Privacy Policy

1. Introduction

This Privacy Policy describes how TRALO Heating & Cooling, a trade name of 12232278
Canada Corp (“the Company,” “we,” “us,” or “our”), collects, uses, discloses, and protects your
personal information when you use our website (https://www.tralo.ca), request services, or
otherwise interact with us.

We are committed to protecting your privacy in accordance with the Personal Information
Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
By using our services, you consent to the practices described in this policy.

2. Definitions

• “Personal Information” means any information about an identifiable individual, as defined
  under PIPEDA. This includes but is not limited to your name, email address, phone
  number, mailing address, IP address, and payment information.
• “Service” refers to the TRALO website, our in-home consultation and installation
  services, quoting and scheduling platforms, and any related customer portals or tools.
• “Usage Data” refers to data collected automatically when you interact with our website,
  including IP address, browser type, pages visited, time spent, device identifiers, and
  other diagnostic data.
• “Service Provider” means a third-party company or individual that processes data on our
  behalf to support, analyze, or improve our services.

3. Information We Collect

3.1 Personal Information You Provide

When you request a quote, book a service, contact us, or create an account, we may collect:

• First and last name
• Email address
• Phone number
• Home or service address, city, province, and postal code
• Property details relevant to HVAC service (home size, equipment type, etc.)
• Payment and billing information (processed securely by our payment provider)

3.2 Usage Data

We automatically collect certain data when you visit our website, including your device’s IP
address, browser type and version, the pages you visit, time and date of your visit, time spent
on pages, unique device identifiers, and other diagnostic data. If you access the website from a
mobile device, we may also collect your mobile device type, unique device ID, mobile operating
system, and mobile browser type.

3.3 Information from Third Parties

We may receive information about you from advertising platforms, lead generation services, or
referral partners when you interact with our marketing content or are referred to us for service.

4. Tracking Technologies and Cookies

We use cookies and similar tracking technologies to monitor activity on our website, store
preferences, and improve our services. These include:

Essential Cookies

Session cookies required to operate the website, authenticate users, and prevent fraud. These
cannot be disabled without impairing core functionality.

Analytics Cookies

We use Google Analytics (GA4) to understand how visitors interact with our website, including
page views, session duration, and traffic sources. Google Analytics may collect your IP address
and device information. You can opt out using the Google Analytics Opt-Out Browser Add-on.

Advertising and Remarketing Cookies

We use Meta Pixel (Facebook/Instagram) and Google Ads remarketing tags to measure
advertising effectiveness and show you relevant ads on third-party platforms after you visit our
website. These tools may collect browsing behaviour, device identifiers, and interaction data.

Functionality Cookies

Persistent cookies that remember your preferences, such as language selection or login details,
to provide a personalized experience.

You can configure your browser to refuse all cookies or alert you when a cookie is being sent.
However, disabling cookies may limit your ability to use certain features of our website. For
more information, please see our Cookie Policy at https://www.tralo.ca/policy/cookies.

5. How We Use Your Personal Information

We use your personal information for the following purposes:

• To provide, deliver, and maintain our HVAC services, including scheduling, quoting,
  installation, and follow-up.
• To manage your account and provide access to customer-facing tools and portals.
• To process payments and fulfill contractual obligations.
• To contact you by email, phone, SMS, or push notification regarding service updates,
  appointment confirmations, and security notices.
• To send marketing communications about products, services, promotions, and rebates
  similar to those you have purchased or inquired about, provided you have not opted out.
• To analyze website usage patterns and improve our website, services, and customer
  experience.
• To measure the effectiveness of our advertising campaigns.
• To comply with legal obligations, resolve disputes, and enforce our agreements.

6. How We Share Your Personal Information

We may share your personal information in the following circumstances:

Service Providers

We engage trusted third-party providers to support our operations. These include:

• Google Analytics (GA4) for website analytics
• Meta (Facebook/Instagram) and Google Ads for advertising and remarketing
• Customer relationship management (CRM) platforms for managing service requests and
  customer communications
• Payment processors for secure transaction handling
• Scheduling and quoting platforms for service coordination

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These providers are contractually obligated to use your personal information only for the
purposes we specify and in compliance with applicable privacy laws.

Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal
information may be transferred. We will provide notice before your data becomes subject to a
different privacy policy.

Affiliates and Business Partners

We may share information with our affiliates, parent company, subsidiaries, or business
partners to offer you relevant products, services, or promotions. All affiliates are required to
honour this Privacy Policy.

Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid
requests by public authorities, including courts or government agencies. We may also disclose
information when we believe in good faith that disclosure is necessary to protect our rights or
property, prevent wrongdoing, protect personal safety, or defend against legal liability.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes
described in this policy, subject to the following general guidelines:

• Customer records (name, contact details, service history): retained for up to seven (7)
  years following your last interaction with us, consistent with tax and regulatory record-
  keeping requirements.
• Payment and transaction records: retained for seven (7) years in accordance with
  Canada Revenue Agency requirements.
• Website usage and analytics data: retained for up to twenty-six (26) months, unless
  required for security or legal purposes.
• Marketing and communication preferences: retained until you withdraw your consent or
  request deletion.

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When personal information is no longer required, we will securely delete or anonymize it.

8. Transfer of Your Personal Information

Your personal information is processed at our operating offices in Ottawa, Ontario and
Dartmouth, Nova Scotia, and may also be processed by our third-party service providers
located in other jurisdictions, including the United States.

When your data is transferred outside of Canada, we take reasonable steps to ensure it is
treated securely and in accordance with this Privacy Policy, and that adequate safeguards are in place to protect your information. Your consent to this policy constitutes your agreement to
such transfers.

9. Your Rights Under PIPEDA

As a Canadian resident, you have the following rights under the Personal Information Protection
and Electronic Documents Act (PIPEDA):

• Access: You have the right to request access to the personal information we hold about
  you and to be informed of how it has been used and to whom it has been disclosed.
• Correction: You have the right to request correction of any inaccurate or incomplete
  personal information.
• Withdrawal of Consent: You have the right to withdraw your consent for the collection,
  use, or disclosure of your personal information at any time, subject to legal or contractual
  restrictions. We will inform you of the implications of withdrawing consent.
• Complaint: If you are not satisfied with how we handle your personal information, you
  have the right to file a complaint with the Office of the Privacy Commissioner of Canada
  (OPC) at www.priv.gc.ca.

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To exercise any of these rights, please contact our Privacy Officer using the contact information
provided in Section 14 of this policy. We will respond to your request within thirty (30) days.

10. Data Breach Notification

In accordance with PIPEDA, if we become aware of a breach of security safeguards involving
your personal information that creates a real risk of significant harm, we will:

• Notify you as soon as feasible, describing the nature of the breach, the information
  involved, and the steps we are taking to reduce the risk of harm.
• Report the breach to the Office of the Privacy Commissioner of Canada.
• Notify any other organization or government institution that may be able to reduce the
  risk of harm.

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We maintain a record of all breaches of security safeguards, regardless of whether they meet
the threshold for notification, as required by law.

11. Security of Your Personal Information

We implement commercially reasonable administrative, technical, and physical safeguards to
protect your personal information against unauthorized access, loss, misuse, or alteration.

These measures include encrypted data transmission, secure storage systems, and access
controls.

However, no method of electronic transmission or storage is completely secure. While we strive
to protect your personal information, we cannot guarantee absolute security.

12. Children’s Privacy

Our services are not directed at individuals under the age of 18. We do not knowingly collect
personal information from minors. If you are a parent or guardian and believe your child has
provided us with personal information, please contact us immediately. If we become aware that
we have collected personal information from a minor without appropriate parental consent, we
will take steps to delete that information.

13. Links to Third-Party Websites

Our website may contain links to third-party websites that are not operated by us. We have no
control over and assume no responsibility for the content, privacy policies, or practices of any
third-party websites. We encourage you to review the privacy policy of every website you visit.

14. Privacy Officer and Contact Information

We have designated a Privacy Officer responsible for overseeing our compliance with this policy
and applicable privacy legislation.

Privacy Officer:

• Louis Lacombe-Denis
• CEO
• Email: contact@tralo.ca
• Phone: 1-800-843-1578
• Mail: TRALO Heating & Cooling, 105-6 Bexley Place, Nepean, ON K2H 8W2

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For general inquiries, you may also reach us at contact@tralo.ca.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices,
technology, legal requirements, or other factors. When we make material changes, we will notify
you by posting the updated policy on our website and updating the “Last Updated” date above.

Where required by law, we will notify you of significant changes by email or through a prominent
notice on our website before the changes take effect. We encourage you to review this policy
periodically.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Province of
Ontario and the federal laws of Canada applicable therein, including PIPEDA. By using our
services, you consent to the exclusive jurisdiction of the courts of Ontario for any disputes
arising under this policy.