--- title: CX Group | Privacy Policy description: CX Group Canada Privacy Policy Annex. This Annex applies to individuals located in Canada who use or interact with CX Group, Inc. websites and apps. image: https://www.cxgroup.com/hubfs/website-2023/imagery/feature-images/new-feature-images/privacy-policy-feature-2.jpg --- - [Join Our Shopper Community](https://www.cxgroup.com/join-our-shopper-community) [![cx-group-logo](https://www.cxgroup.com/hubfs/website-2023/branding/logos/cx-group-logo.svg)](https://www.cxgroup.com?hsLang=en) - [About](https://www.cxgroup.com/about-us) - [Industries](https://www.cxgroup.com/industry-experience) Toggle navigation Toggle navigation - [About](https://www.cxgroup.com/about-us) - [Industries](https://www.cxgroup.com/industry-experience) - [Join Our Shopper Community](https://www.cxgroup.com/join-our-shopper-community) Search Box × Search Search # Canada Privacy Policy Annex ![black-fade](https://www.cxgroup.com/hubfs/website-2023/imagery/black-fade.svg) ![triangle](https://www.cxgroup.com/hubfs/website-2023/imagery/triangle.svg) This Annex was last updated on November 1, 2026. This Annex applies to individuals located in Canada who use or interact with CX Group, Inc. (“Company”) websites, applications, products, and services or who register, apply for, or perform services as a mystery shopper or other independent contractor for Company. This Annex provides you with details about the personal information we collect from you, how we use it, and the rights you have to control the personal information we maintain about you. “We,” “our,” “us” means Company; “you” means an individual in Canada who uses or interacts with our websites, applications, products, or services. This Annex supplements the U.S. Privacy Policy. If there is any conflict between the U.S. Policy and this Annex for individuals located in Canada, this Annex shall control only to the extent necessary to comply with Canadian law. ### 1. Introduction and Scope This Canada Privacy Annex (the “Annex”) supplements Company’s U.S. Privacy Policy to address requirements under Canada’s federal private‑sector privacy law (PIPEDA) and substantially similar provincial laws (Québec’s Act respecting the protection of personal information in the private sector (as modernized by Law 25), British Columbia PIPA, and Alberta PIPA. Where an activity falls within the scope of a substantially similar provincial law, that law governs; otherwise, PIPEDA applies. ### 2. What information do we collect in Canada? We collect only the personal information necessary for the identified purposes below, and we inform you at or before the time of collection in accordance with Canadian law. Through your use of our website, we request the following personal information: *Identifiers and Contact Details* - First name, last name, birthdate, postal address, email address, phone number and any other contact or other information that you choose to provide by using the “contact us” portion of the website. - Internet Protocol (“IP”) address, date and time of connection, pages visited, actions taken on a website. - Demographic information including product preferences and interests. - Usage information, through the use of cookies, such as the name of the web page from which you entered our website, time spent on each of our pages, number of clicks on each web page, and the methods by which you found our website (for more information about our use of cookies, please read our Cookie Policy). - Records of inquiries and support requests (email, phone, web forms, chat box). - Language and region preference (including French for Québec users). - Marketing preferences (opt‑in/opt‑out status; unsubscribe history). - Any information you provide to us directly. When you create an account or complete a transaction through our website, we will collect the following information: *Login and Account Information:* - First name, last name, postal address, email address, phone number. - Login credentials, including username and password. - Transaction type - Transaction amount, payment, and billing information as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate or transact business. When you attend an Event or request Marketing information, we collect the following: *Marketing & Event Interaction* - Newsletter sign‑ups (name, email, region). - Event/webinar registrations (name, email, company, role). - Campaign engagement (opens, clicks) and unsubscribe requests. *Mystery Shopper Information/Independent Contractor* If you register, apply for, or perform services as a mystery shopper or other independent contractor, we may collect: - your name, email address, telephone number, mailing address and other contact information; - account and login information; - information relating to your qualifications, experience, eligibility and availability to perform mystery shopping engagements; - information you provide in connection with your registration or contractor relationship, including information we may use to verify the accuracy of information you provide; - information concerning actual or potential conflicts of interest, including relevant relationships with our clients; - information relating to engagements offered to, accepted by or completed by you; - reports, surveys, photographs, receipts and other information or materials submitted in connection with an engagement; - payment, reimbursement, tax and related financial information necessary to compensate you for services or expenses; - records relating to your performance of engagements and compliance with applicable engagement requirements; and - communications and other information relating to your relationship with us. ### 3. Purpose of collection (Canada) We may ask you to provide personal information to allow you to use our website, applications, services, and products. We only use the personal information we collect for the purpose identified below and, where applicable, for the purposes stated at the time of collection. - ***To process transactions.*** We use contact information to engage in interactions with you, including contacting you about your transactions on the website. - ***To administer mystery shopping engagements.