Evolve Thought Media Group, Inc. Privacy Policy

Effective Date: July 15, 2026
Last Updated: July 15, 2026

1. Our Commitment to Privacy

Evolve Thought Media Group, Inc. is committed to protecting the privacy and security of the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when individuals visit our Canadian websites, submit an online form, request information, communicate with us, use our services or otherwise interact with us.

This policy applies to the websites, landing pages, online forms and other digital services operated by Evolve Thought Media Group, Inc. that link to this Privacy Policy.

In this policy, “Evolve Thought Media Group, Inc.,” “we,” “us” and “our” refer to Evolve Thought Media Group, Inc.

2. Accountability

Evolve Thought Media Group, Inc. is responsible for the personal information under its control.

We maintain privacy policies, procedures and safeguards designed to protect personal information and address questions, requests and concerns relating to our handling of personal information.

Privacy-related questions or requests may be submitted using the information provided in the “Questions, Complaints and Contacting Us” section below.

3. What Is Personal Information?

Personal information is information about an identifiable individual. It may include information that identifies an individual directly or information that can reasonably be combined with other information to identify that individual.

Personal information does not generally include business contact information used solely to communicate with an individual in relation to their employment, profession or business responsibilities where applicable law excludes such information.

Information that has been aggregated or de-identified so that it can no longer reasonably be associated with an identifiable individual is not treated as personal information where permitted by law.

4. Personal Information We Collect

The information we collect depends on how an individual interacts with us.

Information Provided Directly to Us

We may collect information such as:

• Name
• Business or organization name
• Job title
• Mailing or business address
• Email address
• Telephone number
• General geographic location
• Information submitted through contact, consultation, quote or project request forms
• Project requirements, budget information and requested services
• Information contained in emails, telephone calls or other correspondence
• Appointment and meeting information
• Feedback, survey responses and testimonials
• Marketing and communication preferences
• Employment or contractor application information where applicable
• Billing, invoicing or transaction information where applicable
• Any other information an individual voluntarily provides to us

Individuals should not submit sensitive personal information through general website forms unless the information is reasonably necessary and specifically requested.

Information Collected Automatically

When someone visits or uses our website, we and our technology providers may automatically collect certain technical and usage information, including:

• Internet Protocol address
• Browser type and version
• Device type
• Operating system
• Approximate geographic location based on an Internet Protocol address
• Internet service provider or network information
• Referring and exit pages
• Pages viewed
• Links selected
• Date and time of a visit
• Time spent on pages
• Website navigation and interaction information
• Form interaction and conversion information
• Cookie identifiers and similar online identifiers
• Advertising campaign and referral information

This information may be collected through server logs, cookies, pixels, tags, software development kits, local storage and similar technologies.

Payment Information

Where online payment options are available, payment information may be collected and processed by a third-party payment processor.

We do not generally receive or retain complete payment-card numbers. Payment providers process payment information according to their own privacy policies, security standards and terms.

5. How We Collect Personal Information

We may collect personal information:

• Directly from an individual
• Through forms, emails, telephone calls and consultations
• Through website and advertising technologies
• From service providers acting on our behalf
• From publicly available business sources
• Through professional networking and business development activities
• From referral partners or other individuals where they are authorized to provide the information
• From social media platforms when an individual interacts with our pages or advertisements
• Through contracts, transactions and the delivery of services

Where required, we will obtain consent before collecting personal information from another source.

6. How We Use Personal Information

We may use personal information to:

• Respond to inquiries, consultation requests and quote requests
• Contact prospective, current or former clients
• Evaluate project requirements and business opportunities
• Prepare proposals, estimates and service recommendations
• Provide, manage and improve our services
• Process transactions, invoices and payments
• Schedule meetings and communicate about projects
• Provide customer service and technical support
• Manage client, supplier, contractor and business relationships
• Maintain business and transaction records
• Personalize website content and communications
• Understand how visitors use our website
• Diagnose technical issues and improve website performance
• Measure advertising and marketing campaign performance
• Conduct analytics, reporting and business planning
• Protect our websites, systems, clients and organization from fraud, misuse and security threats
• Establish, exercise or defend legal rights
• Meet contractual, accounting, tax, insurance and legal requirements
• Send marketing communications where permitted
• Process employment or contractor applications
• Fulfil other purposes disclosed at the time information is collected
• Carry out other activities with an individual’s consent or as permitted by law

We will not use personal information for a materially different purpose without obtaining additional consent where required.

