This Privacy Policy describes the terms of our commitment to your privacy.

3D STORAGE SYSTEMS LIMITED is committed to excellence in serving all of our customers including those with disabilities while accessing our goods and services.

Scope & Commitment

This Privacy Policy explains how 3D Storage Systems Limited (“we”, “us”, or “our”), our affiliates, and our authorized distributors and logistics partners collect, use, disclose, and protect personal information. We handle personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial private‑sector laws where applicable. This Policy applies to individuals whose personal information we process in the context of our manufacturer–distributor operations, websites and portals, training and incentive programs, warranty and product support, and other commercial activities.

Key Definitions

•  “Personal information” means information about an identifiable individual.
• “Business contact information” (e.g., name, title, business email/phone) may be treated differently under some provincial laws; however, PIPEDA still applies to our commercial activities and cross‑border transfers.
• “Visitors” are individuals who access our websites or portals; “Subscribers” are individuals who sign up for communications; “Customers” include purchasers and recipients; “Distributor Personnel” are individuals engaged by our channel partners.

1) Accountability & Our Privacy Officer

We are responsible for personal information under our control, including information transferred to service providers (e.g., distributors acting as processors, cloud/SaaS providers, contact centers, payment processors, and logistics providers) for processing. We maintain a privacy management program with policies, training, vendor due diligence, and safeguards appropriate to sensitivity and risk.

Privacy Officer: Alicia Katsavos, VP Finance — alicia@3dstoragesystems.com, 270 Harry Walker Pkwy N, Newmarket ON, L3Y 7B4.

2) What We Collect

Depending on the relationship and interaction, we may collect:

• Distributor personnel information (e.g., names, business titles, business contact details, role, credentials, training/compliance records).
• Sales & channel data (e.g., account ownership, pipeline activity tied to identifiable reps, incentive/commission details).
• Order & fulfillment data (e.g., ship‑to contact, delivery instructions, proof of delivery which may include a person’s name/signature, returns/warranty case files).
• Support interactions (e.g., emails, call notes, portal chat logs, device logs that could identify an individual).
• Security & IT telemetry for portals/tools (e.g., login identifiers, IP addresses when linked to a person or device, MFA logs, audit trails).
• Website/portal usage data via cookies and similar technologies (e.g., pages viewed, preferences, session identifiers, approximate location from IP).
• Payment‑related information processed by our payment providers (we do not store full credit card numbers on our systems).

We limit collection to what is necessary for identified purposes (see Section 4).

3) How We Collect It

• Directly from individuals (e.g., account setup, orders, warranty claims, training).
• Automatically through authenticated portals and websites (e.g., access logs, security events, cookies/SDKs).
• From distributors and service providers acting on our behalf (e.g., 3PLs receiving delivery contact info).
• From communications you send to us (e.g., inquiries, testimonials) and from your interactions with our portals and support teams.

4) Purposes (Why We Use Personal Information)

• Establish and manage distributor/customer accounts; authenticate users; administer channel programs and incentives.
• Process and fulfill orders; coordinate shipments/returns; and provide warranty and technical support.
• Provide portals and services; ensure security (access control, fraud prevention, incident response) and maintain auditability.
• Manage training and compliance (e.g., safety certifications for handling products).
• Improve products and services (using aggregated or de‑identified analytics where feasible).
• Meet legal, regulatory, and contractual obligations (e.g., record‑keeping, taxation, sanctions screening, responding to lawful requests).

We do not collect, use, or disclose personal information for purposes a reasonable person would deem inappropriate (e.g., uses that cause significant harm or unlawful profiling).

5) Cookies & Online Tracking

We and our service providers use cookies and similar technologies to operate our sites and portals, keep you signed in, remember preferences, analyze usage, and improve performance. Where required, we obtain consent through banners or settings. You can manage cookies through your browser or our portal settings; disabling certain cookies may affect site functionality.

6) Consent

We seek meaningful consent for the collection, use, and disclosure of personal information, except where an exception applies. The form of consent (express or implied) depends on context and sensitivity. Individuals may withdraw consent, subject to legal/contractual limits and reasonable notice. We are transparent about what we collect, why, with whom it is shared, and key risks.

Cross‑border processing: We generally do not require separate consent to transfer personal information to service providers (including outside Canada) for processing, provided it is used only for the original purpose and comparable protection is ensured through contractual and organizational measures; we remain transparent about such transfers (see Section 8).