*** If you register, apply for, or perform services as a mystery shopper or other independent contractor, we may use your personal information to determine your eligibility and suitability for engagements; establish and administer our contractual relationship with you; identify and offer appropriate engagements; communicate with you regarding engagements; verify information you provide; identify and manage actual or potential conflicts of interest; administer and evaluate engagements and deliverables; process payments and expense reimbursements; maintain appropriate business, tax and accounting records; investigate suspected fraud, misconduct or violations of our agreements or policies; enforce our agreements; and comply with applicable legal and regulatory requirements. - ***To process payments.*** We use financial/credit card and payment information to process your order. We may need to share some of this information with delivery services, credit card clearing houses, and other third parties to complete the transaction - ***To provide support or other services***. We may also use personal information to respond directly to your requests for information, including registrations for newsletters, promotional materials, webinars, events, customer support-related issues, or other specific requests. - ***To provide information based on your needs and respond to your requests***. We use your personal information to provide you with notices of service developments. - ***To select content, improve quality, and facilitate use of our Services***. With your permission, we may use your personal information, including the information gathered through website cookies as a result of your navigation across our website (that may include third-party cookies), to help create and personalize the services that may interest you, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of our website or services (for example, to facilitate navigation and enhance security). - ***To engage with third parties.*** We share personal information with service providers who perform services on our behalf (for example, hosting databases, processing data, or mailing requested information). These service providers are contractually restricted from using personal information for any purpose other than providing services to us and are required to maintain appropriate security measures. From time to time, and only with your prior consent, we may share your personal information with third parties that offer content, products, or services that may interest you. In Québec, this consent will be requested separately and expressly. If any such third party is located outside Canada (or outside Québec for Québec residents), we will disclose this fact at or before collection and implement required safeguards, including transfer impact assessments and written agreements where applicable. - ***To serve personalized advertising to you***. We do not share your personal information with advertisers. With your consent, we may provide special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. - ***To assess usage of our products and services***. We track usage to understand engagement and improve functionality. Where tracking involves cookies or similar technologies, we obtain consent as required by law. In Québec, non-essential cookies and profiling technologies are off by default and require express opt-in. Usage statistics may be shared in aggregated form with licensors and, where applicable, your organization. - ***To communicate with you about events***. We use your information to provide details about events we host or sponsor, including logistics, tickets, and updates. With your consent, we may also send follow-up communications about related events. Event organizers and co-sponsors may request your information directly, provided it is optional and subject to their privacy policies. - ***To update you on relevant benefits, programs, and opportunities.*** We may send you information about benefits, programs, and opportunities available to you, subject to your consent and applicable anti-spam laws. In Québec, this purpose requires separate express consent. - ***To protect our content and services***. We use personal information to prevent fraud, spam, and other potentially illegal activities, and to maintain the security and integrity of our services. We employ technological measures to detect and address anomalous activity and to screen content to prevent abuse. These measures may, in rare cases, result in temporary or permanent suspension of certain functions. We may access, retain, and disclose personal information where required by applicable law or legal process, or where reasonably necessary to: (a) comply with legal obligations; (b) enforce this Privacy Policy or other agreements with you; (c) investigate potential violations; (d) respond to claims of rights infringement; (e) provide customer service; or (f) protect the rights, property, or safety of Company, its affiliates, users, or the public. Where we share information with other organizations for fraud protection or security purposes, we do so under contractual safeguards and, if such organizations are located outside Canada (or outside Québec for Québec residents), we comply with applicable cross-border transfer requirements, including Québec’s transfer impact assessments and Alberta’s notice obligations. - ***To get feedback or input from you***. We may invite you to participate in surveys, usability studies, or focus groups to help us improve our products and services. Participation is voluntary, and we will explain what information we collect and how it will be used at the time of collection. If feedback involves sensitive information or profiling, we will request separate express consent. Where third-party platforms are used, we ensure contractual safeguards and, if data is processed outside Canada (or outside Québec for Québec residents), we comply with applicable cross-border transfer requirements. - ***To protect our assets as well as your own personal information***. Our Information Security Program protects the confidentiality, integrity, and availability of our information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals. - ***Cross‑Border Processing.*** To enable secure processing by service providers outside Canada (and outside Québec, subject to transfer impact assessments and written agreements). - ***Sensitive Information***. For specific services requiring biometric or health data, collected only with express consent and disclosed separately. - **To operate and secure our website.