ADENTRA Privacy Policy

Effective Date: January 20, 2026

Scope of this Policy

This Privacy Policy (“Policy”) explains how ADENTRA and its affiliated corporate entities (referred to as “we,” “us,” or “our”) collect, use, and protect personal information (“Information”) when you interact with our websites (“Sites”), engage in e-commerce transactions, or utilize our services (collectively the “Services”).  This Policy also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services.  Please review the privacy policies on those websites and applications directly to understand their privacy practices.   We may change this Policy from time to time. If we do, we will notify you by posting the updated version on our Services or by or other means.  Residents of certain states may have additional rights described here.

Information We Collect 

We collect Information from you directly, from the devices you use to interact with us, and from third parties. We may combine Information from the Services together and with other Information we obtain from our business records. We may use and share Information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip Information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.

Information you give us

You may provide the following Information to us directly:

• Contact and professional Information, including name, email address, telephone number, and job title, as well as company name and size
• Demographic Information.
• Audiovisual Information, including recordings of online events.
• Payment Information, including credit card Information.
• Content you may include in survey responses.
• Information contained in your communications to us, including call recordings of customer service calls.
• Information you make available to us via a social media platform.
• Any Information or data you provide by interacting in our online forums and chatrooms, or by commenting on content posted on our Services. Please note that these comments are also visible to other users of our Services.
• Information related to your use of our Services
• Information you submit to inquire about or apply for a job with us.
• Any other Information you submit to us.

Information we collect automatically

We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following Information from the devices you use to interact with our Services. We also create records when you make purchases or otherwise interact with the Services.

• Device Information, including IP address, device identifiers, and details about your web browser.
• Analytical Information, including details about your interaction with our Services, website, app, and electronic newsletters, your browsing history, and search history on our Services.
• Diagnostic Information, including web traffic logs.
• Advertising Information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect Information about you when you visit third-party websites or use third-party apps. They may use that Information to better target advertisements to you on our behalf.
• Business record Information, including records of your purchases of products and services and use of our Services.
• Approximate physical location (inferred from IP address).

Information We Collect From Other Sources

We may collect the following Information about you from third-party sources.

• Contact Information, demographic Information, and Information about your interests and purchases, from consumer data providers.
• Information about your credit history from credit reporting agencies.
• Information about your interests, activities, and employment history from social networks and other places where you choose to share Information publicly.
• Information about your interaction with advertisements on our Services, or ads that we place on third party websites, from online advertising companies.
• Subscription registration Information.
• If you invite others to the Services, we will collect your and the other person’s names, email addresses, and/or phone numbers to send an email or text message and follow up with the other person. You agree that you will obtain the other person’s consent before giving us their contact Information. You also agree that you will not send us the contact Information of a minor. We will inform any other person you invite that you gave us their Information in the invitation email.

How We Use Your Information

We may use any of the Information we collect for the following purposes.

• Service functionality: To provide you with our products and services, including to take steps to enter a contract for sale or for services, bill or invoice for services, process payments, fulfill orders, resolve issues, manage returns, create accounts, send service communications (including renewal reminders), system compatibility, and conduct general business operations, such as accounting, recordkeeping, and audits.
• Service improvement: To improve and grow our Services, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, quality assurance, and the effectiveness of our marketing,
• Personalization: To offer you recommendations and tailor the Services to your preferences, to enhance user experiences, to localize content, and for regional compliance (e.g., determining default consent settings)  Also, using analytics, including device identification, to recognize users across our Sites to maintain user state, personalize content, and provide a consistent experience.
• Analytics and Research: Internal analytics, security, performance monitoring, analyzing customer behavior, website performance, trend analysis, and user interaction to understand trends, measure the success of marketing efforts, and improve the functionality and design of our websites and Services.
• Advertising and Marketing: To send you marketing communications, personalize the advertisements you see on our Services and third-party online properties, and measure the effectiveness of our advertising.  This includes emails we send providing updates regarding ADENTRA and its services.  We may share your Information with business partners, online advertising partners, and social media platforms for this purpose.
• Security: To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent theft, unauthorized use and access, illegal activities, or abuse of the Services and other activities that may violate our policies or be fraudulent or illegal.
• Legal Compliance: To comply with legal process, such as warrants, subpoenas, court orders, and lawful regulatory or law enforcement requests and to comply with applicable legal and regulatory requirements.  To enforce our terms and conditions.
• Artificial Intelligence:  To process your Information for the purposes in this Policy with the assistance of artificial intelligence technologies such as machine learning and large language models that analyze and learn from your Information.  This technology may for example evaluate your preferences, past interactions with us, and behavior to send you content that is personalized to you.

