LERACH SKG BOCAZZILA INC.

Privacy Policy – Canada (Federal and Ontario)

Last updated: 19.11.2025

This Privacy Policy describes how SKG and LERACH SKG BOCAZZILA INC. (together, “SKG”, “we”, “us”, or “our”) collect, use, disclose, and protect personal information in the course of operating our business across Ontario and the rest of Canada.

By using our services, visiting our websites, or otherwise interacting with us, you acknowledge that you have read and understood this Privacy Policy.

1. Application of Canadian Privacy Law

1.1 PIPEDA and substantially similar laws
SKG and LERACH SKG BOCAZZILA INC. operate in Canada and handle personal information in accordance with:

  • The Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada’s federal private-sector privacy law); and

  • Any applicable, substantially similar provincial private-sector laws, where they apply to specific activities (for example, in Québec, British Columbia, or Alberta if SKG operations extend there).

1.2 Ontario-specific context
For private-sector activities in Ontario, personal information is governed primarily by PIPEDA. Ontario’s health-sector privacy law (PHIPA) is not generally applicable to SKG’s ordinary cleaning and facility services; if we ever engage in an activity where PHIPA or other sector-specific laws apply, we will comply with those specific requirements.

1.3 Scope – who this Policy covers
This Policy applies to personal information we collect in Canada about:

  • Clients and prospective clients (residential, commercial, hospitality, and specialty services);

  • Website visitors and users of our online booking or contact forms;

  • Vendors, subcontractors, and business partners; and

  • Job applicants and workers engaged by SKG or LERACH SKG BOCAZZILA INC. in Canada.

This Policy does not apply to the personal information of SKG employees where such information is already separately governed by internal HR policies and applicable employment/privacy legislation.

2. Definitions

For purposes of this Policy and in line with Canadian privacy law:

  • “Personal information” means information about an identifiable individual, such as a name, contact details, and information relating to services provided at a specific residence or workplace. Business contact information used solely to communicate with an individual in their business capacity may be treated differently under some privacy laws.

  • “Collection” means the act of gathering, acquiring, or obtaining personal information from any source.

  • “Use” means the processing, handling, and management of personal information within SKG.

  • “Disclosure” means making personal information available to another organization or individual outside of SKG.

3. Personal Information We Collect in Canada

3.1 Identity and contact details

  • Name

  • Residential and/or business address

  • Email address

  • Phone number(s)

  • Unit, buzzer, or access codes voluntarily provided to enable entry

3.2 Service-related information

  • Type of service requested (residential cleaning, office, boat, post-construction, basement, closet organization, specialty, etc.)

  • Property characteristics and notes (size, number of rooms, condition, special surfaces)

  • Preferred dates, time windows, and frequency (e.g., one-time, weekly)

  • Specific preferences or instructions (products to use/avoid, pets present, security notes)

3.3 Billing and payment information

  • Billing name and address

  • Invoice and transaction history

  • Limited payment card information as processed via third-party payment processors (SKG and LERACH SKG BOCAZZILA INC. do not keep full card details on our own servers; payment processing is handled by PCI-compliant providers).

3.4 Communications and records

  • Emails, messages sent through our websites or social platforms

  • Notes from telephone calls or in-person discussions, when recorded for service quality, follow-up, or risk management

  • Complaints, feedback, and satisfaction surveys

3.5 Technical / online usage data
When you visit our Canadian websites or online tools, we may collect:

  • IP address and approximate geolocation inferred from IP

  • Device, operating system, and browser type

  • Pages visited, time and duration of visits, referral URL

  • Cookie identifiers and similar technologies, subject to your browser settings (see Section 10)

3.6 Job applicants and contractors in Canada
If you apply to work with SKG or LERACH SKG BOCAZZILA INC. in Canada, we may collect:

  • Resume/CV and cover letters

  • Employment history and references

  • Training, certifications, and credentials

  • Information from background checks where permitted by law and with appropriate consent.

We collect personal information primarily from you directly, but may also receive it from:

  • Referring partners or platforms you used to find our services;

  • Payment processors; and

  • Publicly available sources, where appropriate and lawful.

4. Purposes for Collection, Use, and Disclosure

We collect, use, and disclose personal information in Canada only for purposes that a reasonable person would consider appropriate in the circumstances, including:

4.1 To provide and manage services

  • To schedule, confirm, and perform cleaning and related services at your location

  • To adapt service delivery based on your preferences and property needs

  • To confirm bookings, changes, and cancellations

  • To issue quotes, invoices, and receipts

4.2 To manage relationships and communications

  • To respond to questions, requests, and complaints

  • To provide ongoing customer support, including follow-up on completed services

  • To send service-related notifications and reminders

4.3 To operate and improve our business

  • To manage internal operations, logistics, and dispatch

  • To analyze service performance and improve quality

  • To conduct internal audits, accounting, and financial reporting for SKG and LERACH SKG BOCAZZILA INC.

4.4 Marketing and Canadian anti-spam compliance (CASL)

  • To send promotional communications (such as special offers or new services), in compliance with Canada’s Anti-Spam Legislation (CASL)

  • To manage your subscription preferences and opt-outs

We only send commercial electronic messages (e.g., promotional emails, certain texts) where we have your consent or another valid basis under CASL. You may unsubscribe at any time (see Section 9).

4.5 Legal, security, and risk management

  • To protect the health and safety of our workers and clients at Canadian service locations

  • To detect, prevent, or investigate fraud, non-payment, or misuse of services

  • To comply with legal and regulatory obligations (tax, accounting, law enforcement requests)

  • To establish, exercise, or defend legal claims involving SKG or LERACH SKG BOCAZZILA INC.

