Privacy Policy

‍Effective date: November 1, 2025
Legal entity: Zero 21 Partners LP (“Zero 21 Partners”, “we”, “us”, or “our”)
Privacy Officer: Steve Choi — privacy@z21partners.com

‍

This Privacy Policy explains how we collect, use, disclose, safeguard, and provide access to your personal information when you interact with our website and services (collectively, the “Services”). It is designed to comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario laws. Where relevant, it also notes obligations under Canada’s Anti-Spam Legislation (CASL). If we handle personal health information, we will comply with Ontario’s Personal Health Information Protection Act (PHIPA) as described below.

1) Scope & Definitions

• Personal information means information about an identifiable individual (e.g., name, email address, IP address when linked to you).
• Business contact information (name, position, business address, business email/phone) used solely to contact you in a business capacity is generally excluded from PIPEDA’s definition but we protect it appropriately.
• Personal health information (PHI) means identifying information about your health or health services. We do not intentionally collect PHI. If a project requires PHI, the PHIPA rules in Section 11 apply.

This Policy covers personal information we handle as an “organization” under PIPEDA when you visit our website, communicate with us, or use our Services. It does not cover information about our employees or contractors, which is governed by internal policies.

‍

2) Our Privacy Principles (PIPEDA)

We follow the ten fair information principles: Accountability, Identifying Purposes, Consent, Limiting Collection, Limiting Use/Disclosure/Retention, Accuracy, Safeguards, Openness, Individual Access, and Challenging Compliance.

‍

3) What We Collect

We collect only what we need for identified purposes:

Information you provide

• Contact details (name, email, phone)
• Business details (company, role)
• Content of inquiries, meeting notes, or feedback
• Billing and transaction data (if you purchase paid services)

Information collected automatically

• Device and browser information, IP address, general location (city/region), pages viewed, referring/exit pages, and timestamps
• Cookies or similar technologies (see Section 7)

Information from third parties

• Lead sources or referral partners (business contact details)
• Public or shared professional profiles you choose to link or provide

We do not knowingly collect information from children under 13. If you believe a child under 13 has provided personal information, contact us and we will delete it.

‍

4) Purposes for Collection and Use

We use personal information to:

• Provide, operate, and improve the Services
• Respond to inquiries, schedule meetings, and manage relationships
• Send administrative messages and (with consent or as permitted by law) marketing communications
• Perform analytics to understand website performance and audience engagement
• Personalize content and experiences
• Process transactions and maintain billing records
• Detect and prevent fraud, abuse, or security incidents
• Meet legal, regulatory, audit, and compliance obligations
• Evaluate or complete a merger, acquisition, financing, or other business transaction (see Section 9)

5) Consent

We obtain express or implied consent depending on context and sensitivity. You can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw consent (including marketing consent), contact privacy@z21partners.com or use the unsubscribe link in our emails.

We may collect, use, or disclose personal information without consent where permitted or required by law (e.g., fraud investigation, debt collection, legal claims).

‍

6) Limiting Collection, Use, Disclosure, and Retention

• We limit collection to information necessary for identified purposes.
• We do not sell personal information.
• We retain personal information only as long as needed for those purposes and legal requirements, then securely delete or de-identify it.

7) Cookies, Analytics, and Interest-Based Ads

Our website uses cookies and similar technologies to operate the site, remember preferences, and conduct analytics. Analytics tools (for example, Google Analytics) may collect device identifiers, IP address (which may be truncated or masked), and usage data to help us understand traffic and improve the Services.

Managing cookies: Most browsers allow you to refuse or delete cookies. Doing so may affect site functionality.
Interest-based ads: If we use advertising networks, they may use cookies to tailor ads. You can opt out via your browser settings or platform tools (for example, Google Ads settings) and industry pages such as the DAA or NAI opt-out pages.

