services such as the web page that you were visiting before accessing our Site, the pages or features of our Site which you browsed and the time spent on those pages or features, search terms, the links on our Site that you clicked on, and how you interact with marketing emails and other communications we may send you. An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet.

We may also permit third-party online advertising networks to collect information (through Cookies or similar tracking technology) about your visits to our Site and use of our Services, in order to allow those third-party networks to display ads on third-party websites and apps that may be relevant to your interests in our Services. You may be able to opt-out from allowing these third-party online advertising networks to collect your Personal Information; please see the "Your Choices About Your Personal Information", "Your Rights" and "European Data Protection Rights" sections below.

How Do We Collect Personal Information? How Do We Obtain Consent?

The Personal Information we collect depends on how you interact with us and the choices you make. We collect and process personal data about you with your consent and/or as necessary to provide the products and services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.

We collect Personal Information in several ways:

• Information you provide to us voluntarily. We may ask you to provide Personal Information voluntarily, including information you provide us when you create an account or contact us for help through the Services. That information may include your name and email address along with additional information you provide in signing up for your account or in your request so that we can provide you with assistance and improve the Service. If you make a purchase, we may also collect credit card numbers and other payment information.

• Information we may receive from third parties. We may receive information about you, including Personal Information, from third parties, and may combine this information with other Personal Information we maintain about you. If we receive information about you, including Personal information, from third parties, this Privacy Notice governs any combined information that we maintain in a personally identifiable format.

• Information we collect automatically from your device. When you visit our Site or use our Services, as part of the standard operation of the Site, we may collect and analyze information from your computer or mobile device and actions taken on the Site, including, but not limited to, information set forth above under "What information do we collect?". Some of this information may be collected using cookies and similar technologies.

• Information we collect using officially sanctioned payment processor integrations. Customers who elect to connect their payment processors to us using their payment processor's official integrations allow us to collect relevant data directly from the payment processor.

Consent. The consent we obtain from an individual must be informed at the time it is collected, except where inappropriate. The form of consent, whether it is express or implied, will primarily depend on the relationship between Junction and the individual, the sensitivity of the personal information, and the reasonable expectations of the individual in the circumstances.

We will not, as a condition of the supply of our Services, require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfil the purposes described above or otherwise described at the time consent is sought. When you provide us with personal information relating to an individual other than yourself, we rely on you to obtain that individual's consent to our collection, use and disclosure of their personal information in the circumstances described above.

What Are Some of the Legal Bases for Collecting Your Information?

We collect and process your Personal Information on the basis of different legal grounds, depending on the nature of the Personal Information being provided and the type of processing involved. Examples include:

• Performance of a Contract. Some of the Personal Information processed by us is processed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at your request prior to entering such an agreement.

• Legitimate Interest. In some cases, processing of your Personal Information is necessary for the purposes of legitimate interests pursued by us. Examples of such legitimate interests will include where we send you marketing about our products and services, where we believe you have a reasonable expectation that we will perform a particular type of processing on your behalf, and where such processing is strictly necessary for fraud detection and prevention. We will only rely on such a ground where an assessment has been performed balancing the interests and rights involved and the necessity of the processing in order to provide our services, products and features to you.

• Compliance with a Legal Obligation. It may be necessary to process your Personal Information in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.

• Consent. In certain limited situations, we rely on your consent in order to process your Personal Information. Where we require your consent, we seek it at the time of provision, and the processing will only be performed where consent is secured. You can withdraw your consent, as detailed in this Privacy Notice where applicable, or by sending an email to info@withjunction.com.

For What Do We Use Your Personal Information?

We will use your Personal Information in compliance with this Privacy Notice to maintain and improve the quality of our Site, to help us deliver the Services to you, and to improve the Services. Any of the information we collect from you may be used in any of the following ways:

• To operate, maintain, and provide to you the features and functionality of the Services (for example, data and logs are used to understand and improve the Services; to troubleshoot the Services; to detect and protect against error, fraud or other criminal activity; and to enforce this Privacy Notice and the Junction Terms of Use).

• To provide our customers with timely and reliable products and digital services, including account management, software deployment, user support, platform feature updates, and communication with our customers about the status of their accounts (including through our online dashboard, by telephone or by e-mail).

• To bill our customers for the products and services we provide them, including the verification of their credit, the authentication of their identities, and the production of detailed invoices that help them verify the charges billed to them.

• To compile statistics and analysis about your and others' use of our Site and our Services.

