Privacy Notice

This Privacy Notice explains how 11092766 Canada Inc., doing business as Bespoke Lingvo ("we", "us", or "our"), collects, uses, discloses, and protects personal information when you visit bespokelingvo.com (the "Website") or contact us through the Website.

We are a Canadian corporation providing private French-language coaching and related educational services to clients in Canada and internationally.

We aim to collect only the personal information reasonably necessary to respond to enquiries and provide our services.

1. What Information We Collect

Information you provide through the contact form. If you choose to contact us through the Website, we collect the information you enter into our enquiry form. This may include:

• your name;
• your email address;
• your current level of French;
• why you need French; and
• your answer to "What would you like to do in French that you cannot comfortably do today?"

We do not ask you to create an account through the Website, and we do not collect payment information through the Website enquiry form.

Please do not submit highly sensitive or confidential information through the enquiry form, such as passwords, payment-card information, government identification numbers, medical information, or confidential documents belonging to your employer, clients, or other third parties.

Technical information. We do not use the Website to create advertising profiles about visitors, and we do not currently use advertising pixels or behavioural advertising technologies.

However, the providers that host, secure, and transmit the Website and its contact form may process limited technical information in the ordinary operation of their services. Depending on the provider, this may include an IP address, browser or device information, request timestamps, and security or server-log information.

We do not use such technical information for behavioural advertising.

2. Why We Collect and Use Information

We use information submitted through the contact form to:

• receive and respond to your enquiry;
• understand your current level of French;
• understand why you are seeking French-language coaching;
• understand what you would like to be able to accomplish in French;
• determine whether our services may be appropriate for your objectives;
• communicate with you about a possible assessment or coaching engagement;
• maintain a reasonable record of our correspondence;
• prevent spam, fraud, abuse, and security incidents; and
• comply with applicable legal obligations.

We do not use information submitted through the enquiry form to add you automatically to a newsletter or general marketing list.

We do not sell your personal information. We do not rent your personal information.

We do not use your contact-form information for third-party behavioural advertising.

We do not make solely automated decisions about you that produce legal or similarly significant effects.

3. Lawful Basis for Processing

The legal basis on which we process personal information depends on where you are located and the circumstances in which the information is collected.

Canada. Where Canadian privacy law applies, including the Personal Information Protection and Electronic Documents Act ("PIPEDA") where applicable, we collect, use, and disclose personal information for purposes that we identify to you and that a reasonable person would consider appropriate in the circumstances. When you voluntarily send us an enquiry, we use the information you provide for the purpose of receiving, evaluating, and responding to that enquiry.

European Union and European Economic Area. Where the General Data Protection Regulation ("GDPR") applies, our lawful bases may include:

• Steps requested before entering into a contract. When you contact us because you are considering our services, processing your information may be necessary to respond to your request and take steps at your request before a possible coaching agreement is entered into.
• Legitimate interests. We may process limited personal information where necessary for our legitimate interests in operating our business, responding to genuine business enquiries, maintaining appropriate records, and protecting the Website against fraud, spam, abuse, and security threats, provided those interests are not overridden by your rights and interests.
• Legal obligations. We may process information where necessary to comply with a legal obligation that applies to us.
• Consent. Where applicable law requires your consent for a particular activity, we will request it separately.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that took place before consent was withdrawn.

United Kingdom. Where UK data-protection law applies, we rely on the corresponding lawful bases available under the UK GDPR and applicable UK legislation.

4. Sharing Information with Third Parties

We disclose personal information only where reasonably necessary to operate the Website and our business, respond to your enquiry, protect our rights and systems, or comply with applicable law.

Service providers. We may use third-party providers for functions such as:

• website hosting;
• contact-form processing;
• business email;
• website and information security; and
• professional services where reasonably necessary.

Information submitted through the enquiry form is stored in Google Cloud Firestore, operated by Google LLC, and a notification is delivered to our business email. The form is protected by Google reCAPTCHA Enterprise, which runs only when you submit the form and may set its own cookies; reCAPTCHA does not load unless the form is used.

Service providers process information according to their respective roles, contractual arrangements, and applicable law.

Legal requirements. We may disclose personal information if reasonably necessary to comply with applicable law, respond to a valid court order or other lawful request, investigate fraud, abuse, or security incidents, protect our legal rights or the rights of another person, or establish, exercise, or defend a legal claim.

No sale of personal information. We do not sell personal information to data brokers, advertising companies, or other third parties, and we do not disclose contact-form information to third parties for their own behavioural advertising purposes.

5. International Data Transfers

We are a Canadian corporation and may provide services to people in Canada, the United States, Europe, and other jurisdictions.

Your personal information may therefore be processed in a country other than the country in which you live. Our service providers may operate infrastructure in Canada, the United States, or other jurisdictions. For example, information submitted through our contact form may be processed through infrastructure operated by our form-processing provider.

