Privacy Policy

1. Introduction

1.1 This Privacy Policy explains how Leading Edge Company Inc., operating as Leading Edge Associates ("Leading Edge Associates", "we", "us", or "our") collects, uses, discloses, and protects personal information in connection with our websites, learning platforms, services, and business operations.

1.2 This Privacy Policy applies to personal information collected through our website, online services, training programs, and related interactions with clients, learners, partners, and visitors.

1.3 We are committed to protecting personal information and handling it responsibly and transparently. Personal information is collected and processed in accordance with applicable Canadian privacy laws and, where relevant, other applicable data protection laws.

1.4 We may engage trusted third-party service providers to support our operations. These providers are required to implement appropriate safeguards to protect personal information and to process it only in accordance with our instructions and applicable law.

1.5 Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those third-party sites.

1.6 We may update this Privacy Policy from time to time. Any updates will be posted on our website and will apply prospectively.

2. Data Controller

2.1 Leading Edge Company Inc. (operating as Leading Edge Associates) is responsible for determining how and why personal information is collected and processed in connection with our services and operations.

2.2 We are incorporated in Canada and are subject to applicable Canadian federal and provincial privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as any other applicable privacy legislation.

2.3 Where personal information is collected or processed in other jurisdictions, we take reasonable steps to ensure compliance with applicable local data protection requirements.

3. Type of Information Collected

3.1 We collect two types of information:

3.1.1 Personal information

"Personal information" means any information relating to and identified or identifiable natural person.

• 3.1.1.1 Information that you provide when expressing an interest in obtaining additional information about our service, registering to use our service or registering for an event, such as name, company name, email address, phone number, and other contact details.
• 3.1.1.2 Information that you provide when applying for a job with our company such as a resume or cover letter containing other details about your employment history.
• 3.1.1.3 Information that you provide when purchasing the service such as billing name and address, and other financial information provided by you when completing a transaction through the website.
• 3.1.1.4 Optional information that you may provide when asked by Leading Edge Associates, for example a request to partake in a survey or to download a brochure/white paper.
• 3.1.1.5 Information about your location when you access the Site.

3.1.2 Non-personal information

Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-personal information comprises information that cannot be used to identify or contact you.

• 3.1.2.1 Information collected from cookies in your Web browser. This information includes standard information from you (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Company website (such as the Web pages viewed and links clicked). Our use of cookies to process information is explained in Section 10 of this policy.

4. Use of Information Collected

4.1 We collect and use your information for the following purposes:

• 4.1.1 To perform the services requested, for example, if you fill out the "Contact Form" Web form, we will use the information provided to contact you about your request. This data processing is necessary to provide or fulfill a service requested by or for you.
• 4.1.2 To perform marketing purposes, for example, we may use information you provide to contact you to further discuss your interest in the service and to send you information regarding the company such as our products, services, or events. This data processing is carried out for marketing purposes where permitted by law.
• 4.1.3 To operate and improve our Website, for example, we may analyse and process information for the purpose of improving the customer experience. Information collected may include your browser type and language, or the city or region or country from which you accessed the Website, as well as the ways you interact with the Website, such as pages visited, time spent on pages, the number of clicks and the domain names. We may use third-party analytic providers and technologies, including cookies and similar tools, to assist. We process this information to improve the Leading Edge Associates Website and our customers' experience, where permitted by law.
• 4.1.4 For payment purposes, for example, to collect payment from you where applicable. This data processing is necessary to provide or fulfil a service requested by or for you.

5. Data Retention

5.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) years afterwards or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.

5.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Consent

6.1 Where required by law, we will obtain your consent to collect, use, or disclose your personal information. In other cases, we may process personal information where permitted by law, including to provide services, manage our relationship with you, or meet legal and operational requirements.

6.2 You may withdraw consent where applicable, subject to legal or contractual restrictions and reasonable notice.

6.3 Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

7. Privacy Principles

7.1 Leading Edge Associates is committed to protecting personal information and adheres to generally accepted privacy principles, including accountability, identifying purposes, consent, limiting collection, limiting use and retention, accuracy, safeguards, openness, individual access, and compliance.

7.2 We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances and in accordance with applicable privacy laws.

7.3 We provide individuals with access to their personal information and the ability to request corrections, subject to legal and operational limitations.

8. Security of Your Personal Information

8.1 We take appropriate security measures against unlawful or unauthorised processing of personal information, and against the accidental loss of, or damage to, personal information.