7. Consent and Privacy Choices

We obtain consent for the collection, use and disclosure of personal information where required by applicable law.

The form of consent may vary depending on the nature of the information, the sensitivity of the information, the reason it is being collected and the reasonable expectations of the individual.

Consent may be express or implied where permitted. Express consent may be obtained verbally, electronically or in writing. Implied consent may arise through an individual’s actions or an existing business relationship where reasonable and legally permitted.

Individuals may withdraw consent at any time, subject to legal, contractual or reasonable notice requirements. Withdrawing consent will not affect processing that occurred lawfully before the withdrawal.

In some circumstances, withdrawing consent may prevent us from providing a requested service or continuing a business relationship. We will explain relevant consequences when a withdrawal request is made.

Certain information may be collected, used, retained or disclosed without consent where permitted or required by law.

8. Cookies and Similar Technologies

Our website may use cookies, pixels, tags, local storage and similar technologies to provide website functionality, remember visitor preferences, understand website usage, measure marketing activities and improve our services.

A cookie is a small data file placed on a browser or device when someone visits a website. Some cookies expire when the browser is closed, while others remain on the device for a defined period.

Essential Cookies

Essential cookies support functions necessary for the website to operate, including:

• Website navigation
• Security
• Network management
• Form functionality
• Fraud prevention
• Cookie preference management

Because these cookies are necessary for the website to function, they may not be capable of being disabled through our cookie preference tool.

Functional Cookies

Functional cookies allow the website to remember selections or preferences and may provide enhanced or personalized features.

Disabling these cookies may affect certain website functions.

Analytics Cookies

Analytics cookies help us understand how visitors interact with the website. They may collect information about pages viewed, navigation patterns, traffic sources, devices, browsers and website performance.

We use this information to improve website content, usability, performance and marketing decisions.

Advertising and Marketing Cookies

Advertising and marketing technologies may be used to:

• Measure advertising campaign performance
• Understand whether advertisements result in website visits or inquiries
• Limit how frequently an advertisement is displayed
• Build or use advertising audiences
• Provide advertisements that may be more relevant to an individual’s interests
• Measure interactions across websites, platforms or devices

These technologies may be placed or accessed by third-party advertising and social media providers.

Managing Cookie Preferences

Where required, visitors will be given an opportunity to accept, reject or manage non-essential cookies through the cookie consent tool displayed on the website.

Visitors may also use their browser settings to block or delete cookies. Browser controls vary, and disabling certain cookies may affect website functionality.

Changing cookie settings does not necessarily delete cookies already stored on a device. Visitors may need to delete existing cookies through their browser settings.

Third-party providers may offer their own privacy controls and opt-out mechanisms. Their handling of information is governed by their respective privacy policies.

9. Analytics, Advertising and Third-Party Technologies

We may use third-party technologies to support website hosting, analytics, advertising, customer relationship management, communications, security and other business functions.

Depending on which services are active on the website, these providers may collect or receive:

• Internet Protocol addresses
• Browser and device information
• Cookie or advertising identifiers
• Website interaction information
• Referral information
• Form or conversion events
• Approximate geographic information

These providers may process information according to our instructions and their own applicable privacy terms.

The specific providers and technologies used by the website may change as our business and technology requirements change. Additional information about currently active cookies may be available through the website’s cookie preference tool.

10. When We Disclose Personal Information

We do not disclose personal information to third parties except as described in this policy, with consent or as permitted or required by law.