How We Share Your Information

We may share any of the Information we collect with the following recipients.

• Affiliates: We share Information with other members of our group of companies and affiliates for internal administrative, operational, and UX consistency purposes, subject to this Policy.
• Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive Information about you from us or collect it directly. These vendors are obligated by contract to use Information that we share only for the purpose of providing these business functions, which include:
  • Supporting Service functionality, such as vendors that support event registration, customer service and customer relationship management, subscription fulfillment, freight services, payment processing, shipping, cloud hosting, application development, list cleansing, postal mailings, and communications (email, fax).
  • Auditing and accounting firms, such as firms that help us create our financial records.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.  For example, these vendors may assist us with  internal measurement, analysis, and as an essential security layer. We consider these tools to be essential for the following reasons: (1) Operational Necessity: They are used solely to generate aggregated and pseudonymized reports on site usage, which is necessary for the continuous operation, maintenance, and security of our services; (2) Cross-Site Consistency: Device identification allows us to provide a consistent and seamless user experience across our family of Sites by recognizing your device when you navigate between them; (3) Preventing Fraud and Abuse (Mutual Benefit): These technologies are essential for security as they allow us to identify and mitigate malicious or automated activity in real-time. By recognizing the identity of a device known to be involved in fraud, we can prevent malicious users from submitting deceitful account setup requests (preventing identity theft and system abuse), creating fraudulent purchase orders or credit applications (protecting both our business and legitimate users from financial damage), and attempting to compromise our Services through automated attacks (ensuring a stable and available service for all genuine users).  This process is designed to prevent bad actors from performing fraud, thereby protecting your account, your data, and the integrity of our services
  • Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.
  • Marketing vendors, such as entities that support distribution of marketing emails.
• Business partners: From time to time, we may share your contact Information with other organizations for marketing purposes.
• Online advertising partners: We partner with companies that assist us in advertising our Services, including partners that use cookies and online tracking technologies to collect Information to personalize, retarget, and measure the effectiveness of advertising.
• Social media platforms: If you interact with us on social media platforms, the platform may be able to collect Information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of Information, please review the privacy policy of the relevant social media platform.
• Government entities/Law enforcement: We may share Information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the health and safety of our employees, contractors, customers, or other individuals.
• Other businesses in the context of a commercial transaction: We may change our ownership or corporate organization while providing the Services. We may transfer to another entity or its affiliates or service providers some or all Information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your Information as described in this Policy.

Security

We use a combination of physical, technical, and administrative safeguards to protect the Information we collect through the Services. While we use these precautions to safeguard your Information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Your Options and Rights Regarding Your Information and Our Cookie Practices

We use a Consent Management Platform to manage user consent and track user preferences regarding non-essential tracking technologies.  You can change your consent preferences regarding non-essential cookies and tracking technologies at any time by clicking the “Your Privacy Choices” link available at the bottom of every page of our websites. This will allow you to revisit and modify your choices managed by our CMP.  When you agree to, or make changes to, your consent management settings on any one of our Sites, that choice will be automatically propagated across all other Sites located under our corporate umbrella. This ensures your privacy preferences are respected consistently throughout our network.  Cookies and other trackers on our Services include the following:

• Non-Essential Cookies: Non-essential cookies, such as certain social media cookies or optional performance cookies (if any) are used outside of our essential internal tracking Information, are managed via the CMP.  Please note that while disabling these cookies is your choice, it may limit your ability to access some features and could potentially affect the overall user experience, as certain functionality designed to enhance your visit may rely on them.
• Default Settings: Depending on your geographic region, non-essential cookies may be disabled by default (Opt-Out basis) or require affirmative action (Opt-In basis) as required by local law.
• Essential Tracking:  Our use of vendors for device identification and internal analytical and security purposes is necessary for the functionality and improvement of our service, so we classify this data processing as Essential.

Your Account: Please visit your account page to update your account Information. Email Unsubscribe: If you do not wish to receive marketing Information from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications. Ad Choices: You have options to limit the Information that we and our partners collect for online advertising purposes.

• You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our online properties.
• The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. 
• You may use our cookie settings menu.
• You may contact us directly.

If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you.  If you delete your cookies, you may also delete your opt-out preferences. Do Not Track: Your browser or device may include “Do Not Track” functionality. Our Information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this Policy regardless of whether a Do Not Track signal is received. Jurisdiction-specific rights: You may have certain rights with respect to your Information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.