• To personalize your experience (for example, to display content, including potentially advertising, that is customized to your interests and preferences); your Personal Information helps us to better respond to your individual needs.

• To improve our Site and our Services; we continually strive to improve our Site offerings based on the information and feedback we receive from you.

• To improve customer service; your Personal Information helps us to more effectively respond to your customer service requests and support needs.

• To send periodic emails; the email address you provide may be used to send you information and notifications that you request about our Services, to alert you of updates to our policies and Services, and to provide you information relevant to your account.

• To send you a newsletter.

• If you purchase our Services, then to enable you to purchase Services from our Site.

• We may also use Personal Information you provide to contact you regarding products, services, and offers that we believe you may find of interest. We allow you to opt-out from receiving marketing communications from us as described in the "Your Choices About Your Personal Information", "Your Rights" and "European Data Protection Rights" sections below.

• In addition, de-identified data that does not identify you may be used to market and promote Junction offerings or for sale to interested audiences. See "Do We Disclose any Personal Information to Outside Parties?" to learn more.

We may also use your Personal Information where necessary for us to comply with a legal obligation, including to share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. 

• We may disclose your Personal Information to government or law enforcement officials or private parties as we believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.

• We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam or fraud. However, such detection methods are not perfect and false positives may occur. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.

If required to do so by applicable data privacy laws, we will request your consent before we use or disclose your Personal Information for a materially different purpose than those set forth in this Privacy Notice. Consent may be obtained by any legally sufficient method. For example, depending on the circumstances and applicable laws, consent may be obtained by providing you with notice and the opportunity to opt-out.

Do We Disclose Any Personal Information to Outside Parties?

We may disclose Personal Information to third parties for a variety of business or commercial purposes. This includes the following disclosures:

• We may share your Personal Information with other companies owned by or under common ownership with Junction. As of the date of this Privacy Notice we have no other group companies. 

  • These companies, if any, may use your Personal Information in the same way as we can under this Privacy Notice for our operational business purposes.

• We may disclose your Personal Information to third-party service providers (for example, payment processing, data hosting, cloud infrastructure, analytics providers, or customer support tools) that assist us in our work for our operational business purposes. 

  • We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information. We require those companies to use your Personal Information solely for the purposes for which it was provided and consistent with this Privacy Notice.

• We may contract with third-party service providers to assist us in better understanding our Site's visitors. 

  • These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

• We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our Site's policies, or protect our or others' rights, property, or safety. 

  • In particular, we may release your Personal Information to third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Junction, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

• If you ask us to do so, we may share your Personal Information with the public and other users of the Services. Any information or content that you voluntarily disclose for public posting to the Service, such as user-generated content or forum posts, becomes available to the public. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Service, or if other users of the Services have copied or saved that information.

• You can direct us to share data with other parties. Once you direct us to share your data with a third party, that data is governed by the third party's Privacy Notice.

• We may also share certain information such as your location, browser and cookie data and other data relating to your use of our Services with our business partners to deliver advertisements ("ads") that may be of interest to you. 

  • We may allow third-party ad servers or ad networks to serve advertisements services related to our business. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Services, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs) to compile information about your browser's or device's visits and usage patterns on the Services, and to measure the effectiveness of their ads and to personalize the advertising content.

  • Please note that an advertiser may ask us to show an ad to a certain audience of users of the Site or the Services (for example, based on demographics or other interests). In that situation, Junction determines the target audience and Junction serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

• Your Personal Information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of our businesses or assets. 

  • This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your Personal Information or as otherwise may be required or permitted by law.

How Do We Protect Your Personal Information?

Junction supports the exercise of your data protection rights in accordance with applicable data protection laws. We care about the security of your Personal Information and strive to protect it. PIPEDA contains 10 fair information principles incorporated into our privacy governance and provide our employees, customers, vendors and other third parties with confidence over how their personal information is handled. Junction recognizes the importance of accountability. This means taking responsibility for the personal information under its control through the management of its Privacy Office that oversees privacy governance.

To help protect your privacy and security, we use appropriate security measures to protect the security of your Personal Information both online and offline. These security measures vary based on the sensitivity of the information. However, no website or internet transmission is completely secure and we cannot guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed. And you are responsible for maintaining the secrecy of your unique password and account information and email communications while they are under your control.

Upon becoming aware of a breach of your Personal Information, we will notify you as quickly as we can and will provide timely information relating to the breach as it becomes known in accordance with any applicable laws and regulations or as is reasonably requested by you. If you have any concerns over the security of your Personal Information, please contact us at info@withjunction.com.