Service Providers

We may disclose information to service providers that perform services on our behalf, including providers of:

• Website hosting
• Cloud storage
• Email and communication systems
• Customer relationship management systems
• Website analytics
• Advertising and campaign management
• Payment processing
• Accounting and invoicing
• Information technology support
• Cybersecurity and fraud prevention
• Form processing and appointment scheduling
• Professional, legal, insurance and financial services

Service providers are given only the information reasonably necessary to perform their assigned services. We expect service providers to protect personal information and use it only for authorized purposes, subject to applicable contractual and legal requirements.

Business Partners and Subcontractors

Where necessary to provide a requested service, we may disclose appropriate information to authorized business partners, consultants, suppliers or subcontractors.

We will limit these disclosures to information reasonably required for the applicable service or project.

Legal and Regulatory Purposes

We may disclose personal information where we reasonably believe disclosure is necessary to:

• Comply with applicable laws, regulations, court orders or legal processes
• Respond to lawful requests from government or regulatory authorities
• Investigate fraud, security incidents or unlawful conduct
• Protect our rights, property, systems, personnel or clients
• Protect the safety of an individual or the public
• Establish, exercise or defend legal claims
• Collect an outstanding debt
• Enforce a contract or website term

Business Transactions

Personal information may be disclosed as part of a proposed or completed financing, merger, acquisition, reorganization, sale of assets or other business transaction.

Where required, the recipient will be expected to use and protect the information in a manner consistent with applicable law and the purposes for which the information was originally collected.

Aggregated or De-Identified Information

We may use and disclose aggregated, statistical or de-identified information for research, reporting, analytics, advertising and business planning, provided that the information does not reasonably identify an individual.

We do not sell or rent directly identifying personal information to third parties for monetary consideration.

11. Processing and Storage Outside Canada

Some of our service providers may store or process personal information outside the province in which an individual resides or outside Canada, including in the United States or other countries.

When information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies, national-security authorities or regulatory bodies in accordance with local law.

We take reasonable steps to select reputable service providers and require appropriate protections for personal information. However, foreign laws may differ from Canadian privacy laws.

Individuals may contact us for additional information about our use of service providers outside Canada.

12. Marketing Communications

We may send promotional emails or other commercial electronic communications where an individual has provided consent or where another legal basis permits us to do so.

Marketing communications may contain information about:

• Services
• Articles and resources
• Offers and promotions
• Company updates
• Events
• Related business opportunities

Commercial electronic messages will include a method for unsubscribing where required.

An individual may unsubscribe by selecting the unsubscribe link in an applicable communication or by contacting us directly. Unsubscribe requests will be processed within the period required by law.

Unsubscribing from marketing communications will not prevent us from sending necessary transactional, project-related, security, billing or service communications.

13. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to:

• Fulfil the purposes for which it was collected
• Provide requested services
• Maintain appropriate business records
• Manage an ongoing or potential business relationship
• Meet contractual, legal, tax, accounting and insurance requirements
• Resolve disputes
• Enforce agreements
• Protect against fraud, security threats and legal claims

Retention periods may vary depending on the nature and sensitivity of the information, the purpose for which it was collected and applicable legal requirements.

When personal information is no longer reasonably required, we will securely delete, destroy or anonymize it, subject to legal requirements and reasonable limitations relating to backup systems.

14. Safeguarding Personal Information

We use reasonable administrative, technical and physical safeguards designed to protect personal information against:

• Loss
• Theft
• Unauthorized access
• Unauthorized use
• Unauthorized copying
• Unauthorized modification
• Unauthorized disclosure
• Accidental destruction

Safeguards may include access controls, authentication measures, encryption where appropriate, secure hosting, monitoring, backups, employee or contractor confidentiality obligations, security procedures and limited access based on business responsibilities.

The safeguards used will depend on the sensitivity, amount, format, location and intended use of the information.

