Privacy Policy

PRIVACY POLICY

Date Updated: May 5, 2025

Page Two Strategies Inc. and its affiliate, Page Two Books Inc. (“Page Two”, “we”, “us”, or “our”) takes the protection of Personal Information and Business Contact Information seriously (collectively, “Personal Data”). This privacy policy (the “Policy”) is designed to help you understand how we collect, use, share and protect the Personal Data of individuals in connection with providing our services and business operations. This Policy applies to the Personal Data we collect online and offline during our business operations, such as when our website is accessed, including pagetwo.com and its local sub-domains (the “Website”).

The Website may contain links to other third-party websites or applications. Please be aware that these third-party websites and applications may collect information and may have their own privacy notices or policies. To the extent any linked websites or applications visited are not owned and operated by Page Two, we are not responsible or liable for the websites or applications’ content, and any use of the websites or applications would be subject to the privacy and security practices and policies of those website or applications.

I.  WHAT IS PERSONAL DATA?

For the purposes of this Privacy Policy:

  • “Personal Information” is any information that can be used, either alone or in combination with other information, to identify an individual. Personal Information includes but is not limited to your name, residential address, residential telephone number and personal e-mail address.
  • “Business Contact Information” is your name, position name or title, company, work address, work email address and work telephone number. Business Contact Information generally does not constitute Personal Information.

When you provide Personal Data to us, you represent and warrant that you have the appropriate authority and consent, including on behalf of your employer, to provide the Personal Data and that we are entitled to collect, use and disclose the Personal Data as outlined in this Policy.

II.  WHAT PERSONAL DATA DO WE COLLECT?

We may collect the following Personal Data. Please note we may combine Personal Data collected from one source with Personal Data we have collected from other sources.

(a)    Utilizing our Services

We collect Personal Data voluntarily provided to us directly, such as when you submit information through our Website or when utilizing our services or purchasing our products. This Personal Data may include:

      • Contact information, including name, telephone number and email address;
      • Employment details, including company name, job title and company address;
      • Experience and profile related to publishing submissions, including information related to your website, social media, professional biography, authorship history, spoken languages and self-identification as an under-represented group;
      • Delivery information related to product purchases, such as shipping address and payment and invoicing information;
      • Financial information related to product purchases, such as credit card details, bank details; and
      • Any other materials you submit to us, such as feedback.

(b)     Correspondence and Customer Service

We collect Personal Data when we engage in correspondence, and we typically keep a record of such correspondence. This correspondence may include contacting us for support or information, or signing up for email communications, including our newsletter and other updates.

This Personal Data may include your name, contact information, employer details, service information, queries, and other Personal Data provided to us.

(c)     Social Media Information

We maintain presences on social media platforms, including, Facebook, X (formerly Twitter), Instagram and LinkedIn. We collect Personal Data when individuals interact with us on social media. Please note that these social media platforms may set cookies and other tracking technologies on a device when their pages are visited. The output of such information may be provided to us (i.e. for statistical purposes to see how users interact with our content on social media platforms). Information about how the social media platforms collect and use Personal Data can usually be found in their respective privacy policies and cookies policies on their websites.

(d)     Employment

When applying for employment with Page Two, we are provided with contact information, questions or comments about the job posting, as well as Personal Data set out in a resume, including educational and employment history. We use this information to review the application and suitability for current employment opportunities, as well as to contact individuals with respect to same. We may also be provided with additional Personal Data through communications as part of the job application process.

III. HOW WE USE PERSONAL DATA

We may use your Personal Data for a variety of business purposes, which we have set out below.

(a)     To conduct our business, provide our services and access to our Website

To conduct our business, including to enable use of our services and Website, to respond to queries, to carry out our obligations arising from any agreements entered into, and to contact clients or potential clients in connection with the foregoing. This includes publishing services, the processing and fulfilling purchases and orders and providing information and updates relating to our business.

 (b)    To provide communications and customer support

To communicate about updates to our terms, services and Website, to provide customer support and to respond to requests, comments, questions, or concerns, and to contact clients or potential clients if we have any issues with respect to same. Such communications are provided by various means, including email and telephone number, and may include SMS text message. We only utilize SMS text messaging in accordance with section “IV. SMS Text Messages”.

(c)     To facilitate payments

To take and process payment for purchased products and services.

(d)     To ensure our Website content is relevant and to maintain its security

To ensure that content from our Website is presented in the most effective and secure manner.

(e)     To provide marketing materials

To provide our newsletter and/or other marketing materials, where you have chosen to receive these by email. Where required by law, we will ask for consent at the time we collect the Personal Data and provide an option to unsubscribe or opt-out of further communication.

(f)     To enforce our terms and in connection with legal or regulatory obligations

We may process Personal Data to enforce our terms and to comply with our legal and regulatory requirements or dialogue with regulators / judicial proceedings / court orders as applicable which may include disclosing Personal Data to third parties, the court service and / or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so.

(g)     To reorganise or make changes to our business

In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer Personal Data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer Personal Data to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this Policy.

IV. SMS TEXT MESSAGES

We do not use our Website submission forms to seek your consent to receive SMS text messages.

