1. About this policy
This Privacy Policy explains how Surger PRO ("we", "us", "our") collects, uses, discloses and protects personal information when you visit surger-pro.ca (the "Site") or submit a registration request through it. We handle personal information in line with the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, provincial privacy laws such as Quebec's Law 25.
2. Information we collect
Information you provide: first name, last name, email address, phone number and the country linked to your phone number.
Information collected automatically:
- IP address and approximate (country-level) location;
- browser, device, operating system and language settings;
- pages viewed, referring page, date and time of your visit;
- campaign and referral parameters in the link you used (for example click IDs or sub-IDs).
Some of this is collected through cookies — see our Cookie Policy.
3. How we use your information
- to process your registration request and contact you by phone or email;
- to pass your request to partner investment service providers who can offer you access to their services;
- to pre-select your country in the phone field and show relevant content;
- to measure the performance of the Site and our campaigns;
- to prevent fraud, abuse and duplicate submissions;
- to meet legal obligations.
4. Legal grounds
We collect, use and disclose your personal information with your consent, given when you submit the registration form, or where otherwise permitted or required by law — for example to prevent fraud or to meet legal obligations. Commercial electronic messages are sent in line with Canada's Anti-Spam Legislation (CASL), and you can unsubscribe at any time.
5. Sharing your information
We do not sell your personal information. We may share it with:
- Partner service providers — financial and investment companies that receive your request so they can contact you, under their own privacy policies;
- Technical providers — hosting, lead-management, IP-geolocation and analytics services acting on our instructions;
- Advertising partners — such as Meta, when measurement pixels are active;
- Authorities — where required by law.
6. International transfers
Some recipients may be located outside Canada, and your information may be processed in other jurisdictions and be accessible to their authorities. We use contractual and other measures to protect it to a comparable standard.
7. Data retention
We keep registration data only as long as necessary for the purposes above — normally no more than 24 months after your last interaction — unless the law requires longer.
8. Security
The Site uses encrypted (HTTPS) connections and access to personal data is restricted. No online system is completely secure, but we work to protect your information from loss, misuse and unauthorized access.
9. Your rights
You may request access to and correction of the personal information we hold about you, and withdraw your consent at any time, subject to legal or contractual restrictions. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner.
10. Age restriction
The Site is for adults only. We do not knowingly collect information from anyone under the age of majority in their province or territory.
11. Changes
We may update this policy. The date at the top shows the latest version.
12. Contact
For privacy questions or requests, email [email protected].