Privacy Policy

1. Who We Are and Scope of This Policy

SuperiorColo ("SuperiorColo", "we", "us", "our") is a division of Donald L Davidson Fuels Ltd., headquartered at 160 Mills Drive, Wawa, Ontario P0S 1K0, Canada. This Policy covers personal information processed through:

• all SuperiorColo‑branded websites, portals and mobile apps;
• visits to our data‑centre facilities;
• business contacts, contracts and marketing interactions; and
• support, billing and account‑administration services.

2. Key Definitions

• Personal Information – any information about an identifiable individual, including contact details, device IDs or biometric templates.
• Processing – any operation performed on personal information, such as collection, storage, use, disclosure or destruction.
• PIPEDA – Canada's Personal Information Protection and Electronic Documents Act, which applies to private‑sector organisations across Canada, including those in Ontario.
• GDPR – the EU General Data Protection Regulation, which may apply when we process personal data of individuals in the European Economic Area.

3. What We Collect

4. How We Use Personal Information

5. Legal Bases for Processing

• Consent – CASL email marketing, optional cookies.
• Performance of a contract – providing rack space, cross‑connects, remote‑hands, etc.
• Legitimate interests – securing our facilities and networks, improving services.
• Legal obligations – tax, bookkeeping, mandatory breach reporting, export‑control.

6. Sharing & International Transfers

We do not sell personal information. We share it only with:

• Data‑centre security vendors, connectivity partners or cloud providers under strict contracts;
• Payment processors and auditors bound by confidentiality;
• Government or law‑enforcement bodies when legally required;
• Affiliates inside and outside Canada, relying on Canada‑EU adequacy, standard contractual clauses or equivalent safeguards for cross‑border transfers.

7. Safeguards

We employ layered physical, administrative and technical controls, including 24 × 7 security personnel, CCTV, multi‑factor biometrics, network segmentation, encryption in transit and at rest, vulnerability management and regular penetration tests.

8. Data Retention & Destruction

Personal information is retained only as long as necessary for the purposes set out here, after which it is securely deleted or anonymised. Biometric templates are erased within one year of access termination unless a longer period is mandated by law or dispute‑preservation needs.

9. Your Rights

Under PIPEDA (and, where applicable, GDPR) you may:

• request access to or correction of your personal information;
• withdraw consent for non‑essential processing;
• lodge a complaint with the Office of the Privacy Commissioner of Canada or your local EU supervisory authority;
• request portability or erasure where GDPR applies.

10. Breach Notification

Should a breach of security safeguards pose a real risk of significant harm, we will notify the Office of the Privacy Commissioner of Canada, affected individuals and (where applicable) EU regulators without undue delay, and maintain breach records as required.

11. Children's Privacy

We do not knowingly collect information from children under 16. If we learn that we have inadvertently done so, we will delete it promptly.

12. Third‑Party Sites & Services

Links to external sites are provided for convenience; their privacy practices are not governed by this Policy.

13. Policy Changes

We may revise this Policy periodically. Material changes will be highlighted on our website and, where required by law, we will seek renewed consent.

14. Contact Us

15. Effective Date

18 April 2025 – supersedes prior versions.