No method of electronic transmission or storage is completely secure. Although we take reasonable measures to protect information, we cannot guarantee absolute security.

Individuals should avoid sending highly sensitive information through ordinary email or general website forms.

15. Privacy and Security Incidents

If we become aware of a privacy or security incident involving personal information, we will take reasonable steps to:

• Contain and investigate the incident
• Reduce the risk of harm
• Recover affected information where possible
• Correct relevant security or procedural weaknesses
• Evaluate the nature and seriousness of the incident
• Maintain required records
• Notify affected individuals, privacy regulators or other parties where required by law

The timing and content of any notification will depend on the circumstances and applicable legal requirements.

16. Accessing and Correcting Personal Information

Subject to applicable legal exceptions, an individual may request:

• Confirmation of whether we hold personal information about them
• Access to their personal information
• Information about how their personal information has been used or disclosed
• Correction of inaccurate or incomplete personal information
• Withdrawal of consent
• Information about applicable retention practices
• A copy of eligible computerized personal information in a structured and commonly used technological format where required by law
• De-indexing or cessation of dissemination in circumstances provided by applicable law

Requests should be submitted in writing using the contact information below.

We may ask for information reasonably necessary to verify the identity and authority of the person making the request. Information submitted for identity verification will be used only for that purpose.

We will respond within the period required by applicable law. In certain circumstances, we may extend the response period where legally permitted.

Access may be limited or denied where permitted or required by law, including where disclosure would reveal:

• Personal information about another individual
• Confidential commercial information
• Information protected by legal privilege
• Information generated during a formal dispute-resolution process
• Information that could threaten the safety or security of an individual
• Information that cannot be disclosed by law

Where appropriate, we will explain the reason for refusing or limiting a request and identify available complaint options.

17. Privacy Rights and Requests from Quebec Residents

Where Quebec privacy law applies, individuals may have additional rights relating to their personal information, including rights concerning:

• Access and correction
• Withdrawal of consent
• Data portability for eligible computerized personal information
• Information about automated decision-making where applicable
• Cessation of dissemination or de-indexing in qualifying circumstances
• Complaints to the Commission d’accès à l’information du Québec

Requests may be submitted using the contact information below.

18. Children’s Privacy

Our website and services are intended for businesses and adults and are not directed toward children under 14 years of age.

We do not knowingly collect personal information directly from children under 14 without consent from a parent, guardian or other authorized person where such consent is required.

If we learn that personal information has been collected from a child in circumstances where appropriate consent was required but not obtained, we will take reasonable steps to delete or otherwise address the information.

A parent or guardian who believes that a child has provided personal information to us may contact us.

19. Third-Party Websites and Services

Our website may contain links to websites, platforms, applications or services operated by third parties.

We do not control and are not responsible for the privacy, security, content or information-handling practices of third parties. This Privacy Policy does not apply to third-party websites or services.

Visitors should review the privacy policies and terms of third-party services before providing personal information or using those services.

20. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes to:

• Our business practices
• Our services
• Our website technologies
• Our service providers
• Legal or regulatory requirements
• Industry practices

The updated policy will be posted on our website with a revised “Last Updated” date.

Where a change is material, we may provide additional notice through the website, email or another appropriate method. Where required, we will obtain consent before applying a material change to personal information previously collected.

Continued use of the website after an updated policy is posted does not replace consent where express consent is legally required.

21. Questions, Complaints and Contacting Us

Questions, privacy requests, complaints or concerns may be directed to:

Evolve Thought Media Group, Inc.

Email: Info@ThoughtMedia.ca
Telephone: +1 (416) 628-9411
Telephone hours: Monday to Friday, 10:00 a.m. to 5:00 p.m. Eastern Time

Please include sufficient information to allow us to understand and respond to the request. Do not send highly sensitive personal information through ordinary email.

We will review privacy complaints and make reasonable efforts to investigate and resolve valid concerns.

If an individual is dissatisfied with our response, they may have the right to contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.