This Local Country Addendum for Canada (“Canada Addendum”) applies in relation to the processing of “personal information” of individuals falling within the scope of the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”) by Fortude Canada. As used in this Canada Addendum, “Personal Data” shall refer to “personal data” as defined in the Privacy Policy that falls within the definition of “personal information” as used in PIPEDA.
Fortude Canada shall comply with PIPEDA when processing your Personal Data and shall not use your Personal Data for any purposes which are not specified in this Privacy Policy. Detailed information on PIPEDA can be found at: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/pipeda_brief/.
Exercise of your Data Protection Rights
Under PIPEDA, you have the right to:
- Request access to your personal information;
- Request correction of your personal information where it is inaccurate or incomplete.
In addition to the above, as a matter of Fortude’s global policy, we also extend the following rights to you:
- The right to request erasure of your personal information, in certain circumstances;
- The right to request restriction of processing of your personal information, in certain circumstances;
- The right to request the transfer of your personal information to another party, in certain circumstances;
- The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Where a right listed above is not a statutory right under PIPEDA, we will still make reasonable efforts to honour your request, but we are not obliged to do so where it is not legally or technically feasible.
You may exercise any of your data protection rights as stipulated in the Privacy Policy:
- If you are above 18 years of age;
- Where you are a minor, by a parent or a person who has parental authority over you or has been appointed as your legal guardian;
- Where you are physically or mentally unfit, by a personal who has been appointed as your guardian or administrator by a court of law;
- Except in items 2 and 3 above, by a person duly authorized in writing by you to make a request; or
- By your legal heir within a period of 10 years from your demise.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights), which shall include your full name and other information or documentation that we may reasonably request to confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Time limit to respond
We will respond to your request as soon as reasonably possible. In the event we are not able to respond to your request within thirty (30) days after receiving your request, we will inform you before the deadline.
If we are unable to provide you with any Personal Data or to make a correction you have requested, we shall inform you of the reasons.
Transmission and storage of Personal Data outside Canada
Personal Data that we collect may be uploaded, moved, stored, processed in, backed up and/or transferred between any of the countries in which we operate or may operate in order to enable us to collect, use, and/or disclose the Personal Data in accordance with the Privacy Policy. Your Personal Data may be uploaded, moved, stored, processed in, backed up and/or transferred in Fortude Canada’s discretion in Canada or in jurisdictions other than Canada, including the United States, and you consent to the same. You also acknowledge and agree that your Personal Data may be transmitted, uploaded, or moved across international borders in Fortude Canada’s discretion, and you consent to the same. Personal Data processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws.
PIPEDA Use and Disclosure Exceptions
You acknowledge and agree that Fortude Canada may use and/or disclose your Personal Data, without notice, if legally permitted to do so according to the relevant provisions of PIPEDA, and/or any other relevant privacy enactment. PIPEDA may permit the use and/or disclosure of Personal Information without notice if, for example: (a) the Personal Data could be useful in the investigation of a contravention of the laws of Canada, a province of Canada or a foreign jurisdiction; (b) the Personal Data is used or disclosed for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual; and/or (c) the Personal Data is disclosed to comply with the edicts of the law, or to comply with a subpoena or warrant issued or an order made by a court.
Complaints
You also have the right to lodge a complaint with the applicable supervisory authority, if you consider that the processing of your personal data infringes upon any rights or obligations under PIPEDA. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us beforehand.
Amendments to the Canada Addendum
Fortude Canada reserves the right at any time to add to, change, update or modify this Canada Addendum. These changes will be notified on the website and will be effective immediately upon posting. If we make material changes to the Canada Addendum, we may also let you know via email.
This Canada Addendum was last updated on 19ᵀᴴ August 2026.