‍

8) Disclosures to Service Providers and Other Parties

We may share personal information with:

• Service providers/Processors who support our operations (hosting, analytics, CRM, payment processing, email delivery, security). They may access personal information only to perform services for us and must protect it.
• Business partners with your consent or as part of joint initiatives you choose to join.
• Authorities or other parties where required by law, to protect rights or safety, or in connection with legal claims.
• Business transactions: Personal information may be transferred as part of a merger, acquisition, financing, reorganization, or sale of assets. We will require recipients to protect the information and use it only for the transaction or the continuing business.

9) Cross-Border Transfers

Our service providers may be located outside Ontario and Canada (including the United States). Personal information processed in other jurisdictions may be subject to those jurisdictions’ laws and lawful access by courts, law enforcement, or authorities. We take contractual and technical measures appropriate to the sensitivity of the data to protect it when transferred.

‍

10) Safeguards

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including:

• Access controls and least-privilege principles
• Encryption in transit and at rest (where appropriate)
• Secure development and logging practices
• Vendor due diligence and contractual protections
• Employee and contractor confidentiality obligations

No method of transmission or storage is 100% secure. We maintain incident response procedures and will notify you and regulators of privacy breaches in accordance with applicable law.

11) Personal Health Information (PHIPA) — If Applicable

We do not intentionally collect personal health information (PHI). If a project requires PHI:

• We will identify roles (e.g., health information custodian or agent) and comply with PHIPA and any applicable professional or sector-specific rules.
• We will collect only what is necessary, obtain appropriate consent or rely on a permitted purpose under PHIPA, and apply heightened safeguards and retention controls.
• You may request access and correction to PHI as provided in Section 13.

For clarity: if we are not handling PHI in your interaction with us, this section does not apply.

‍

12) Accuracy

We take reasonable steps to keep personal information accurate, complete, and up to date for the purposes for which it is used. You can help by notifying us of changes.

‍

13) Your Rights: Access, Correction, and Portability

You have the right to:

• Access your personal information under our control and learn how it has been used and disclosed
• Request corrections to inaccuracies or omissions
• Receive explanations of decisions made about you where legally required (including any significant automated decision-making, if we ever use it for eligibility or similar decisions)

We will respond within the timelines required by law (generally 30 days). In limited cases, we may refuse requests where permitted by law and will provide reasons.

How to make a request: Email privacy@z21partners.com with “Privacy Request” in the subject line. We may need to verify your identity.

‍

14) Marketing Communications (CASL)

We send commercial electronic messages (e.g., newsletters) only with consent or as otherwise permitted by CASL. Every marketing email includes an unsubscribe mechanism that works within 10 business days. Transactional or service messages may still be sent as allowed by law.

‍

15) Third-Party Links and Social Media

Our Services may link to third-party sites or features. We are not responsible for the privacy practices of those third parties. Review their policies before providing information.

‍

16) De-Identification and Aggregation

We may de-identify or aggregate data for analytics, research, and business purposes. De-identified or aggregated information is not used to re-identify individuals, and we implement controls to prevent re-identification.

‍

17) Changes to This Policy

We may update this Policy to reflect changes to our practices or legal requirements. The “Effective date” shows when it was last updated. Material changes will be highlighted on our website or communicated directly when appropriate.

‍

18) Contact, Complaints, and Escalation

Privacy Officer
Steve Choi
Zero 21 Partners LP
Email: privacy@z21partners.com

We investigate all privacy inquiries and complaints. If you are not satisfied with our response, you may contact:

Office of the Privacy Commissioner of Canada (OPC)
30 Victoria Street, Gatineau, QC  K1A 1H3
Toll-free: 1-800-282-1376

For matters involving personal health information in Ontario, you may also contact:

Information and Privacy Commissioner of Ontario (IPC)
2 Bloor Street East, Suite 1400, Toronto, ON  M4W 1A8
Phone: 416-326-3333 | Toll-free (Ontario): 1-800-387-0073

‍

19) How to Reach Us

Questions, requests, or complaints about this Policy or our privacy practices can be sent to privacy@z21partners.com. Please include your name, contact information, and a description of your request.

‍