Privacy Policy

Last updated:

1. Data Controller

The data controller responsible for your personal data is:

Zefrylonkhuliu
4280 Harvester Rd Unit 9, Burlington, ON L7L 5Z5, Canada
Email: partnership@zefrylonkhuliu.world
Phone: +1 877 456 5766
Website: zefrylonkhuliu.world

2. Scope and Applicable Law

Zefrylonkhuliu is operated from Ontario, Canada. We handle personal information in line with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws where they apply. If you access this site from the European Economic Area or the United Kingdom, the General Data Protection Regulation (GDPR) or UK GDPR may also apply; in those cases we provide the rights and safeguards described in this policy that align with those frameworks.

3. What Data We Collect

We may collect the following categories of personal data:

• Name — provided through the contact form
• Email address — provided through the contact form
• Message content — provided through the contact form
• Cookie preferences — stored locally in your browser
• Technical data — IP address, browser type, operating system, referring URL, pages visited, and time of access (collected through analytics cookies, if consented)

4. Purposes of Data Processing

We process your personal data for the following purposes:

• To respond to inquiries submitted through the contact form
• To ensure the proper technical functioning of the website
• To analyze website usage and improve content (only with your consent)
• To comply with legal obligations

5. Legal Basis for Processing

Canada (PIPEDA). We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances. We identify these purposes at or before collection. We rely on your consent where required by law (for example, for optional analytics or marketing technologies, and for contact form submissions where you check the consent box). We may also use or disclose information when necessary for purposes that are clearly in your interest and you would not reasonably expect us to obtain consent, or as required or permitted by law.

European Economic Area and United Kingdom (GDPR / UK GDPR). Where those laws apply, we process personal data based on the following legal grounds under GDPR Article 6:

• Consent (Article 6(1)(a)) — for analytics and marketing cookies, and for processing contact form submissions
• Legitimate interest (Article 6(1)(f)) — for ensuring website security and functionality
• Legal obligation (Article 6(1)(c)) — for compliance with applicable laws

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:

• Contact form data: retained for up to 12 months after the inquiry is resolved, then securely deleted
• Analytics data: retained for up to 26 months, then automatically deleted
• Cookie consent preferences: stored in your browser's localStorage until you clear it or withdraw consent

7. Your Privacy Rights

Canada (PIPEDA). Subject to limited legal exceptions, you have the right to request access to the personal information we hold about you, to request correction of inaccurate or incomplete information, and to withdraw consent to uses that are based on consent (where withdrawal is not restricted by contract or law). You may also challenge our compliance with PIPEDA by contacting the Office of the Privacy Commissioner of Canada (see Complaints below).

European Economic Area and United Kingdom. Where the GDPR or UK GDPR applies, you may have the following rights:

• Right of access — request a copy of your personal data
• Right to rectification — request correction of inaccurate data
• Right to erasure — request deletion of your personal data
• Right to restrict processing — request limitation of data processing
• Right to data portability — receive your data in a structured, machine-readable format
• Right to object — object to processing based on legitimate interest
• Right to withdraw consent — withdraw consent at any time without affecting the lawfulness of prior processing

To exercise any of these rights, contact us at partnership@zefrylonkhuliu.world. We will respond within a reasonable time and, where the GDPR or UK GDPR applies, within 30 days unless applicable law allows an extension.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• HTTPS encryption for all data transmitted between your browser and our servers
• Access controls limiting data access to authorized personnel only
• Regular review of security practices

9. Third-Party Sharing

We do not sell, rent, or trade your personal data. We may share data with:

• Hosting providers — for the purpose of operating this website
• Analytics providers — only if you have consented to analytics cookies

Where we use processors outside Canada, we take steps that are appropriate under PIPEDA (including contractual measures) to protect personal information. Where the GDPR applies, processors are contractually bound to meet GDPR requirements.

10. International Transfers

Personal information may be processed or stored in Canada and, depending on our service providers, in other countries. Under PIPEDA, we remain accountable for personal information in our custody or under our control, including when processed by service providers abroad, and we use contractual or other means to provide a comparable level of protection.

If your data is transferred outside the European Economic Area (EEA) or UK, and the GDPR or UK GDPR applies, we ensure appropriate safeguards are in place where required, such as Standard Contractual Clauses approved by the European Commission or UK authorities.

11. Cookies

This website uses cookies. For detailed information about the types of cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy.

12. Commercial Electronic Messages (CASL)

Canada’s Anti-Spam Legislation (CASL) regulates commercial electronic messages. We do not send you marketing or promotional emails unless you have given express consent or an exception applies. Messages we send in direct response to your contact form inquiry are not treated as unsolicited commercial electronic messages under CASL when they solely relate to that inquiry.

13. Children's Privacy

This website is not directed at children. We do not knowingly collect personal information from anyone under 13. Where the GDPR or UK GDPR applies, we do not knowingly collect personal data from individuals under 16 without appropriate consent. If you believe we have collected such information by mistake, contact us and we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

15. Complaints

If you believe we have not handled your personal information in accordance with Canadian law, you may file a complaint with the Office of the Privacy Commissioner of Canada: 30 Victoria Street, Gatineau, Quebec K1A 1H3; telephone 1-800-282-1372; website https://www.priv.gc.ca.

Residents of Quebec may also contact the Commission d’accès à l’information du Québec regarding certain privacy matters: https://www.cai.gouv.qc.ca.

If you are in the EEA or UK and the GDPR or UK GDPR applies, you may lodge a complaint with your local data protection supervisory authority.

16. Contact

For any questions or concerns about this Privacy Policy or our data practices, please contact us:

Zefrylonkhuliu
4280 Harvester Rd Unit 9, Burlington, ON L7L 5Z5, Canada
Email: partnership@zefrylonkhuliu.world
Phone: +1 877 456 5766