Privacy Policy

1. Who we are

UpGrow inc. (“UpGrow”, “we”, “us”) is a precision-manufacturing company based in Quebec, Canada. We are responsible for the personal information described in this policy.

This policy covers our public website, https://upgrow.ca. It does not cover https://app.upgrow.ca, our access-controlled client production tracker — what happens in there is governed by your client agreement with us.

2. What we collect

It depends entirely on how you use the site. There are three groups, and most visitors only ever fall into the first.

• If you just browse. Pages you viewed and how long you stayed, the link or search that sent you here, an approximate location worked out from your IP address (city and country level, never your precise position), and your device type, browser, operating system and screen size. Only if you accept cookies do we also store a random identifier that tells one visit apart from another. We do not learn your name from any of this, and we do not try to work out who you are.
• If you book a call. Your name, your email address, your time zone, and whatever you write in the box describing what you want to discuss. Our scheduler collects it and we use it to hold the meeting and follow up afterwards.
• If you become a client or a supplier. Your business contact details and the project information you send us: drawings, specifications, tolerances, quantities, delivery requirements. We treat your drawings and specifications as confidential and they never leave the people working on your quote or your order.

3. What we never do

• Sell, rent, or trade your personal information.
• Hand it to advertisers, ad networks, or data brokers.
• Run advertising or retargeting pixels on this site.
• Build a behavioural profile of you.
• Use your information to make an automated decision about you, with no human involved.
• Send you marketing you did not ask for.

4. Cookies and tracking

A cookie is a small file a site stores in your browser. We set none of them until you say yes, and none of them are for advertising.

By default our analytics runs in a cookieless mode: it counts the visit without writing anything to your browser and without any identifier that could single you out. The cookies in the table below come into existence only if you press Accept on the notice at the bottom of the page. Ignore that notice and nothing is ever stored.

• Google Analytics opt-out add-on

Changed your mind? Clearing this site's data in your browser settings resets your choice and puts you back to the cookieless default. You can also block cookies outright or install Google's official opt-out add-on. The site works identically either way — nothing here depends on being tracked.

5. Who we share it with

A small number of service providers, and only so they can do a specific job for us. Each one is bound by a written agreement that limits what they may do with your information. They may not use it for their own purposes.

We will also disclose information where the law genuinely requires it — a court order, a subpoena, a lawful demand from a regulator. If that happens and we are permitted to tell you, we will.

6. Where your information goes

We are in Canada. The providers listed above are in the United States, so some of your information is stored or processed outside Canada, under different privacy laws.

Before your information leaves Quebec we satisfy ourselves that it will receive protection adequate to what it gets here, which is what Law 25 requires of us, and each transfer is covered by a written agreement with the provider. If we ever conclude a provider no longer meets that bar, we replace them.

7. How long we keep it

We keep it for as long as it is genuinely useful, then it goes.

• Analytics: no longer than 14 months, then Google deletes it automatically.
• Booking and enquiry details: 24 months after we last spoke.
• Client project records: 7 years after your last order. Tax rules and our ISO 9001 and ISO 13485 quality systems require us to keep production records that long.
• Anything you ask us to delete: gone within 30 days, unless the law requires us to hold on to it. If that is the case we will tell you which rule applies and when it expires.

8. How we protect it

• Every page of this site is served over HTTPS, so what you send is encrypted in transit.
• Access is limited to the people who need it to do their job.
• Multi-factor authentication is on the accounts that hold it.
• Client drawings and specifications are held under confidentiality and are never used for anyone else's work.

No system is perfect. If a breach ever happens that presents a risk of serious injury, we will notify you and the Commission d'accès à l'information du Québec promptly, as Law 25 requires, and we will tell you plainly what happened.

9. Your rights

Whatever we hold about you, you can ask us to:

• Show it to you — get a copy of the personal information we hold about you.
• Fix it — correct anything inaccurate, incomplete, or out of date.
• Delete it — remove it, unless the law requires us to keep it.
• Stop — withdraw your consent to analytics or to marketing at any time.
• Move it — receive it in a structured, commonly used technical format so you can take it elsewhere.
• De-index it — ask us to stop disseminating information about you, or to de-index a link to it, where the law allows.

• Commission d'accès à l'information du Québec
• Office of the Privacy Commissioner of Canada

Email privacy@upgrow.ca. We answer within 30 days and it costs you nothing. If you are not satisfied with our answer, you can complain to the regulator — you do not need our permission and we will not hold it against you.

10. Our Privacy Officer

Law 25 requires us to name the person accountable for protecting your information, and to publish how to reach them. That role sits with the person exercising the highest authority at UpGrow.

Write to the Privacy Officer at privacy@upgrow.ca and it reaches them directly.

11. Automated decisions and profiling

We do not use your personal information to make a decision about you based solely on automated processing. A person is always involved. If that ever changes we will tell you before it does, and you will be able to ask why a decision was made and have it reviewed.

12. Children

This is a business-to-business site and it is not aimed at children. We do not knowingly collect personal information from anyone under 14. If we find out that we have, we delete it.

13. Changes to this policy

When we change this policy we post the new version here and update the date at the top. If a change materially affects your rights we will say so clearly on this page rather than quietly swapping the file.

14. Contact us

Questions about this policy, or about anything we hold on you, go to one address and a human reads it.

• Privacy and data requests: privacy@upgrow.ca
• Everything else: info@upgrow.ca
• Company: UpGrow inc., Quebec, Canada