** When you browse our website, we collect technical information such as your IP address, time of request, requested URL, and other HTTP header details. We use this information to ensure the website functions correctly, maintain security, and improve performance. We may collect certain demographic information (such as age range, region, or industry) to analyze trends and improve our products and services. If demographic information includes sensitive data, we will request separate express consent. We do not use demographic information for marketing unless we have your consent. You may withdraw consent at any time by emailing [helpdesk@cxgroup.com](mailto:helpdesk@cxgroup.com). ### 4. Disclosure of personal information *Service providers acting on our behalf* We share personal information with service providers and affiliated entities that perform services on our behalf (e.g., hosting, data processing, customer support, payment processing, mailing requested information, conference/event operations). We require these recipients to: (i) use personal information only to provide the contracted services to us; (ii) implement appropriate security measures, and (iii) delete or return the information at the end of the engagement. *Transfers outside your province, Canada, or (for Québec residents) outside Québec* Some service providers may be located outside your province or outside Canada (and, for Québec residents, outside Québec) to other countries or jurisdictions around the world that have different privacy laws that may or may not be as comprehensive as the country you reside in. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. We disclose the countries/regions where personal information is or may be processed and the purposes for such processing in our Sub‑processors & Locations page. We provide this information at or before collection and update it if locations change. All personal information is stored within the United States of America. *Alberta residents:* In accordance with Alberta PIPA, you may obtain written information about our policies and practices with respect to service providers outside Canada and contact our Privacy Officer with any questions using the details below. *Québec residents:* Before communicating personal information outside Québec, we conduct a transfer impact assessment and enter into a written agreement with the recipient containing appropriate safeguards. We also notify you at collection of the possibility that your information may be communicated outside Québec. We share your personal information with the following categories of third parties: | **Who?** | **Why?** | | --- | --- | | **Cloud service providers** | To host data across the world for us. In some cases, we may need to disclose or transfer your personal information to other affiliated entities or to third parties in areas outside of your province of residence | | **Payment services providers** | To process payment information and complete transactions made on our Site. | | **Mailing service providers** | To send you relevant communications. | | **Analytics and Marketing service providers** | To help us provide you with content, products, or services of interest to you. | | **Business partners** | To allow for conference or event management. The treatment of your information will be further subject to the privacy policies of those parties. | | **Customer Support providers** | To communicate with you, including to respond to your inquiries or complaints, to help you place an order; to identify and repair issues on our websites or accounts, and other related customer support inquiries. | | **Mystery Shopping Clients** | Where reasonably necessary to administer or complete a mystery shopping engagement, we may disclose personal information relating to a Mystery Shopper to the applicable client. We limit such disclosures to information reasonably necessary for the engagement, administration of the client relationship, investigation or resolution of issues relating to an engagement, or another purpose identified to you at or before collection, unless a broader disclosure is permitted or required by law. |   Except for the recipients acting on our behalf and as otherwise explained in this Policy, we do not disclose personal information to unrelated third parties without your consent unless permitted or required by law. We may disclose personal information where necessary to comply with lawful process or legal obligations, to enforce our agreements, to address fraud or security threats, or to protect the rights, property or safety of Company, our users, or the public. We limit such disclosures to what is reasonably necessary in the circumstances. ### 5. How do we protect the personal information we collect? *Security of Personal Information* We are committed to protecting the security of your personal information. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. Within our Company, we limit access to personal information on a need-to-know basis. We implement physical, organizational, and technical safeguards appropriate to the sensitivity of personal information to protect against loss, theft, and unauthorized access, disclosure, or use. We limit access to personal information on a need‑to‑know basis, encrypt data in transit (HTTPS/TLS) and at rest where appropriate, apply role‑based access controls and least‑privilege principles, and conduct regular security testing (audits, vulnerability scans, penetration tests). We maintain policies, procedures, and training on data protection and confidentiality, and we review and update our security program to reflect legal requirements, technological changes, and business needs. *Retention of Personal Information* We retain personal information only for as long as necessary to provide the services you request and to meet legal or business requirements (e.g., tax, dispute resolution, enforcement of agreements). Once the purposes for collection have been achieved, we destroy the personal information or anonymize it for serious and legitimate purposes, in accordance with applicable law. We apply safeguards to anonymized data to reduce the risk of re‑identification. If you would like to know more about our data transfer practices, please [helpdesk@cxgroup.com](mailto:helpdesk@cxgroup.com). ### How do you correct, update, or remove your personal information? To change, correct, or remove information you previously submitted to us: Mystery Shopper Help Desk: [helpdesk@cxgroup.com](mailto:helpdesk@cxgroup.com) ### 6. What are your privacy rights? We respect your right to access and control your personal information. You have choices about the information we collect. When you are asked to provide personal information that is not necessary for the purposes of providing you with our Sites, products or services, you may decline. However, if you choose not to provide data that is necessary to provide a service, you may not have access to certain features, Sites, products, or services. We aim to keep all personal information that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. *Access to personal information*: In some jurisdictions, you have the right to request access to your personal information. