Privacy Policy

WhiteBox GiftWorks Inc. ("WhiteBox GiftWorks," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect, how we use and protect it, and the choices you have. We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

This Policy applies to information collected through our website at whiteboxgiftworks.ca and whiteboxgiftworks.com and related pages (the "Site"), and through your communications with us. Use of our TRYBE Relationship OS software platform by registered customers is also governed by the terms of your subscription agreement.

1. Who We Are

WhiteBox GiftWorks Inc. is a corporate gifting and relationship-intelligence company based in Winnipeg, Manitoba, Canada. We are the organization responsible for the personal information collected through the Site. You can reach our privacy contact using the details in the "Contact Us" section below.

2. Information We Collect

a) Information you provide to us

When you fill out our contact or callback form, request a quote, book a call, or otherwise communicate with us, we may collect:

• Your name;
• Your email address;
• Your phone number;
• Your company or organization (if provided);
• The contents of your message and any details you choose to share with us.

b) Information collected automatically

When you visit the Site, certain information may be collected automatically through cookies and similar technologies, including your IP address, browser type, device information, pages viewed, and the dates and times of your visits. Please see our Cookie Policy for more detail.

We do not knowingly collect sensitive personal information (such as government identifiers, financial account numbers, or health information) through the Site, and we ask that you do not submit such information through our forms.

3. How We Use Your Information

We use the personal information we collect to:

• Respond to your inquiries and callback requests, and arrange and conduct calls or meetings;
• Provide you with information, quotes, and proposals about our gifting services and software;
• Establish and manage our business relationship with you;
• Send you marketing communications where you have consented to receive them (see Section 6);
• Operate, maintain, secure, and improve the Site and our services;
• Detect, prevent, and respond to fraud, security incidents, and misuse; and
• Comply with our legal and regulatory obligations.

4. Consent

We collect, use, and disclose your personal information with your consent, except where otherwise permitted or required by law. By submitting information through our forms, you consent to our handling of that information as described in this Policy. Depending on the sensitivity of the information, your consent may be express or implied. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us — though doing so may limit our ability to provide certain services to you.

5. Cookies and Analytics

We use cookies and similar technologies to operate the Site, remember your preferences, and understand how the Site is used so we can improve it. You can control cookies through your browser settings. For full details, see our Cookie Policy.

6. Marketing Communications and CASL

Where permitted, we may send you marketing communications, such as newsletters, product updates, and promotional offers. We send these communications in accordance with Canada's Anti-Spam Legislation (CASL). This means we will obtain your consent (express or implied) before sending commercial electronic messages, we will clearly identify ourselves, and every marketing email will include an easy way to unsubscribe. You can opt out of marketing communications at any time by using the unsubscribe link in any email or by contacting us directly. We will honour opt-out requests promptly.

7. How We Share and Disclose Information

We do not sell your personal information. We may share it in the following limited circumstances:

• Service providers: We work with trusted third-party providers who perform services on our behalf — for example, website hosting, database services, form processing, email delivery, and analytics. These providers may only use your information to provide services to us and are required to protect it.
• Legal and safety reasons: We may disclose information where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of WhiteBox GiftWorks, our customers, or others.
• Business transfers: If we are involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to appropriate confidentiality protections.

8. Service Providers and Data Storage

Our Site and database services are hosted with reputable providers. We use Supabase (database and authentication) with data stored in a Canadian region, and Vercel for website hosting. Some of our service providers may store or process information outside of Manitoba or Canada, including in the United States. Where information is processed outside Canada, it may be subject to the laws of the jurisdiction in which it is held, including lawful access by courts and authorities in that jurisdiction. We take reasonable steps to ensure our providers maintain appropriate safeguards.

9. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, to maintain our business relationship with you, and to comply with our legal, accounting, and reporting obligations. When personal information is no longer required, we take reasonable steps to securely delete or anonymize it.

10. Safeguards and Security

We use reasonable administrative, technical, and physical safeguards to protect personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. These include access controls, encryption in transit, and database-level security rules. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Withdraw your consent to our use of your information (subject to legal and contractual limits);
• Ask questions about, or challenge our compliance with, this Policy.

To exercise any of these rights, please contact us using the details below. We may need to verify your identity before responding. We will respond within the timeframes required by applicable law.

12. Children's Privacy

The Site is intended for businesses and individuals who are the age of majority in their province or territory. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

13. Third-Party Links

The Site may contain links to third-party websites and services that we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we make changes, we will revise the "Last updated" date at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Site after changes take effect constitutes acceptance of the updated Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our Privacy Officer:

If you are not satisfied with our response to a privacy concern, you have the right to contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.