5. Consent Under Canadian Law

5.1 Obtaining consent
As required by PIPEDA and applicable provincial laws, SKG and LERACH SKG BOCAZZILA INC. obtain your consent for the collection, use, and disclosure of personal information, except where an exception is permitted or required by law (for example, in emergencies, to comply with court orders, or where the information is publicly available under regulation).

Consent may be:

  • Express (e.g., you sign a form or click an “I agree” checkbox); or

  • Implied (e.g., you provide personal information for an obvious purpose, such as giving your address so we can perform cleaning services there).

5.2 Withdrawing consent
You may withdraw your consent to certain uses and disclosures (for example, marketing communications) at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect SKG’s ability to provide some services.

To withdraw consent, contact us using the information in Section 12.

6. How We Share Personal Information in Canada

We do not sell your personal information. We disclose it only when necessary, appropriate, and lawful.

6.1 Within SKG / LERACH SKG BOCAZZILA INC.
Personal information may be shared between internal teams and affiliated entities to coordinate bookings, manage customer accounts, and deliver consistent services across locations in Canada.

6.2 Service providers (Canada and abroad)
We may transfer personal information to third-party service providers acting on our behalf, which may be located inside or outside Canada, including:

  • Payment processors

  • Cloud hosting and data storage providers

  • Email, SMS, and communication platforms

  • Scheduling, dispatch, and route optimization tools

  • Professional advisers (legal, accounting, audit)

We require these service providers to protect personal information with safeguards appropriate to its sensitivity and to use it only for the purposes we specify.

6.3 Law enforcement and legal disclosure
We may disclose personal information to law enforcement, regulators, courts, or other authorized parties when required or permitted by Canadian law, including to:

  • Comply with legal processes or regulatory requests;

  • Protect the rights, property, or safety of SKG, LERACH SKG BOCAZZILA INC., our staff, our clients, or others;

  • Detect and prevent fraud, security incidents, or other unlawful activities.

6.4 Business transactions in Canada
If SKG or LERACH SKG BOCAZZILA INC. enters into a merger, acquisition, financing, or sale of some or all of its assets, personal information may be transferred as part of the transaction, subject to applicable Canadian privacy law and continuity of protections.

7. Cross-Border Transfers

Some of our service providers may be located outside Canada, and personal information may be processed in other jurisdictions.

When personal information is transferred outside Canada:

  • It may be subject to the laws of the foreign jurisdiction;

  • It may be accessible to courts, law enforcement, and national security authorities in that jurisdiction;

  • SKG and LERACH SKG BOCAZZILA INC. will use contractual or other safeguards to require an appropriate level of protection consistent with Canadian privacy principles, where reasonably practicable.

You may contact us (Section 12) for more information about our use of service providers outside Canada.

8. Safeguards and Security Measures

We maintain physical, organizational, and technological safeguards reasonably designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These may include:

  • Restricted access to personal information on a “need-to-know” basis;

  • Password protection, secure networks, and other technical controls;

  • Encryption and secure transmission where appropriate;

  • Policies and training for staff and contractors handling personal information;

  • Contractual protections with service providers processing information on our behalf.

Despite these measures, no system is entirely risk-free. However, SKG and LERACH SKG BOCAZZILA INC. are committed to maintaining security measures that are reasonable in light of the sensitivity of the information and the risks involved.

9. Your Rights Under Canadian Law

Subject to limited exceptions under PIPEDA and applicable provincial laws, individuals in Canada have the following rights:

9.1 Access
You may request access to the personal information SKG and LERACH SKG BOCAZZILA INC. hold about you, including an explanation of how it has been used and to whom it has been disclosed, within a reasonable time and at minimal or no cost, as required by law.

9.2 Correction
If you believe your personal information is inaccurate or incomplete, you may request correction. We will correct or annotate the information as required by law.

9.3 Withdrawal of consent / marketing opt-out
You can withdraw your consent to certain uses and disclosures (particularly for marketing) and unsubscribe from commercial electronic messages in compliance with CASL, using the “unsubscribe” link in our emails or by contacting us directly.

9.4 Complaints
If you have concerns about how we handle your personal information, you may contact us first (Section 12). If you remain unsatisfied, you may have the right to complain to the Office of the Privacy Commissioner of Canada (OPC) or, where applicable, to a provincial privacy commissioner.

We may request sufficient information to confirm your identity before providing access or making corrections, to protect your privacy and the privacy of others.

10. Cookies and Online Tracking (Canada)

Our Canadian websites and online booking tools may use cookies and similar technologies to:

  • Remember your preferences (e.g., language, region)

  • Maintain session security

  • Analyze aggregated traffic patterns and site performance

Your browser may allow you to disable or delete cookies. Doing so may affect certain features of our websites or tools. Where required by law, we will provide additional notice or obtain consent for certain types of cookies.

11. Retention of Personal Information in Canada

We keep personal information only as long as necessary to fulfill the purposes identified in this Policy or as otherwise required by Canadian law, including:

  • To provide services and maintain business records;

  • To comply with legal, tax, and regulatory requirements;

  • To resolve disputes and enforce agreements.

When personal information is no longer required, we will securely delete, anonymize, or aggregate it, in accordance with our retention policies and applicable legal obligations.

12. Contact Information – SKG / LERACH SKG BOCAZZILA INC.

For any questions, requests, or concerns about this Privacy Policy or our Canadian privacy practices, please contact:

Privacy Officer – SKG / LERACH SKG BOCAZZILA INC.

info@lerach.ca

III. Changes to This-Specific Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or operations in Ontario and across Canada.

When we make material changes, we will:

  • Update the “Last updated” date; and

  • Provide additional notice where appropriate (e.g., website notice, email for significant changes).

Your continued use of SKG and LERACH SKG BOCAZZILA INC. services in Canada after changes take effect will constitute your acknowledgment of the revised Policy.

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