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. *Right to Rectification****:*** You have the right to correct or amend your personal information if it is inaccurate or requires updating. You may also have the right to request deletion of your personal information in some circumstances. Please note that such a request could be refused because your personal information is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law. *Withdrawing Consent*: In some jurisdictions, you may request to withdraw your consent to the use, disclosure and retention of your personal information. How this request is handled depends on the situation and the purpose for which it is made. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. In all cases, we may be required to retain certain personal information to comply with our legal obligations. *Marketing preferences*: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email, postal mail or telephone about our products, services and events that may be of interest to you, including newsletters. Our email communications will generally provide an unsubscribe link allowing you to opt-out of receiving future email or to change your contact preferences. Email communications may also include a link to directly update and manage your marketing preferences. If you have an online account with us, you can also change your contact preferences through your account settings. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts. **Under Quebec Private Sector Act, an individual has the following additional rights:** *Right to Erasure****:*** You have the right to require an organization to: - - cease disseminating personal information about them; - de-index any hyperlink that provides access to that information, if the dissemination violates the law or a court order; and - re-index any hyperlink that provides access to that information. - the dissemination of such information would cause the person serious harm in relation to the person's right to respect of their reputation or privacy; - the harm is clearly greater than the public’s interest in knowing the information or the right to freedom of expression (the balance of convenience criterion); and - the relief sought does not exceed what is necessary to prevent the continuation of the injury. Such a request may be made when the following conditions are met: *Right to data portability****:*** You have the right to request a copy of computerized personal information in the form of a written and intelligible transcript. *Exercise your rights*: To exercise your privacy rights or if you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact our privacy officer at [helpdesk@cxgroup.com](mailto:helpdesk@cxgroup.com). You can also opt out of our marketing emails at any time by contacting us at [helpdesk@cxgroup.com](mailto:helpdesk@cxgroup.com) or by sending us a post card to **CX Group**,**“OPT OUT”, *1919 S. Industrial, Suite 300, Ann Arbor, MI 48104.*** ### 7. What is our privacy policy if you are an underage child? We understand the importance of protecting the privacy of all individuals, especially minors. Our services are intended for Canadian audiences over the age of 18, and we do not knowingly collect personal information from children without appropriate consent. Our website and its services are not directed to children under 14. In Québec, minors under 14 cannot consent on their own; a parent or legal guardian must provide consent if we collect personal information for their benefit. Minors aged 14 or older may consent themselves, provided they understand the nature and consequences of the consent. You must also be old enough to consent to the processing of your personal information under the laws of your province or territory. For certain features, such as website forums or applications, you must be at least 16 years old. Subscribing to our services is restricted to adults who are 18 years of age or older, as a company policy. ### 8. What happens when you link to a third party website? If you click on a link and go to another site, you will be subject to that website’s privacy policy. We encourage you to read the posted privacy policy statement at any website ***before*** submitting any personal information at all. ### 9. What happens when we update our privacy policy? We may on occasion update our Privacy Policy. If we make any changes to our Privacy Policy, we will post a notice about the change at a prominent location on our website or notify you by appropriate means. Any changes to this Privacy Policy will be effective from the time they are posted. Your acceptance of any changes to this Privacy Policy is indicated by your continued use of our services. We encourage you to periodically review our Site and this Privacy Policy for any changes. ### 10. How to contact us For any questions or concerns about our personal information policies or practices, please contact our privacy officer: CX Group, Inc. Attn: Privacy Officer C.Krosnowski 1919 S. Industrial, Suite 300, Ann Arbor, MI 48104 ckrosnowski@cxgroup.com 734-302-8425 Please also see our other policies, standards, and codes which can be found here: [https://www.cxgroup.com/privacy-policy](https://www.cxgroup.com/privacy-policy?hsLang=en) ### 11.  Language in Québec (Charter Of The French Language) We acknowledge Québec’s language requirements for commercial publications and websites. While this Annex is provided in English, CX Group, Inc. will make privacy disclosures and interfaces available in French for Québec users under conditions no less favorable (equal or greater prominence and functionality). CX Group is an operating holding company that builds, supports, and scales specialized customer experience organizations focused on de-risking multi-location revenue. 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