Who at Junction May Access Your Personal Information?

Designated members of our staff may access your Personal Information to help you with any questions you have, including help using our Services, or investigating security issues. This activity is logged in our system for compliance, and we maintain different levels of access for various employees depending on his or her role in our company.

Some types of Personal Information may be accessible only to certain types of employees, consultants, or contractors who need to know this Personal Information to perform the tasks associated with the worker's role (finance, administration, sales, marketing, legal, system administration).

Do We Use Cookies?

Yes. Cookies are small files that a website or its service provider transfers to your computer's hard drive through your Web browser (if you allow). These cookies enable the Site to recognize your browser and, if you have a registered account, associate it with your registered account.

We may use both session Cookies and persistent Cookies to identify that you've logged in to the Services and to tell us how and when you interact with our Site. We use cookies to remember information so that you will not have to re-enter it during your visit or the next time you visit the Site, and to understand and save your preferences for future visits and compile aggregate data about the Site's traffic and interaction so that we can offer better experiences and tools in the future.

We may also use Cookies to provide aggregated information on Site usage and patterns. We may also use Cookies to monitor web traffic routing on our Services and to customize and improve our Services, to provide custom, personalized content and information relevant to your interest in our Services, including advertising, and to diagnose or fix technology problems.

Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don't accept Cookies, you may not be able to access all portions or features of the Site or the Services.

We may also collect information via standard server logs or clear GIFs (also known as "Web beacons"). Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. Junction, or third-party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality.

Your browser may provide you the option of blocking cookies, such as third-party cookies. Some browsers also give you the ability to review and manage cookies individually. We encourage you to review your browser's settings and documentation for additional information on any controls your browser may offer and how they work. Please note, if you delete from your device or browser any cookie Junction uses on our Site, but do not set your browser or device to block third-party cookies, we may install the same cookie during a later visit. Some third-party cookies are also integral to the services we provide on our Site. By blocking third-party cookies, you may not be able to take advantage of all of the features available on our Site.

Your Choices About Your Personal Information

We may use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out. If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this Privacy Notice. Additionally, if we offer user accounts for our Services, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.

Please be aware that if you opt out of receiving commercial e-mail from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial e-mail from us during that period. Additionally, even after you opt out from receiving commercial messages from us, if you are our customer then you will continue to receive administrative messages from us regarding our Services (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

You may modify Personal Information that you provide to us. If you are our customer and remove data from your Junction user account for our Services, it will no longer appear to you. Backups of that data will remain associated with your Junction account and in our archive servers.

Your Rights to Opt Out. You can opt-out of receiving commercial email or other email not directly related to customer data or your account settings by unsubscribing via the "Unsubscribe" link in any Junction email. If you are our customer then opting out of these emails will not end transmission of important service-related emails that are necessary to your use of the Services.

In addition, you may opt out of allowing third-party online advertising networks to collect information from our Site by adjusting the browser "settings" on your computer or mobile device. Please refer to your mobile device or browser's technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents us or our business partners from tracking your browser's activities in relation to the Service, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Services. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly.

Analytics

Our Site may include Cookies from third-party service providers. In some cases, that is because we have hired the third party to provide services on our behalf, such as site analytics. For this purpose, Junction may work with various third-party partners like Amazon, Facebook and/or Google to see what actions you take on third party websites to deliver our personalized ads to you via third party websites. We use Demographics and Interest reporting features in Google Analytics to inform our requests to our service providers.

Our third-party partners like Google use Cookies on our site to:

• Measure and analyze aggregate usage and volume statistical information from our users on our site. Information gathered may include, but is not limited to the following: activity of the user browser when the user is visiting the site, the site path of users, general information regarding the visitor's internet service provider and host, and the time users come to the site.

• Remember our users' previous search of products and services, and dynamically display more relevant content to them.

• Record users' behavior on our site, such as pages visited, emails clicked, forms completed and products and services purchased to create customized advertisements and communications that better meet your needs.

• Evaluate user traffic and behavior on the site to compile activity reports.

• Conduct research and diagnostics to improve our products and services.

• Identify users arriving at the site via a referral from an affiliate website or sponsored link.

Google's ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Learn more about privacy at Google here.

