Nani's Gelato Inc. ("Nani's Gelato," "we," "us," or "our") operates gelato shops and franchise locations and the website at nanisgelato.com (the "Site"). This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in the course of our commercial activities.

We handle personal information in accordance with applicable Canadian privacy laws, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector, and other applicable provincial legislation. By using the Site or submitting information to us, you acknowledge that you have read this Policy. Where consent is required, we will seek it in an appropriate form.

1. Scope

This Policy applies to personal information collected through the Site, online forms, email, telephone, SMS/text messaging, franchise inquiries and applications, catering or general inquiries, newsletter subscriptions, promotions, and other interactions with Nani's Gelato. It does not apply to independently operated third-party websites or services, or to employee information governed by a separate policy.

2. Personal Information We Collect

Depending on how you interact with us, we may collect:

• Contact information, such as your name, email address, telephone or mobile number, mailing address, city, and preferred location.
• Inquiry and transaction information, including the content of your messages, catering details, requests, preferences, and related correspondence.
• Franchise application information, such as desired territory, business and industry experience, occupation, intended involvement, available investment capital, and responses concerning bankruptcy, criminal-record history, or other eligibility questions. We collect sensitive application information only where reasonably necessary and with appropriate consent.
• Marketing and consent information, including newsletter selections, SMS opt-in records, the date and method of consent, and records of unsubscribe, STOP, or HELP requests.
• Technical and usage information, such as IP address, browser and device type, operating system, referring pages, pages viewed, approximate location, cookie identifiers, and Site interaction data.

Please do not provide personal information that we do not request or need. If you submit personal information about another person, you represent that you have authority to do so and have provided any notice or obtained any consent required by law.

3. How We Collect Information

We collect information directly from you when you complete a form, subscribe, contact us, apply for a franchise opportunity, communicate with us, or opt in to calls, emails, or SMS messages. We also collect limited technical information automatically through cookies and similar technologies. We may receive information from service providers acting for us, our franchise development personnel, or other sources where permitted by law.

4. How We Use Personal Information

We may use personal information to:

• Respond to inquiries and provide requested information or services;
• Evaluate and process franchise inquiries and applications and communicate about related opportunities;
• Send service, follow-up, marketing, email, or SMS communications where you have consented or where otherwise permitted by law;
• Manage subscriptions, consent records, preferences, and opt-out requests;
• Operate, secure, maintain, troubleshoot, personalize, and improve the Site and our forms;
• Analyze Site traffic and usage, measure campaigns, and understand customer interests;
• Prevent fraud, misuse, security incidents, and violations of our Terms and Conditions; and
• Meet legal, regulatory, accounting, reporting, and contractual obligations.

We will not use personal information for a materially different purpose without obtaining additional consent where required by law.

5. Consent and Communications

We collect, use, and disclose personal information with your knowledge and consent, except where permitted or required by law. Consent may be express or implied, depending on the sensitivity of the information and the circumstances. Where a form asks you to opt in to calls, text messages, or emails, we rely on your express consent to send those communications, including as required by Canada's anti-spam legislation (CASL).

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. To stop text messages, reply STOP. To request assistance, reply HELP or email [email protected]. You may unsubscribe from marketing emails using the unsubscribe link in the message. Withdrawal does not affect processing already carried out lawfully and may limit our ability to provide certain communications or services.

6. SMS Privacy Disclosure

Mobile phone numbers, SMS opt-in information, and consent data will not be sold, shared, or disclosed to third parties or affiliates for marketing or promotional purposes. SMS consent information will only be used as necessary to provide the requested communications and services.

We may provide this information to service providers that transmit or support our messages solely to perform services for us, subject to confidentiality and data-protection obligations. Message frequency may vary. Message and data rates may apply. See the SMS Terms & Conditions in our Terms and Conditions.

7. When We Disclose Information

We do not sell personal information. We may disclose personal information only as reasonably necessary:

• To service providers that host the Site, process forms, manage customer or applicant relationships, deliver communications, provide analytics, support security, or perform other services for us. These providers may use the information only to provide contracted services or as otherwise permitted by law.
• To Nani's Gelato personnel and authorized franchise development personnel who need the information to respond to or evaluate an inquiry or application.
• To professional advisers, auditors, insurers, regulators, courts, law-enforcement authorities, or other persons where required or permitted by law or necessary to protect rights, safety, and security.
• In connection with a proposed or completed financing, reorganization, merger, acquisition, sale, or transfer of all or part of our business, subject to applicable confidentiality and legal requirements.

We require service providers to safeguard personal information and limit their use of it to the purposes for which it was disclosed.

8. Cookies and Analytics

The Site may use cookies, pixels, tags, and similar technologies, including tools provided by HubSpot and Google Analytics, to enable forms, remember preferences, recognize repeat visits, attribute submissions, maintain security, and understand Site usage. These tools may collect technical and usage information and may set their own cookies.

You can control or disable cookies through your browser settings and any cookie controls made available on the Site. Blocking some cookies may affect Site or form functionality. Where applicable law requires consent for non-essential cookies, we will request it through the Site's consent mechanism.

9. Cross-Border Processing

Some service providers may process or store personal information outside your province or outside Canada, including in the United States. Information processed in another jurisdiction may be subject to that jurisdiction's laws and may be accessible to courts, law-enforcement, or national-security authorities. We use contractual and other measures intended to provide appropriate protection when information is handled by service providers.

10. Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Policy, meet legal or business requirements, resolve disputes, and enforce agreements. Retention periods vary based on the nature and sensitivity of the information and the reason it was collected. When information is no longer required, we securely delete, destroy, or anonymize it, subject to backup and legal-retention requirements.

11. Safeguards

We use administrative, physical, and technological safeguards appropriate to the sensitivity and amount of the information and the purposes for which it is used. These measures are designed to protect against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. No system or transmission method is completely secure, and we cannot guarantee absolute security.

12. Your Privacy Rights

Subject to applicable law, you may request access to personal information we hold about you, request correction of inaccurate or incomplete information, and withdraw consent. Depending on your province, you may also have rights concerning deletion, data portability, automated decision-making, or the cessation of dissemination or de-indexing of information.

To exercise a privacy right, contact our Privacy Officer using the details below. We may verify your identity and may ask for enough detail to locate the relevant information. We will respond within the time required by applicable law. If we cannot fulfill a request, we will explain why, subject to legal restrictions.

13. Children's Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without consent from a parent or guardian. If you believe a child has provided personal information to us inappropriately, please contact us so we can review and take appropriate action.

14. Third-Party Websites

The Site may contain links to websites or services operated by others. Their privacy practices are governed by their own policies. We are not responsible for their content, security, or privacy practices, and we encourage you to review their policies before providing information.

15. Complaints and Contact Us

Our Privacy Officer is responsible for overseeing compliance with this Policy. Questions, access or correction requests, consent withdrawals, and complaints may be directed to:

Nani's Gelato Inc.
Attention: Privacy Officer
1A-6039 Erin Mills Parkway
Mississauga, ON L5N 0G5
Email: [email protected]

We will investigate privacy complaints and respond appropriately. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at priv.gc.ca or the applicable provincial privacy regulator, including Quebec's Commission d'acc�s � l'information where relevant.

16. Changes to This Policy

We may update this Policy from time to time. We will post the revised version on the Site and change the effective date above. Where required by law, we will provide additional notice or seek renewed consent. We encourage you to review this Policy periodically.