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Overview

We obtain certain personal information about individuals as described in this section.

Onward may collect and process personal information relating to different categories of individuals, including website visitors, customers and prospective customers, customer personnel, suppliers, agents, subcontractors, job applicants, and other individuals interacting with Onward.

When you use our website at www.onwardinnovate.com or other online services that we own or control (collectively, the “Sites”), you may provide personal information directly to us in the following ways:

On the contact form on the Sites, we request your name, email address and country, the type of service requested, information on how you found us, and the subject and content of your message.

When you subscribe to our newsletter, we request your name, company name, country, phone number, and type of subscription.

The information requested in the forms on our Sites varies. In most cases, an asterisk (*) indicates that the requested information is required. You may choose to provide additional information in fields that are not required.

For customers, suppliers, agents, and subcontractors, we obtain information about their personnel, such as name, title, email and postal address, company name, department, and phone number. In addition, to help us comply with and enforce anti-corruption requirements and other legal obligations, we ask Onward agents, suppliers and subcontractors to provide additional information, such as (1) information about the company’s executives, directors, and shareholders, including their dates of birth, nationality, percentage of ownership in the company, and copies of their identification documents; and (2) names of and contact information for the company’s commercial and financial references.

In addition, individuals may choose to submit information to us: (1) in response to marketing or other communications, (2) through social media, (3) by signing up for a product or service, (4) through participation in an offer, program or promotion, (5) in connection with an actual or potential business relationship with us, or (6) by giving us a business card or other information at a trade show or other event.

For the purposes of the CCPA and other applicable laws, depending on the nature of the relationship with Onward, the categories of personal information processed may include the following:

Onward uses sensitive personal information only as reasonably necessary to provide services, comply with law, conduct due diligence, maintain security, and manage employment relationships.

When you interact with our Sites, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products and services; (3) tailor the products and services around your preferences; (4) measure the usability of our products and services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies which are necessary for providing our products or services, you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

Information about our cookie practices and how to change your cookie settings is available in our Cookie Notice. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

Our Sites do not respond to browser ‘Do Not Track’ signals. However, where required by applicable law, Onward may recognize browser-based opt-out preference signals, including Global Privacy Control (GPC) signals.

Overview

We use the information we obtain about you to perform our contract with you, including to:

Provide our services to you;

Manage the contractual relationship we have with your organization;

Process billing inquiries in connection with our services; and

Provide customer support services.

We also use the information we obtain based on our legitimate interests, including to:

Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our products and services; conducting research and developing new services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing, reconciliation and collection activities and other internal functions);

Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);

Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;

Send you promotional materials, newsletters, surveys and other communications about our services; to the extent required by applicable law, we will obtain your consent to send you electronic marketing communications; and

Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, and our policies and terms.

When we process personal information for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights, and freedoms, about which we will provide more information upon request.

We may use the information we collect to comply with and enforce applicable legal requirements to which we are subject, and for the establishment, exercise or defense of legal claims, whether in court proceedings or in administrative or out-of-court procedures.

We also may use the information we collect about you in other ways for which we will provide specific notice at the time of collection and obtain your consent if required by applicable law.

We use third-party web analytics services on our Sites, such as Google Analytics. The service providers that administer these services use automated technologies to collect data (such as IP addresses) to evaluate use of the Sites. To learn more about these analytics services, please visit our Cookie Notice

To learn how to opt out of Google Analytics, click HERE .

We offer you certain choices in connection with the personal information we obtain about you. To exercise your choices, please contact us as specified in the How To Contact Us section of this Privacy Notice. You also may opt out of receiving promotional communications from us by following the unsubscribe instructions in the communications you receive. We do need to send you certain communications about our products and services, and you will not be able to opt out of those communications. This includes, for example, information about billing.

Where you have consented to the processing of your personal information, you have the right to withdraw your prior consent at any time. To exercise these rights, please contact us as indicated in the ‘How To Contact Us’ section below. Subject to applicable law, you also have the right to receive, in a structured, commonly used and machine-readable format, the personal information you have provided to us about you with your consent or based on a contract to which you are party. You have the right to have this information transmitted to another company, where it is technically feasible.

If you have a complaint regarding how Onward collects, uses, shares, retains or otherwise handles your personal information, you may contact us using the contact details provided in the “How to Contact Us” section below.

Onward will review and respond to complaints in accordance with applicable data protection laws and internal complaint-handling procedures.

Where required under applicable law, including the UK Data (Use and Access) Act 2025 (“DUAA”), Onward may acknowledge receipt of complaints within applicable statutory timeframes and take appropriate steps to investigate and respond to complaints without undue delay.

If you are a California resident, subject to certain exceptions and limitations under applicable law, you may have the right to: (1) exercise your right to know and request information regarding the categories and specific pieces of personal information we have collected about you, the categories of sources from which such information was collected, the purposes for collecting, using or disclosing such information and the categories of third parties to whom we disclose such information; (2) request that we delete personal information we have collected from you; (3) request that we correct inaccurate personal information we maintain about you; (4) opt out of the sale and sharing of your personal information, where applicable; (5) limit the use and disclosure of sensitive personal information, where applicable; and (6) not be discriminated against for exercising your privacy rights.

Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as specified in the ‘How To Contact Us’ section below.

Residents of other certain U.S. states may have rights regarding access, correction, deletion, portability, and opt-out rights relating to targeted advertising, profiling, and sales of personal data. Onward will honor such rights in accordance with applicable law.

You may exercise your rights by contacting us as described in the ‘How To Contact Us’ section of this Privacy Notice. We may take steps to verify your identity before responding to your request. You may also designate an authorized agent to submit a request on your behalf in accordance with applicable law.

If we deny a privacy rights request, you may appeal the decision using the contact information provided in ‘How To Contact Us’ section of this Notice. We will review and respond to appeals as required by applicable law.

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

We will keep your personal information for the time period necessary to achieve the purposes outlined in this Privacy Notice, taking into account applicable statute of limitation periods and records retention requirements under applicable law and the nature of the relationship with the individual, legal and regulatory obligations, operational requirements and dispute resolution or enforcement needs.

If you are a job candidate, we will keep your personal information for the time period necessary to complete the application process and the purposes described in this Privacy Notice. Subject to applicable law, we may ask you if you would like us to keep your personal information to contact you about future opportunities.

This Privacy Notice may be updated periodically to reflect changes in our privacy practices. We will post a notice on the Sites to notify you of significant changes to our Privacy Notice and indicate at the top of the Privacy Notice when it was most recently updated.

If you have any questions about this Privacy Notice, or if you would like us to update information we have about you or change your preferences, please contact us by email at info@onwardinnovate.com or write to us at:

510 Frederick Street Unit #4, Kitchener, ON, N0B 1E0