Privacy Policy

September 10, 2022


Our Commitment to Privacy

Garnet Labs Inc. and its representatives and affiliates (collectively, “Garnet”, “we”, “us” or “our”) are committed to protecting your privacy. This Privacy Policy (as updated from time to time, this “Privacy Policy”) has been designed to comply with Canada’s Personal Information Protection and Electronic Documents Act and other applicable federal, state and provincial privacy laws relating to the protection of personal information (collectively, “Privacy Laws”). This Privacy Policy forms part of and is hereby expressly incorporated into our Terms of Service (the “Agreement”).


In this Privacy Policy, we explain how we collect, use, disclose and protect the personal information of our Users (as defined below).

You are a “User” if you are an individual and you access our website located at or related links (collectively, the “Site”), install or use any other software supplied by us, access any information, function, feature, application, product or service made available by us or register an account with us (collectively, the “Service”).

Your “personal information” means any information about you as defined in applicable Privacy Laws and includes information such as your full name, address, postal code, email address and geographic location. It may also include information on how you use the Service. It does not include business contact information or certain publicly available information.


We may modify this Privacy Policy at any time for any reason, effective upon posting an updated version through the Service. If the modifications are significant, we will use commercially reasonable efforts to provide you with prior notice via email or other reasonable means. You should regularly review this Privacy Policy, as your continued use of the Service after the date on which an updated version becomes effective constitutes your acceptance of the updated Privacy Policy. In the event that you do not accept the updated Privacy Policy, your sole and exclusive remedy is to cease your access and use of the Service.


We may collect personal information when you provide it to us, including by way of your interaction with us and your access and use our Service. We try to minimize the collection of personal information to only what is reasonable and necessary to provide our Service and to develop, assess and improve our Service. We only collect personal information if non-identifying information is not sufficient for this purpose.

We may collect the following categories of personal information about you:

  • identifiers, which may include your name, address, email address, telephone number, social media ID, user ID, username or screen name, password, IP address or MAC address;
  • commercial information, which may include payment, banking or other financial information;
  • internet or network activity, which may include your operating system type and version, web server type and version, database type and version, cookie information, device information, browsing information, browsing activities, platform use data, mobile use data, referring domain, destination domain, destination path, performance, security, software configuration, website user statistics, viewing activity and communication preferences;
  • mobile device information, which may include your unique device identifier, mobile advertising identifier (assigned by your mobile platform), information about your mobile device screen size, date and time of mobile device use and other mobile device-related information;
  • geolocation information, which may include geographical information derived from your IP address, MAC address or device GPS;
  • audio, visual or electronic information, which may include screen sharing views or any data contained in files uploaded, emailed or otherwise provided by you;
  • information from third parties (where you have authorized it); and
  • other information, which may include the contents of your communications with us, whether through email, social media, telephone or otherwise, and inferences we may make from other personal information we collect.

Use and Disclosure

Purposes of Use and Disclosure

We may use or disclose the personal information we collect about you for the following purposes:

  • to verify your identity;
  • to contact you or your designated representatives;
  • to manage the administration of your account,
  • to provide you with our Service;
  • to maintain and improve our Service;
  • to develop new services;
  • to advertise, market and promote our Service
  • to identify new users or customers;
  • to measure our performance;
  • to tailor the content and advertising on our Site and other services;
  • to manage your preferences;
  • to provide a more personalized user experience;
  • to monitor your compliance with any of your agreements with us;
  • to satisfy our legal, regulatory, custodial and tax reporting requirements;
  • to establish our legal rights or defend against legal claims;
  • to protect you, us and others from fraud and error and to safeguard our business interests;
  • to collect debts owed to us;
  • to manage or transfer our assets or liabilities, which may include in the event of an acquisition, disposition, merger, amalgamation or other business transition or transaction; and
  • for any other purpose which we disclose to you from time to time.

If we ever wish to use or disclose the personal information we collect about you for a purpose not previously identified, the new purpose will disclosed to you prior to such use or disclosure and your consent to such use or disclosure will be sought (unless such use or disclosure is required or authorized by law).

Third Party Use and Disclosure

To the extent permitted by applicable law, we may disclose the personal information we collect about you to the following third parties:

  • our affiliates, agents or business partners;
  • our service providers, which may include service providers of website hosting, payment processing, product delivery, accounting services, legal services, tax services, consulting, professional advising, surveys, market research, data analysis, reporting, and marketing;
  • a purchaser, investor, new affiliate or other successor in the event that we or any affiliate, portion, group or business unit of us undergoes an acquisition, disposition, merger, amalgamation or other business transition or transaction;
  • legal, governmental, regulatory, tax or judicial authorities (“Authorities”) to comply with any law, directive, judicial or administrative order, legal process, investigation, warrant, subpoena, government request, regulatory request, law enforcement or as otherwise required or authorized by law or such Authorities; and
  • other third parties, including (a) to whom you have authorized us to disclose your personal information, (b) to investigate, prevent or take action regarding suspected illegal activities, fraud or violations of the Agreement, (c) to protect the safety or the security of persons or property, and (d) to the extent we believe is reasonable and necessary for the purposes set out in this Privacy Policy.

Whenever we disclose personal information to third parties, we try to minimize the disclosure of personal information to only what is reasonable and necessary for the third party to fulfill the particular purpose for disclosure. We also require, by contractual means, that the third party maintain and protect the confidentiality of the disclosed personal information to the same degree as it if were in our possession.

At times, we may transfer your personal information outside of Canada, including to third parties outside of Canada who may perform services for us which involve some of the personal information we collect about you. Accordingly, some of your information may be processed or stored in the jurisdiction where the third party is located. This information is subject to both the laws of Canada and the laws of the third party’s jurisdiction and may be accessible by the Authorities of other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession.

