Effective Date: July 30, 2025

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Published by: HarjTech Inc. (referred to as “HarjTech”, “we”, “us”, or “our”)

1. Purpose and Scope

This Privacy Policy outlines how HarjTech Inc. collects, uses, discloses, retains, and protects your personal information when you:

• Visit our website at www.harjtech.com
• Interact with us directly through forms, emails, or consultations
• Engage us to deliver professional services
• Participate in our marketing campaigns, webinars, or newsletters

This policy applies to all visitors, clients, partners, suppliers, and users who provide personal information to us within Canada or from abroad. We adhere to the Personal Information Protection and Electronic Documents Act (PIPEDA) and relevant provincial legislation such as:

• The Freedom of Information and Protection of Privacy Act (FIPPA) (Manitoba, Ontario)
• The Personal Information Protection Act (PIPA) (Alberta, British Columbia)

2. What Information We Collect

A. Personal Information

We may collect:

• Full name, company name, business address
• Email address and telephone number
• Job title, industry, project role
• Authentication details (for user login systems)
• Communications with our support or project teams

B. Client Data (Project-Specific or Uploaded Data)

• Files, credentials, code snippets, logs, or business data provided as part of consulting services
• Access logs, usage records from custom applications developed by us

Note: All client data is handled in accordance with signed NDAs or MSAs.

C. Website Usage Data (Collected Automatically)

• IP address, location (approximate)
• Browser type, device ID, operating system
• Pages visited, time spent, referral URLs
• Cookies (session-based, analytics, preferences)

3. Legal Basis for Collection and Use

Under Canadian law, personal information must be collected for a reasonable purpose and with your knowledge and consent, unless otherwise permitted.

We collect and process personal information based on:

• Explicit consent (e.g., form submission, newsletter signup)
• Implied consent (e.g., continued use of our website)
• Contractual necessity (to deliver services you requested)
• Legal obligations (e.g., tax compliance, security logs)
• Legitimate interest (e.g., analytics, fraud detection)

4. Use of Personal Information

We use the data we collect for the following purposes:

PurposeLegal BasisDeliver services and respond to inquiriesContractual necessityCommunicate project updates, proposals, or invoicesLegitimate interestSend marketing or technical updates (opt-in only)ConsentImprove our website and offerings through analyticsLegitimate interestComply with regulatory/legal requirementsLegal obligationProtect HarjTech from fraud, abuse, or legal riskLegitimate interest

We do not use your data for AI model training, data resale, or unsolicited marketing unless you explicitly opt in.

5. Disclosure of Information

We may disclose personal information only when necessary and under the following conditions:

• To vendors, contractors, or cloud providers who help us operate (e.g., email marketing platforms, CRM tools, hosting services) — under strict data protection agreements
• To accountants, legal advisors, or auditors under confidentiality
• To government agencies or legal authorities if required by law, warrant, or legal process
• During business transitions such as mergers, acquisitions, or asset sales — under NDA and post-notification

6. Cross-Border Transfers

If personal information is processed or stored by a third-party service provider outside Canada (e.g., U.S.-based cloud hosts), we ensure:

• Compliance with PIPEDA’s "comparable protection" requirement
• That data is only accessible for necessary service operations
• That appropriate contractual clauses are in place

7. Safeguards and Data Security

HarjTech employs administrative, physical, and technical controls to safeguard personal data:

• Encrypted communication (HTTPS, TLS 1.2+)
• Role-based access control (RBAC) for internal systems
• Secure development practices for all apps we deliver
• MFA (Multi-Factor Authentication) on all admin accounts
• Regular patching, updates, and audit logging

Client credentials or project access tokens, if ever received, are stored only temporarily and then securely destroyed.

8. Retention and Destruction

• We retain personal and project-related data only as long as necessary to fulfill the intended business purpose or legal obligation.
• After retention periods expire, data is securely deleted or anonymized.
• You may request deletion of your personal data at any time, subject to contractual or legal exceptions.

9. Your Rights

As a data subject in Canada, you have the right to:

• Access your personal information
• Request corrections to inaccurate or outdated data
• Withdraw consent at any time (for marketing, cookies, etc.)
• Request deletion of your information (if no legal reason to retain)
• File a complaint with the Office of the Privacy Commissioner of Canada (OPC)

You may exercise your rights by contacting us (see Section 11).

10. Use of Cookies and Tracking

Our site uses cookies and similar technologies for:

• Session management
• Traffic analytics (via Google Analytics or similar)
• Preference storage (language, UI)

You may control cookies via your browser settings. Disabling cookies may affect certain features or performance of the site.

11. Privacy Officer Contact

All inquiries or concerns can be directed to:

Privacy Officer
HarjTech Inc.
Email: contact@harjtech.com

12. Changes to This Policy

HarjTech reserves the right to amend this Privacy Policy as needed. Any material changes will be posted on our website, with the "Last Updated" date adjusted. We recommend reviewing this policy periodically to stay informed.

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