Business transactions: If we engage in mergers, acquisitions, or similar transactions, applicable laws allow certain uses/disclosures without consent under specific safeguards and notice requirements; we follow those statutory conditions

7) Limiting Collection, Use, Disclosure & Retention

We collect only what we need; use and disclose it solely for the identified purposes (unless consented or required by law); and retain it only as long as necessary for those purposes and to meet legal/operational requirements (e.g., audit, tax, warranty limitation periods), after which we securely delete or anonymize.

8) Cross‑Border Transfers & Service Providers

We may transfer personal information to service providers in other provinces or countries for processing. We remain accountable and require comparable protection via contracts, due diligence, and technical/organizational safeguards. Information processed in other jurisdictions may be accessible to foreign authorities under local laws.

9) Safeguards

• Organizational: access governance, least‑privilege, vendor management, staff training, confidentiality undertakings.
• Technical: encryption in transit/at rest (where appropriate), multi‑factor authentication, network segmentation, logging/monitoring, vulnerability management.
• Physical: secure facilities, restricted areas, and disposal controls.

Safeguards scale with sensitivity (e.g., payment data, government identifiers, or warranty files containing personal details). We ensure similar protections when information is processed by service providers.

10) Your Choices (Marketing, Cookies, Testimonials)

• Marketing communications: You can unsubscribe from marketing emails at any time by using the link in the message or by contacting us. We may still send service or transactional messages (e.g., account, order, or warranty notices).
• Cookies & analytics: Manage your preferences via your browser or our portal settings. Some features may rely on cookies to function.
• Testimonials & reviews: With your permission, we may publish testimonials you provide. You may withdraw permission by contacting us; removal will occur where practicable.

11) Accuracy, Access & Correction

We keep personal information as accurate, complete, and up to date as needed for its purposes. Individuals may request access to their personal information and challenge accuracy/completeness, subject to legal exceptions. We will respond within a reasonable time and provide explanations where access is restricted by law.

12) Breach Reporting, Notification & Record‑Keeping

If we experience a breach of security safeguards involving personal information under our control that creates a real risk of significant harm, we will report to the Office of the Privacy Commissioner of Canada (OPC), notify affected individuals and relevant third parties, and keep records of all breaches as required by law. We maintain internal breach response procedures and assess sensitivity and probability of misuse when determining risk.

13) Questions, Requests or Complaints (Challenging Compliance)

To raise a question, access request, or complaint, contact our Privacy Officer: Alicia Katsavos, VP Finance — alicia@3dstoragesystems.com, 270 Harry Walker Pkwy N, Newmarket ON, L3Y 7B4. We will investigate and respond. Individuals may also contact the Office of the Privacy Commissioner of Canada.

14) Special Notes for Manufacturer/Distributor Operations

• Order Fulfillment & Logistics: When a distributor submits delivery contact details (e.g., a warehouse receiver’s name/phone), the distributor confirms it has authority to share those details for fulfillment. We process the data strictly for shipping/returns and apply safeguards across carriers/third‑party logistics providers.
• Channel Enablement & Incentives: Personal information about identified sales representatives may be used to administer deal registration, MDF, training and certification, and incentive programs consistent with this Policy.
• Warranty & Product Safety: We may process personal information to validate claims, trace lots/serials, and conduct product safety notifications or recalls, consistent with legal obligations.
• Biometrics (if used for secure facility/portal access): We treat biometric identifiers as sensitive and apply heightened consent and safeguards; we do not permit covert surveillance or discriminatory profiling.

15) Changes to this Policy

We may update this Policy to reflect changes in practices or law. When changes are material, we will provide more prominent notice (e.g., via portal banner, email, or posting) and obtain fresh consent where required. The “Last updated” date at the top of this Policy indicates when it was last revised.

Appendix A — Summary of PIPEDA’s 10 Fair Information Principles (How This Policy Maps)

• Accountability (Sections 1, 8–9, 13)
• Identifying Purposes (Section 4)
• Consent (Section 6)
• Limiting Collection (Sections 2, 7)
• Limiting Use, Disclosure, Retention (Section 7)
• Accuracy (Section 11)
• Safeguards (Section 9)
• Openness (Sections 1, 11, 15)
• Individual Access (Section 11)
• Challenging Compliance (Section 13)