Privacy Policy

1. Data Controller and Operator

This website is operated by Brass & Broom, a debt management consultancy based in Halifax, Nova Scotia. In the context of the Personal Information Protection and Electronic Documents Act (PIPEDA), Brass & Broom acts as the organization responsible for the collection, use, and disclosure of your personal information.

Our commitment is to transparency regarding the financial strategies we provide, including credit card debt reduction and interest rate optimization models.

2. Applicable Legal Framework

As we operate out of Halifax, Nova Scotia, we comply primarily with the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada. Additionally, we adhere to the Personal Information International Disclosure Protection Act (PIIDPA) relevant to Nova Scotia public sector entities, though as a private entity, PIPEDA remains our primary governing statute.

For our international visitors, we strive to maintain high standards consistent with the General Data Protection Regulation (GDPR) for EU residents and CCPA for California residents, ensuring a global standard of data integrity.

3. Nature of Data Collection

We collect information that helps us provide tailored debt management strategies. This includes:

• Identity Data: Name and title provided through contact forms.
• Contact Data: Email address and telephone number.
• Financial Profile Data: Voluntary information regarding credit card balances, interest rates, and debt-to-income ratios submitted for analysis.
• Technical Data: IP address, browser type, time zone setting, and location data (Halifax-specific or global).
• Usage Data: Information about how you use our compounding interest models and financial literacy resources.

6. Data Retention Policy

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Typically, contact information for debt analysis inquiries is retained for 24 months following the last interaction, unless a longer period is required by Canadian tax or financial record-keeping laws.

7. Third-Party Disclosure and Transfers

We do not sell your personal data. We may share data with trusted service providers who assist in our operations (e.g., hosting providers, analytical tools). These parties are contractually obligated to protect your data.

In the event of a cross-border transfer (e.g., data stored on cloud servers located in the USA), your data remains protected under our strict security protocols and remains subject to the laws of that jurisdiction.

8. Your Privacy Rights

Under Canadian law, you have significant rights regarding your information:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right of Correction: You can request that we rectify inaccurate or incomplete information.
• Right to Withdraw Consent: You may withdraw your consent for data processing at any time, subject to legal or contractual restrictions.
• Right to Complain: You have the right to contact the Office of the Privacy Commissioner of Canada (OPC) if you believe your rights have been violated.