Where we already have a relationship with you, we may seek your express consent (verbally or via written communication) to collect your name and mobile phone number to send you SMS text messages. We use this information to communicate with you respecting the provision of our services and products.

Your name and mobile phone number, as well as the information you provide through SMS text messages (the “SMS Data”) is not shared with third parties for promotional or marketing purposes. Your SMS Data is only shared with our SMS service provider as strictly required to enable messaging.

You can text STOP at any time to unsubscribe from further text messaging.

V.  COOKIES

We use browser cookies (or “cookies”) on our Website, which are small text files. Cookies are uniquely assigned to you and can only be read by a website or web server that issued the cookie to you. We also use browser “log files” which record certain information when you visit our Website, including your IP address.

You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, our Website might not function correctly.

VI. PERSONAL DATA WE SHARE

We may collect, share or disclose Personal Data for the purposes outlined in this Policy via or to third parties as outlined below and as required by law. We do not sell your Personal Data to third parties.

(a)    Service providers

We share Personal Data with the following types of service providers:

      Type and purpose of Service Provider Type of Personal Data shared
      Email marketing distributor
      (i.e. Mailchimp)      		 Name and email address
      Website security and operations
      (i.e. WordPress, Wordfence)      		 Automatic technological collection data, including  location, page visited, date/time, IP address, hostname, operating device/system, and browser type
      Customer relationship management
      (i.e. Hubspot)      		 Contact information, employment details, submissions through our Website, and feedback
      Phone and SMS provider
      (i.e. Zoom)      		 Name, email address, and phone number
      Invoicing and billing management
      (i.e. QuickBooks)      		 Contact information and financial information
      Content management
      (i.e. BiblioSuite)      		 Contact information

(b)    Advisors

Such advisors may include legal, financial, business or other advisors.

(c)    Affiliated Companies

As our business continues to evolve, we may acquire, establish or sell business units or subsidiaries. Personal Data is one of the business assets that would be transferred in these types of transactions. In such a situation, your Personal Data would only be used in a manner consistent with this Policy.

(d)    Third parties as required by law or regulation

We may disclose Personal Data as required by law or regulation, and when we believe that disclosure is necessary to protect our rights and / or comply with a judicial proceeding, court order, or legal process served on Page Two.

VII. TRANSFERS OF PERSONAL DATA TO OTHER JURISDICTIONS

Our service providers are located in Canada, the United States, the United Kingdom and Ireland, and as a result, we may collect, process, store, share, and transfer your Personal Data within these countries. If you are a Quebec resident, your Personal Data will be collected, used and shared outside of Quebec.

As such, Personal Data may be accessed, transferred to, and / or stored at, a destination within and/or outside Canada or Quebec, including the United States and Ireland, in accordance with this Policy. Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, when your Personal Data is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

VIII. DATA RETENTION

Our retention periods for Personal Data are based on business needs and legal requirements.

We will retain Personal Data while we are using it, for purposes described in this Policy. We may continue to retain it after we have ceased such uses to meet our legal requirements.

The length of time for which we will retain Personal Data will depend on the purposes for which we need to retain it. After we no longer need to retain it, we will delete it or securely destroy it.

IX.  YOUR RIGHTS

When a request to exercise certain rights in relation to Personal Data is made, we will need to check the entitlement prior to answering a request.

In general, the following rights are available:

  • the right to be provided with details about what Personal Data we hold about you and whether your Personal Data has been transferred to a third party, and to be provided with a copy of your Personal Data;
  • the right to withdraw your consent;
  • the right to stop receiving marketing communication; and
  • the right to require us to update any inaccuracies in the Personal Data we hold. In order to assist us with this, please keep the relevant information up to date.

Your exercise of these rights may be subject to certain exemptions.

To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section below.

X.    UPDATING YOUR PERSONAL DATA

It is important that the information contained in our records is both accurate and current. If your Personal Data happens to change during the course of our relationship, please keep us informed of such changes.

XI.    SECURITY SAFEGUARDS

We protect and safeguard your Personal Data using physical, electronic and procedural measures appropriate to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, including safeguards to protect your information against loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Specifically, we implement the following measures to protect your Personal Data, including:

  • Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of an item of information and limit their access to that information on a “need-to-know” basis;
  • Physical, electronic and procedural safeguards that comply with relevant standards to protect personal information;
  • A designated privacy officer to monitor our compliance with applicable privacy laws; and
  • Procedures for receiving, investigating, and responding to complaints or inquiries about our information handling practices.

XII.    CHANGES TO THIS POLICY

We may update this Policy from time to time to reflect changes in our privacy practices and the law. We will indicate at the top of the Policy when it was most recently updated. We encourage you to periodically review this page for the latest information on our privacy practices.

XIII.    CONTACT US

If you have any questions about this Policy or our processing of your Personal Data, please contact our Privacy Officer at info@pagetwo.com. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

XIV.    INTERPRETATION OF THIS POLICY

This Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’. Should there be, in a specific case, any inconsistency between this Policy and privacy laws, as applicable, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

This Policy does not create or confer upon any individual any rights, or impose upon Page Two any obligations outside of, or in addition to, any rights or obligations imposed by privacy laws, as applicable.