Special Information for Job Applicants

When you apply for a job with us, we may collect Information from you, including:

• Information you provide in connection with your application.
• Information that you make available in your social media accounts.
• Information about you that is available publicly.
• Information that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Other Important Information

Data retention

We may store Information about you for as long as we have a legitimate business need for it.  We determine the retention period for the Information that we collect based on (1) the length of time we need to retain the Information to achieve the purposes for which we collected it, (2) any legal or regulatory requirements applicable to such Information, (3) internal operational needs, and (4) any need for the Information based on any actual or anticipated litigation or investigation.

Cross-border data transfer

Our business operations and all customer transactions are conducted exclusively within the United States and Canada. We may collect, process, and store your Information in the United States, Canada, and other countries. The laws in the United States and Canada regarding Information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law.

Information about children

The Services are intended for users who are eighteen years old and older. We do not knowingly collect Information from children. If we discover that we have inadvertently collected Information from anyone younger than the age of 18, we will delete that Information. Please contact us with any concerns.

Sharing of Medical or Health Information

If we receive protected health Information about you, that Information is subject to electronic disclosure as permitted by applicable law.

Privacy Disclosures for Specific Jurisdictions

California 

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of Information about them, as well as rights to know/access, correct, delete, and limit disclosure of Information. You have the right to be free from discrimination based on your exercise of these rights. If we collect Information subject to the CCPA, that Information, our practices, and your rights are described below. Notice at Collection Regarding the Categories of Information Collected The following table summarizes the categories of Information we collect; the categories of sources of that Information; whether we disclose, sell, or share that Information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such Information. The table also summarizes the categories of “sensitive” Information that we collect, the purposes for which such Information is used, and whether we sell or share such Information.  The categories we use to describe Information are those enumerated in the CCPA. We collect this Information for the purposes described above in “How We Use Your Information.”  Additional information about the Information we process is in the “Information We Collect” section and subsequent sections.

We determine the retention period for each of the categories of Information listed above based on (1) the length of time we need to retain the Information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such Information, (3) internal operational needs, and (4) any need for the Information based on any actual or anticipated investigation or litigation. Entities to whom we disclose Information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using Information for any purpose that is not related to our engagement.  Entities to whom we “sell” or with whom we “share” Information are third parties. Under the CCPA, a business “sells” Information when it discloses Information to a company for monetary or other benefit. A company may be considered a third party either because we disclose Information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using Information for purposes unrelated to the service it provides to us.  A business “shares” Information when it discloses Information to a company for purposes of cross-context behavioral advertising. Your rights under the CCPA, which are subject to exceptions:

• Opt out of sale or sharing of Information: You have the right to opt out of our sale or sharing of your Information to third parties. To exercise this right, please visit our Do Not Sell or Share My Information webpage or contact us. Your right to opt out does not apply to our disclosure of Information to service providers.
• Limit the use of your sensitive Information: You have the right to limit our use of your sensitive Information if we use such Information to infer characteristics about you.  We do not engage in this processing.
• Know and request access to and correction or deletion of Information: You have the right to request access to Information collected about you and Information regarding the source of that Information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct Information that we have collected about you and to delete Information that we have collected directly from you. Please contact us to exercise these rights.

Your California Privacy Rights; “Shine the Light” Law

California residents are entitled once a year, free of charge, to request and obtain certain Information regarding our disclosure, if any, of certain categories of Information to third parties for their own direct marketing purposes in the preceding calendar year. We do not share your Information with third parties for those third parties’ direct marketing purposes.

Other States

Residents of other states may have the following rights:

• Opt out of “sales” of Information and use of their Information for “targeted advertising,” as those terms are defined under applicable law.
• Opt out of “profiling” under certain circumstances, as defined under applicable law.
• Confirm processing of and access to Information under certain circumstances.
• Correct Information under certain circumstances.
• Request the specific third parties (other than natural persons) to which Information has been disclosed. (Minnesota, Oregon, and Connecticut only)
• Delete Information under certain circumstances.

You may contact us by using one of the methods listed below to exercise any rights applicable to your state of residence.

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their Information to third parties. Currently, we do not engage in such sales.

Contact Information, submitting requests, and our response procedures

Contact

Please contact us if you have questions or wish to take any action with respect to Information to which this Policy applies:

ADENTRA
Attention: Privacy Officer
20161 86th Avenue
Building B – Suite 340
Langley, BC, V2Y 2C1
Email: privacy@adentragroup.com
Phone: 866-250-5393

Making a request to exercise your rights

Submitting requests: You may request to exercise your rights by making a request using the contact Information above. If you are a resident of some states, you may, under certain circumstances, authorize another individual or a business, called an authorized agent, to make requests on your behalf.   We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response. Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against Information we may have collected from you previously. We may need to follow up with you to request more Information to verify identity.  We will not use Information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Appeals

Residents of certain states have the right to appeal a denial of their request by contacting us as described in the notice of denial.