8.2 We have put in place procedures and technologies to maintain the security of all personal information from the point of collection to the point of destruction. Personal information will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself. In addition, we have appropriate written agreements in place with all of our data processors.

8.3 We maintain data security by protecting the confidentiality, integrity and availability of the personal information, defined as follows:

• 8.3.1 Confidentiality means that only people who are authorised to use the data can access it.
• 8.3.2 Integrity means that personal information should be accurate and suitable for the purpose for which it is processed.
• 8.3.3 Availability means that authorised users should be able to access the data if they need it for authorised purposes.

8.4 We follow strict security procedures in the storage and disclosure of your personal information, and to protect it against accidental loss, destruction or damage. Leading Edge Associates uses third party vendors and hosting partners to provide the necessary hardware, software networking, storage, and related technology required to run. The information you provide to us is protected using appropriate technical and organizational safeguards.

9. Cross-border Processing of Personal Information

9.1 Personal information collected by Leading Edge Associates may be processed, stored, or accessed in jurisdictions outside the country in which it was collected, including through the use of third-party service providers and cloud-based platforms.

9.2 Where personal information is transferred across borders, Leading Edge Associates takes reasonable steps to ensure that such transfers are carried out in accordance with applicable data protection and privacy laws and that appropriate contractual, technical, and organizational safeguards are in place to protect the security and confidentiality of personal information. Service providers may be located in Canada, the United States, or other jurisdictions.

9.3 Individuals may contact us using the details set out in this policy to request further information regarding our approach to cross-border data processing.

10. Cookies and Website Analytics

10.1 We use cookies and similar technologies to operate our website, understand usage patterns, and improve functionality and user experience.

10.2 Cookies may collect technical information such as IP address, browser type, device information, pages visited, and referring URLs. This information is used in aggregate form and is not intended to identify individual users.

10.3 You may control cookie preferences through your browser settings. Disabling cookies may affect certain website features.

11. Will we share your information with anyone else?

11.1 We may disclose personal information to trusted third-party service providers to support our operations (for example, hosting, email, learning platforms, analytics, and marketing tools). We require all third parties to have appropriate technical and operational security measures in place to protect your personal information, in accordance with applicable privacy and data protection laws. Any such company or individual will have access to personal information needed to perform these functions but may not use it for any other purpose.

11.2 Specifically, we need to have written agreements in place with all of our data processors and, before we sign each agreement, we need to have vetted and be satisfied with the processor's data security. The agreements also need to contain specific clauses that deal with data protection.

11.3 We use the following categories of data processors in the course of our business:

• 11.3.1 Cloud Service Provider, Cloud-based Support Services, Cloud-based Email Notification Services, Marketing service providers

11.4 These categories may be updated from time to time and for an updated list of categories of data processors you should check this Privacy Policy on Leading Edge Associates's website.

11.5 We pass on your details if we are under a duty to disclose or share a data subject's personal information in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or personal information to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.

11.6 We need to demonstrate accountability for our data protection obligations. This means that we must be able to show how we comply with the data protection rules, and that we have in fact complied with the rules. We do this, among other ways, by our written policies and procedures, by building data protection compliance into our systems and business rules, by internally monitoring our data protection compliance and keeping it under review, and by taking action if our employees or contractors fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.

12. Marketing

12.1 We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. At the point at which you provide us with your personal information you will be asked whether you wish to receive any marketing communications from us.

12.2 We may use analytics tools as described in Section 10.

12.3 We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

12.4 We will not share your personal information with any third party for marketing purposes.

13. Sale of Business

13.1 Situations may arise where it is necessary to transfer information (including your personal information) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Privacy Policy and provided that the third party only uses your personal information for the purposes that you provided it to us. The personal information transferred will be limited to that which is absolutely necessary. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

14. Your Data Protection Rights

14.1 The rights described below apply to the extent provided under applicable privacy and data protection laws.

• 14.1.1 Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
• 14.1.2 Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• 14.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

15. Requests by Data Subjects to Exercise Their Rights

15.1 Leading Edge Associates has appointed a Privacy Contact to oversee compliance with applicable data protection and privacy laws and to respond to data subject inquiries.

15.2 Individuals may request access to, correction of, or deletion of their personal information, or otherwise exercise their data protection rights, by contacting our Privacy Contact. We will respond to such requests in accordance with applicable law.

15.3 Our Privacy Contact can be contacted as follows:

15.4 Data subjects also have the right to lodge a complaint with the applicable data protection or privacy authority in their jurisdiction.

For individuals in Canada, this is the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).

16. Changes to the Privacy Policy

16.1 Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal information in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.