"Do Not Track" Options Will Not Affect How We Use Your Personal Information

Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time. As discussed above, we track our Site's usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you after you leave our Site across websites or apps over time, your selection of the "Do Not Track" option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

Your Rights

In addition to other rights provided for in this Privacy Notice, you have the rights to:

• Withdraw your consent where you have previously given your consent to the processing of your Personal Information.

• Object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent.

• Ask for a copy of your Personal Information. This is known as a Subject Access Request. If you would like a copy of some or all your Personal Information, please email info@withjunction.com.

• Ask us to correct your Personal Information. It is your right to lodge an objection to the processing of your Personal Information if you believe that the legal ground "relating to your particular situation" applies. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

• Ask us to transfer your Personal Information to other organizations.

• Ask us to erase certain categories or types of information. If you choose to remove your Personal Information, you acknowledge that we may retain archived copies of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

• Ask us to restrict certain processing or "opt out" of certain sharing of Personal Information. You may limit or "opt out" of our sharing your Personal Information with third parties. For further information on opting out, please see the "Your Choices About Your Personal Information" section of this Privacy Notice.

• Bring a claim before a competent data protection authority.

Restrictions: Information about Children

We offer the Services only to adults age 18 and over. We strive to comply with the requirements of COPPA (Children's Online Privacy Protection Act). Further, we do not knowingly collect any Personal Information from children under the age of 16. If we discover we have received any Personal Information from a child under the age of 16 then we will take reasonable steps to delete the information as quickly as possible. If you believe we have any such information please contact us as described at "Contacting Us" below.

Social Media

On some pages of our Site, we may allow you to share personal data with third parties, such as social networks like Facebook. In these instances, you are agreeing to the data being shared and the shared data is subject to the privacy policies of such third parties.

We may combine information we receive from those platforms (e.g., profile information, likes, pageviews) with other information we collect from you or other sources and use and disclose it as described in this privacy policy. Except where required by applicable law or regulation, we do not control and do not assume any responsibility for the use of personal data by such third parties. For more information about the third party's purpose and scope of their use of personal data in connection with sharing features, please visit the privacy policies of these third parties.

Public Areas

Our Site may include discussion forums or other interactive areas or services, including blogs, chat rooms, bulletin boards, message boards, online hosting or storage services, or other areas or services in which you or third parties create, post or store any content, messages, comments, materials or other items on the Site ("Interactive Areas").

If you use an Interactive Area, you should be aware that these areas are open to the public and any personal data you post or provide at registration may be viewable by others. We are not responsible for public disclosure of personal data you submit in connection with the Interactive Areas, nor are we responsible for how others might use that information, including to send you unsolicited messages. Interactive Area postings may be retained indefinitely. If at any time you would like to request that we remove a posting, please email us at info@withjunction.com. Please keep in mind that removal of a posting from an Interactive Area does not necessarily mean that the posting will be deleted from our backend systems.

Retention of Your Personal Information

We retain your Personal Information for as long as we have a legitimate business purpose to retain the information, or as otherwise allowed by applicable law. Junction may also store the information detailed in this Privacy Notice on its equipment or the equipment of third parties with whom Junction has a relationship. Such storage services will be governed by appropriate protections, as required by applicable rules.

Please be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable. These service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Information, by these companies.

Third-party Links

This Site may make available links to other third-party websites. This Privacy Notice only applies to our Site, so when you link to other websites you should read those separate and independent privacy policies. Your browsing and interaction on any third-party websites, app, or service, including those that have a link or advertisement on our Site, are subject to that third party's own rules and policies. We are not responsible for the practices employed by websites, mobile apps, or services linked to or from the Service, including the information or content contained therein. In addition, you agree that we are not responsible for and we do not have any control over any third parties that you authorize to access your Personal Information. However, we seek to protect the integrity of our Site and welcome any feedback about these websites.

Changes to Our Privacy Notice

We are constantly trying to improve our Site and the Services, so this Privacy Notice may need to change. If we change the Privacy Notice then we will notify you here in this Privacy Notice by describing the changes at the top of this Privacy Notice. Please review the "Last Updated" legend at the top of this page to determine when this Privacy Notice was last amended. Any changes to this Privacy Notice will become effective on the "Last Updated" date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Notice. If we are going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then we will notify you via email and/or by posting a notice on the Site for 30 days prior to such use or by other means as required by law.

Contacting Us

If you have any questions, comments, complaints or concerns about this Privacy Notice, please contact us using the following contact information. We prefer email.

