Part A — Overview
1. Introduction and Scope
This Privacy Policy describes how Solutions Purely Inc. collects, uses, discloses, and safeguards personal information when you visit our website, create an account, purchase our products or Plans, use our applications and water-report tools, or otherwise interact with us. It applies to all users of our Services, wherever located. If you do not agree with this Policy, please do not use the Services.
In this Policy, “personal information” (also referred to as “personal data”) means information that relates to an identifiable individual, as defined under applicable privacy law.
2. Our Privacy Officer
We have designated a Privacy Officer responsible for overseeing our compliance with applicable privacy law and for handling your requests and concerns. You may contact our Privacy Officer using the details in Section 21.
3. The Laws That Apply to You
We are based in Quebec, Canada, and we comply with applicable privacy law depending on where you are located:
- Quebec residents: the Act respecting the protection of personal information in the private sector (as modernized by Law 25).
- Other Canadian residents: the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and equivalent provincial legislation where applicable.
- Residents of the European Economic Area, United Kingdom, and Switzerland: the General Data Protection Regulation (GDPR) and UK GDPR, to the extent they apply to our processing of your personal data.
- Other jurisdictions: applicable local data protection laws.
Where the mandatory law of your jurisdiction grants you stronger protections than this Policy describes, those protections apply.
Part B — What We Collect and Why
4. Information We Collect
4.1 Information You Provide to Us
We collect personal information you voluntarily provide when you create an account, make a purchase, contact support, subscribe to communications, participate in a survey or promotion, or request water reports. This may include:
- Contact information — name, email, postal address, phone number;
- Account information — username, password, and registration details;
- Household and usage profile — information about your water consumption, household size, and drinking-water preferences, used to personalize your experience and improve our filter-life predictions;
- Payment information — processed by our third-party payment processor; we do not store full payment card numbers on our servers;
- Communications — feedback, questions, and correspondence you send us.
4.2 Information We Collect Automatically
When you use our Services, we automatically collect: log and usage data (such as IP address, browser type, operating system, pages visited, and access times); device data (such as hardware model, operating system, and unique device identifiers); and approximate location derived from your IP address.
4.3 Cookies and Similar Technologies
We use cookies, web beacons, and similar technologies to operate the Services, remember your preferences, analyze usage, and (where permitted) support marketing. Where required by law, we obtain your consent before placing non-essential cookies. You can control cookies through your browser settings and, where offered, our cookie preferences tool. Disabling some cookies may affect how the Services function.
5. How We Use Your Information
We use personal information to: provide, operate, and maintain the Services; process transactions and manage orders and Plans; personalize and improve the Services; communicate with you, including support and administrative messages; send marketing communications in accordance with your preferences and applicable law; monitor and analyze usage and trends; detect, prevent, and investigate fraud and misuse; and comply with our legal and regulatory obligations.
6. Our Legal Bases for Processing
Where required (including under the GDPR), we rely on the following legal bases to process your personal data:
- Providing the Services, processing orders and Plans: performance of a contract with you.
- Personalization, analytics, fraud prevention, securing the Services: our legitimate interests, balanced against your rights.
- Marketing communications and non-essential cookies: your consent (which you may withdraw).
- Meeting legal, tax, and regulatory obligations: compliance with a legal obligation.
Where we rely on consent, you may withdraw it at any time as described in Section 7.
7. Consent and How to Withdraw It
Where the law requires consent to collect, use, or disclose your personal information, we will obtain it, and we will identify the purposes for which information is collected at or before the time of collection. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawing consent may limit our ability to provide certain Services. Withdrawal does not affect processing already carried out.
8. Automated Processing and Profiling
Part C — Sharing, Storage and Security
9. How and When We Share Information
We share personal information only in these limited circumstances:
- Service providers: trusted vendors who process information on our behalf (such as payment processing, hosting, analytics, email delivery, and customer service), bound by confidentiality and data-protection obligations and permitted to use it only to provide services to us;
- Business transfers: in connection with a merger, financing, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality protections;
- Legal and protective: where required to comply with law, legal process, or governmental request, or to protect the rights, safety, and property of Purely Solutions, our users, or others;
- With your consent: for any other purpose disclosed to you and to which you consent.
10. International Data Transfers
We are based in Canada, and your personal information will be processed in Canada and may be processed by our service providers in other countries whose data protection laws may differ from those of your jurisdiction. Where we transfer personal data internationally, we take steps required by applicable law to protect it, which may include contractual safeguards such as standard contractual clauses. By using the Services or providing information to us, you understand that your information will be transferred to and processed in Canada.
11. Data Retention
We retain personal information only as long as necessary for the purposes set out in this Policy, including to provide the Services, maintain your account and Plan, comply with our legal, tax, and regulatory obligations, resolve disputes, and enforce our agreements. When information is no longer required, we will securely delete, destroy, or anonymize it in accordance with applicable law.
12. Data Security
We use administrative, technical, and physical safeguards designed to protect personal information appropriate to its sensitivity, including access controls, encryption in transit where appropriate, and vendor due diligence. No method of transmission or storage is completely secure, and while we work to protect your information, we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
13. Confidentiality Incidents (Breach Notification)
We maintain procedures to detect, assess, and respond to confidentiality incidents involving personal information. Where an incident presents a risk of serious injury or where applicable law otherwise requires, we will notify the relevant regulatory authority and affected individuals without undue delay, and we maintain a register of such incidents as required by law.
Part D — Your Rights
14. Your Privacy Rights
15. How to Exercise Your Rights
To exercise any of these rights, contact our Privacy Officer using the details in Section 21. We will respond within the timeframe required by applicable law. To protect your information, we may need to verify your identity before acting on a request. We will not discriminate against you for exercising your rights. If you are unsatisfied with our response, you may contact your privacy regulator, including, in Quebec, the Commission d’accès à l’information.
16. Marketing and SMS / Text Messaging
We send marketing communications only in accordance with your preferences and applicable law, including Canada’s Anti-Spam Legislation (CASL). You may unsubscribe at any time using the link in our emails or by contacting us.
If you provide your phone number and agree to receive texts, you consent to receive messages from Solutions Purely Inc. regarding account notifications, customer care, and delivery updates. Consent is not a condition of purchase. Message frequency varies, and message and data rates may apply. Reply STOP to unsubscribe or HELP for assistance. Mobile opt-in data and consent are never shared with third parties.
17. Children’s Privacy
Our Services are not directed to children, and we do not knowingly collect personal information from children under the age of majority in their jurisdiction (and, in any event, not under 13, or under 16 where applicable). If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.
Part E — General
18. Third-Party Links and Services
Our Services may link to or integrate with third-party websites and services that we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing personal information.
19. Limitation of Liability
20. Changes to This Policy
We may update this Policy from time to time. We will post the updated version and revise the “Last updated” date, and, where required by law, provide additional notice or obtain your consent. Your continued use of the Services after an update takes effect constitutes acknowledgement of the revised Policy, to the extent permitted by law.
21. How to Contact Us
SOLUTIONS PURELY INC. — PRIVACY OFFICER
Email: info@purelysolutions.ca
Mail: Attn: Privacy Officer, Solutions Purely Inc., Montreal, Quebec, Canada