We will not collect, use or disclose your personal information without first obtaining your consent (except where required or authorized by law). Your consent can be express, implied or given through an authorized representative, such as a lawyer, agent or broker.

By accessing or using our Site or Service or voluntarily providing your personal information to us, you are consenting to the collection, use and disclosure of your personal information in accordance with this Privacy Policy

You may withdraw all or part of your consent for us to collect, use or disclose your personal information in accordance with this Privacy Policy at any time upon reasonable notice to us in writing, subject to legal, contractual or other restrictions. The withdrawal of your consent may affect our ability to provide you with the same access to or use of our Service.

You may also withdraw all or part of your consent to receive promotional emails from us by following the opt out instructions provided in such emails. If you opt-out, we may still send you non-promotional emails, such as messages about your account or our ongoing business relations.



We try to ensure that the personal information we collect about you is accurate, complete and up to date. In some cases, we rely on you to ensure that certain personal information, such as your address or telephone number, is accurate, complete and up to date. Users are requested to notify us as soon as possible of any changes, deletions or corrections to their personal information so that we may keep such information up to date.


With certain limited exceptions as provided under applicable Privacy Laws, you have the right to access your personal information held by us and to request that the information be corrected if it is inaccurate, incomplete or collected in violation of law. You may update or correct information about yourself by contacting us in accordance with Section 7. Please note that we may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons to do so, or if the information has been securely destroyed in accordance with our practices. Subject to legal or contractual restrictions, we will provide you with an explanation if we are unable to fulfill your access request. In accordance with applicable law, we must take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we may verify your identity through existing authentication practices for the account, such as your username and password. We may also verify your identity by matching two or three data points of identifying information about you.


We maintain physical, electronic and procedural controls consistent with regulatory standards to protect the personal information in our custody or control. Reasonable measures, such as system access security controls, safeguards to detect and prevent security system failures, restricted access, and employee training, have been implemented to help protect personal information from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. We also take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the third parties who assist us in providing products and services to you. However, please note that complete and permanent confidentiality and security cannot be guaranteed when information is transmitted electronically.

You can also play an important role in protecting your personal information. For example, you should:

  • create a strong and unique password for your user accounts;
  • never share your user accounts or passwords with anyone (note that we will never ask you for your password, including in any unsolicited communication such as letters, telephone calls or emails);
  • log out of your user account each time you are finished using it, especially if you share your device with others;
  • use a strong and unique password on your device; and
  • never post information on our Site that you do not want to be viewed or used by others.

Retention and Disposal

We retain personal information in accordance with our records retention program. Such personal information is retained for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer period is permitted or required under applicable law or is needed to resolve disputes or protect our legal rights. After this period, such personal information will be destroyed or disposed of in a manner commensurate with its sensitivity.

Other Data Practices

Cookies and Similar Technologies

We may use cookies and similar technologies to measure web activity to provide you with a better user experience on our Site and during the course of providing our Services. A “cookie” is a unique numeric code that we transfer to your device so that we can keep track of your interests and preferences and recognize you as a returning visitor to the Site and Service. If you choose not to accept cookies from us, you will still be able to access many of the features on our Site and Service, but with certain limitations to access and functionality.

Aggregated and Anonymized Personal Information

To the extent permitted by applicable law, we may uses, process, transfer and store data about Users or partners in an anonymous or pseudonymous manner. We may also aggregate statistics that we gather about our Users, sales, usage data and products and services. We may combine such anonymized and/or aggregated personal information with other information collected, including from third parties. With your consent or as permitted by applicable law, we may use such anonymized and/or aggregated personal information in ways and for purposes not previously identified in this Privacy Policy, including for benchmarking, analytics, research, reporting, machine learning and other business purposes.


Our Service is not targeted or directed at children under the age of 13, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us in accordance with Section 7 to request that we remove the information from our systems. If we learn that any personal information we collected has been provided by a child under the age of 13, we will promptly delete that personal information.

External Websites

Our Service may provide URL links to other websites, mobile applications, resources or Internet locations which we do not have control over (“External Websites”). Such links do not constitute an endorsement by us of those External Websites. We have no control over and are not responsible for External Websites, their content or any goods or services offered or made available on them. Your access to or use of any External Website is subject to the terms of use and privacy policy of that such External Website.

GDPR Privacy

We may process Personal Data under the following conditions:

  • Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre*contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
Your Rights under the GDPR

We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your Personal Data. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact Us to assist you. This also enables you to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about you. You have the right to to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it.
  • Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where ye used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Disclaimer to Complete Security

By accepting this Privacy Policy, you acknowledge and agree that no data transmission over the Internet is completely secure. We cannot guarantee or warrant the security of any information you provide to us and you transmit such information to us at your own risk.

Contact us

If you have questions or complaints with respect to our privacy policies and practices or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:

AttentionGarnet Labs Inc.
Mailing Address155 Wellington Street West
Toronto, Ontario
M5V 3J7 Canada
Email[email protected]

Inquiries or complaints will be dealt with promptly. We will acknowledge your query, investigate it and provide you with a response within 30 days.

File a Complaint

If you believe the Privacy Laws relating to the protection of your personal information or this Privacy Policy have not been respected, you may file a complaint with us. We will acknowledge your complaint, investigate it and provide you with a response within 30 days. If, after an investigation, your complaint is deemed justified, we will take appropriate steps to correct the situation, including, if necessary, amending our policies and practices. If you are not satisfied with the results of the investigation or the corrective measures taken by us, you may exercise the remedies available to you under law by contacting the Office of the Privacy Commissioner of Canada at the address below:

AddressOffice of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3