Junction

Attn: Privacy Issues

211-56 The Esplanade

Toronto, ON M5E 1A6 Canada

info@withjunction.com

Special Provisions Applicable to Residents of California

If you are a California resident, you may have additional rights under the California Consumer Privacy Act ("CCPA") relating to the collection and processing of your personal information. 

For purposes of this section, the terms personal information, consumer, and sell or sold shall be defined only as broadly as set forth in the CCPA and to the extent applicable to the Site visitor.

• We do not sell the personal information of California consumers. 

• We have no actual knowledge that we have sold personal information of minors under the age of 16 years old.

California's "Shine the Light" law, California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.

California residents also have the following rights:

• You can request to know, access, correct, update or delete your Personal Information by contacting us using the contact details provided under "Contacting Us" above, and we will fulfill your request in accordance with applicable data protection laws. We may need to verify your identity in order to action your request, including by asking for you to provide a government-issued identification document. Once we have verified you, we will respond and comply with your specific requests.

• You have the right to opt out of the sale of your Personal Information, described in the Section "Do we disclose any Personal Information to outside parties?". If you wish to opt out from the sale of your Personal Information, you can do so by contacting us as described above at "Contacting Us."

• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under "Contacting Us."

• You have the right not to receive discriminatory treatment for the exercise of your privacy rights under California law.

Special Provisions Applicable to Residents of the European Union

This section of our Privacy Notice applies to all personal information that is governed by the General Data Protection Regulations (the "GDPR"), within the territorial scope of the GDPR, that may be used to identify you as a visitor to our Site and that is obtained by us in connection with the Site or providing a product or service to you as part of our operations.

What is a Data Controller? For general data protection regulation purposes, the "Data Controller" means the organization who decides the purposes for which, and the way in which, any Personal Information is processed. Our customers and website visitors are the Data Controllers.

What is a Data Processor? A "Data Processor" is an organization which processes Personal Information for a Data Controller. We are the Data Processor for our customers. As a Data Processor, we may be bound by the requirements of the GDPR.

What is Data Processing? Data processing is any operation or set of operations (whether automated or not) performed upon Personal Information. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

Junction's own data centers are located in Canada and the United States, and by interacting with our Site and using our Services, or otherwise providing your Personal Information to us, your Personal Information will be transferred to and processed in Canada and the United States.

In some cases, Junction may share your Personal Information with its subprocessors, to the extent permitted by applicable law. Each of these subprocessors are limited to accessing or using this Personal Information to provide our hosted services only and must provide reasonable assurances that they will appropriately safeguard any customer data provided by Junction. Each of these subprocessors using customer data processes this data in Canada and the United States.

By submitting your Personal Information, you're agreeing to this transfer, storing or processing. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Canadian law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. If we transfer your Personal Information from the E.U. and process it in Canada, we do so in accordance with applicable law. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

• You can request access to, and rectification or erasure of, personal data;

• If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of your personal data in a usable and portable format;

• If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;

• You can object to, or obtain a restriction of, the processing of personal data under certain circumstances; and

• For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, contact us at info@withjunction.com. When we are processing data on behalf of another party that is the Data Controller, you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns. Please be aware that those rights set out above may not apply in some instances, for example where our right to processing your personal data may be necessary for exercising the right of freedom of expression (e.g., news gathering); or for the establishment, exercise or defense of legal claims.

Governed by the requirements contained in GDPR, we will provide you with a reasonable opportunity to access your Personal Information that we have collected, correct it if it is inaccurate, erase it, or to request we restrict processing of the data. You also have the right to data portability, to have us provide the data to other entities. Please see GDPR Articles 15 through 18 then 20 for the requirements and procedures necessary to exercise these rights.

We do not engage in automated data processing or profiling as those terms are understood under GDPR.

With respect to these rights:

• (a) we reserve the right to not provide information until we receive adequate information to identify that you are the relevant data subject and to request additional information to confirm your identity;

• (b) with an access request or data portability request, we reserve the right to deny access to information where the rights or freedoms of other individuals may be adversely affected;

• (c) for requests for copies of data pursuant to an access request, we reserve the right to charge an administrative fee for any request after the first;

• (d) when requests are manifestly unfounded or excessive, we reserve the right to charge an administrative fee or to refuse to act on the request.

When the purpose for data processing is based on consent, you have the right to withdraw consent at any time, although that does not affect the lawfulness of processing based on consent before it is withdrawn. When the purpose for data processing is based on contract, we will likely not be able to provide you services without the Personal Information we request and so will likely have to terminate the relationship.