When personal information is processed in another country, it may be subject to the laws of that jurisdiction, including lawful access requirements applicable to service providers there.

Where European or UK data-protection law requires specific safeguards for an international transfer, we will use applicable transfer mechanisms or other safeguards as required by law.

6. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and for applicable legal, accounting, record-keeping, or dispute-resolution requirements.

Website enquiries. If you contact us through the Website but do not become a client, we ordinarily retain your enquiry and related correspondence for up to 12 months after our last substantive communication with you. We may delete the information sooner if it is no longer reasonably necessary.

If you become a client. If you subsequently become a client, relevant information from your initial enquiry may become part of the records associated with our professional relationship. Those records may be retained for longer periods where reasonably necessary for contractual, accounting, tax, legal, or business record-keeping purposes. Information concerning an active or former client may also be governed by a separate service agreement or privacy information provided in connection with the client relationship.

Legal claims. We may retain particular information for longer where reasonably necessary to establish, exercise, or defend a legal claim or where retention is required by law.

When information is no longer required, we take reasonable steps to delete, destroy, or anonymize it as appropriate.

7. Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature and sensitivity of the personal information under our control.

We also select third-party service providers with consideration for their security and privacy practices.

However, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of information transmitted through the Internet.

If we become aware of a personal-information breach, we will assess and respond to it in accordance with applicable legal requirements.

8. Your Privacy Rights

Your privacy rights depend on where you live and which privacy laws apply.

To make a privacy request, contact privacy@bespokelingvo.com. We may need to verify your identity before responding to certain requests.

Canada. Where applicable Canadian privacy law applies, you may have the right to:

• ask whether we hold personal information about you;
• request access to personal information we hold about you;
• ask how that information has been used or disclosed;
• request correction of inaccurate or incomplete personal information; and
• raise a complaint about our privacy practices.

If PIPEDA applies and you are not satisfied with our response to a privacy complaint, you may also have the right to contact the Office of the Privacy Commissioner of Canada. Depending on your province or territory, another provincial privacy authority may also have jurisdiction.

European Union and European Economic Area. Where the GDPR applies, you may have the right, subject to the conditions and exceptions established by law, to access your personal data; correct inaccurate or incomplete personal data; request erasure of your personal data; request restriction of processing; object to certain processing; receive certain personal data in a portable format; withdraw consent where processing is based on consent; and lodge a complaint with a competent data-protection supervisory authority. You may also object to processing based on legitimate interests where applicable.

We do not use contact-form information for direct-marketing profiling or automated decision-making that produces legal or similarly significant effects.

United Kingdom. Where UK data-protection law applies, you may have corresponding rights under the UK GDPR and applicable UK legislation.

United States. Depending on your state of residence and whether a particular state privacy law applies to our business and to the information concerned, you may have statutory privacy rights. We do not sell personal information and do not use contact-form information for targeted behavioural advertising.

Nothing in this Privacy Notice is intended to limit any privacy right that applicable law gives you and that cannot legally be waived.

9. Cookies, Analytics, and Tracking

We do not currently use the Website for behavioural advertising or cross-site tracking.

We do not currently use advertising pixels such as the Meta Pixel, and we do not currently use information from the enquiry form for advertising analytics.

The Website may use strictly necessary browser technologies required for its ordinary operation.

If the Website remembers a display preference you choose, such as the light or dark colour scheme, that preference is stored locally in your browser. It is used only to remember your selection and is not used to track you across other websites.

If we later introduce analytics, advertising technologies, or other non-essential tracking tools, we will update this Privacy Notice and implement any consent mechanism required by applicable law before or when those technologies are introduced.

10. Children's Privacy

The Website and the professional coaching services promoted through it are intended primarily for adults.

We do not knowingly use the Website to solicit personal information from children.

If we learn that personal information from a child has been submitted in circumstances where parental or guardian authorization is legally required and has not been obtained, we will take reasonable steps to delete the information.

If you believe a child has submitted personal information to us inappropriately, please contact privacy@bespokelingvo.com.

11. Third-Party Websites

The Website may contain links to third-party websites or services.

These third parties operate independently of us and have their own privacy practices.

We are not responsible for the privacy practices, security, or content of third-party websites. We encourage you to review the privacy notice of any third-party service you choose to use.

12. Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in:

• the Website;
• our information-handling practices;
• our service providers;
• our business operations; or
• applicable legal requirements.

When we update the Privacy Notice, we will change the "Last updated" date at the top of this page. The current version will be available on the Website.

If a change materially affects how we use personal information already collected, we will take any additional steps required by applicable law.

13. Contact Us

11092766 Canada Inc. is responsible for personal information under its control.

The person responsible for our privacy practices may be contacted at:

You may contact the Privacy Officer to ask a question about this Privacy Notice; request access to personal information; request correction or deletion where applicable; ask how your information has been used or disclosed; exercise another privacy right available to you; or make a complaint about our privacy practices.