Privacy Policy

Effective Date: January 2024 Jurisdiction: Quebec, Canada

Disclaimer: This Privacy Policy is a standardized template designed for Brindle Home, focusing on subscription management services in Montreal. This document does not constitute legal advice. We recommend consulting with a qualified legal professional to ensure full compliance with the most recent amendments to Quebec’s Bill 64 (Law 25).

1. Introduction and Data Controller

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Welcome to Brindle Home. We are committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, and disclose personal data when you use our platform to manage, audit, and cancel recurring digital costs.

For the purposes of the Act respecting the protection of personal information in the private sector (Quebec) and the Personal Information Protection and Electronic Documents Act (PIPEDA), the data controller is Brindle Home.

Our designated Privacy Officer is responsible for overseeing questions in relation to this privacy policy. You may contact us at:

  • Email:
  • Address: 1250 René-Lévesque Blvd W, Montreal

2. Personal Information We Collect

We collect information that identifies, relates to, or could reasonably be linked, directly or indirectly, with a particular consumer or device. This includes:

  • Identity Data: First name, last name, and username.
  • Contact Data: Email address, telephone number, and billing address.
  • Financial Data: While we do not store full credit card numbers, we collect transaction history related to your subscriptions to provide our optimization services.
  • Technical Data: IP address, login data, browser type and version, time zone setting, and location data (specifically Montreal-based regional data).
  • Usage Data: Information about how you use our website and services to track hidden monthly expenditures.

3. Legal Basis for Processing

Under Quebec's Bill 64 (Law 25), we must establish a clear legal basis for processing your data. Brindle Home processes your information under the following grounds:

  1. Consent: Where you have given us clear consent to process your personal data for a specific purpose (e.g., newsletter subscription).
  2. Performance of a Contract: Where processing is necessary for the execution of our "Subscription Management Guide" or other service agreements.
  3. Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, such as preventing fraud or improving our digital inventory tools.
  4. Legal Obligation: Where we need to comply with a legal or regulatory obligation in Canada or Quebec.

4. Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience when you browse our "Montreal Market Analysis" and allows us to improve our site.

We use the following types of cookies:

  • Essential Cookies: Required for the operation of the site.
  • Analytical/Performance Cookies: Allow us to recognize and count the number of visitors.
  • Functionality Cookies: Used to recognize you when you return to our website.

5. Data Retention and Security

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve those purposes through other means.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those employees, agents, and contractors who have a business need to know.

6. Your Rights Under Quebec Law

As a resident of Quebec, you have specific rights regarding your personal information under Law 25:

  • Right to Access: You can request a copy of the personal data we hold about you.
  • Right to Rectification: You can request that we correct inaccurate or incomplete data.
  • Right to Deletion (Right to be Forgotten): You can request that we erase your personal data under certain conditions.
  • Right to Data Portability: You have the right to receive your data in a structured, commonly used, and machine-readable format.
  • Right to Withdraw Consent: If we rely on your consent to process data, you can withdraw it at any time.
  • Right to De-indexation: You can request that we stop disseminating your personal information or de-index any hyperlink providing access to it if the dissemination contravenes the law or a court order.

To exercise any of these rights, please contact our Privacy Officer via the phone number +1 (681) 816-1700.

7. International Data Transfers

While Brindle Home is based in Montreal, we may use service providers located outside of Quebec or Canada (e.g., cloud hosting in the USA). Whenever we transfer your personal data out of Quebec, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Transferring data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Using specific contracts approved for use which give personal data the same protection it has in Canada.

Questions or Complaints?

If you have any questions about this Privacy Policy or our privacy practices, please contact us. You also have the right to make a complaint at any time to the Commission d'accès à l'information du Québec (CAI).

+1 (681) 816-1700