Privacy Policy for millertrades.ca

Last Updated: May 12, 2025

Alex Miller, operating as Miller Trades (“Miller Trades”, “We”, “Us”, “Our”), is committed to protecting the privacy of individuals who visit millertrades.ca (the “Website”) and use Our web hosting, domain name registration/management, and online directory services (collectively, the “Services”). This Privacy Policy outlines how We collect, use, disclose, and safeguard Your personal information in compliance with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and applicable provincial legislation.

Please read this Privacy Policy carefully. By using Our Website or Services, you consent to the data practices described in this policy.

1. Information We Collect We collect personal information that You voluntarily provide to Us when You register for Services, make an inquiry, or interact with Our Website, and information that is automatically collected when You use Our Website or Services.

  • Personal Information You Provide:
  • Contact Information: Your name, email address, phone number, mailing address when You contact Us, create an account, or register for Our Services.
  • Account & Billing Information: Usernames, passwords, payment information (e.g., credit card details, which are typically processed by Our secure third-party payment processors), and billing address for Clients using Our paid Services.
  • Domain Registration Information (WHOIS Data): For domain registrations, We collect registrant, administrative, technical, and billing contact information as required by domain registration policies (e.g., ICANN). Some of this information may be made publicly available via WHOIS lookups unless a WHOIS privacy service is used.
  • Directory Listing Information: Business name, contact person, address, phone number, email, website, business description, images, and other details You submit for inclusion in Our online Directory. Certain elements of this information will be publicly displayed as part of the Directory.
  • Client Content (Hosting): Data, files, emails, databases, and other content that You upload or create on Your hosting account (“Client Content”). Our access to Client Content is strictly limited and governed by Our Hosting Agreement and this Privacy Policy.
  • Communications: Records of Your correspondence with Us, including emails, chat logs, and support tickets.
  • Information Automatically Collected (Usage Data):
  • Log and Device Information: IP address, browser type, operating system, device type, access times, pages viewed, referring website addresses, and server logs related to Your hosting account usage.
  • Cookies and Tracking Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about Your Browse behavior, preferences, and to enhance Website and Service functionality. You can control the use of cookies at the individual browser level.

2. How We Use Your Information We use the personal information We collect for the following purposes:

  • To provide, operate, maintain, and improve Our Website and Services.
  • To create and manage Your account, process Your domain registrations, provide hosting services, process transactions, and send You related information, including confirmations and invoices.
  • To manage and display listings in Our online Directory.
  • To respond to Your comments, questions, and requests, and provide customer service and support.
  • To send You technical notices, updates, security alerts, and administrative messages.
  • To communicate with You about products, services, offers, promotions, and events offered by Us, and provide news and information We think will be of interest to You (in compliance with CASL, where applicable, including providing unsubscribe mechanisms).
  • To monitor and analyze trends, usage, and activities in connection with Our Website and Services.
  • To detect, investigate, and prevent fraudulent transactions, unauthorized access to Services, and other illegal activities, and protect Our rights and property and that of others.
  • To comply with applicable legal and regulatory obligations, including ICANN policies for domain registrations.

3. Consent We obtain Your consent to collect, use, or disclose Your personal information, except where authorized or required by law (e.g., for domain WHOIS information as required by ICANN). Consent can be express or implied. You may withdraw Your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may affect Our ability to provide You with certain Services (e.g., domain registration if required WHOIS data is withheld).

4. Cookies and Tracking Technologies

  • We use cookies to improve user experience, analyze site usage, and for essential Service functionality.
  • You can manage Your cookie preferences through Your browser settings. Rejecting certain cookies may impact the functionality of Our Website or Services. We will seek appropriate consent for non-essential cookies as required by law.

5. Sharing and Disclosure of Your Information We do not sell or rent Your personal information to third parties. We may disclose Your personal information in the following circumstances:

  • Domain Registrars & Authorities: For domain registrations, We must share Your WHOIS information with the applicable domain registrars and authorities (e.g., ICANN, CIRA) as required by their policies. This information may be publicly accessible via WHOIS lookups unless a privacy service is utilized.
  • Service Providers: To third-party vendors, consultants, and other service providers who need access to such information to carry out work on Our behalf (e.g., payment processors, domain registrars, data center operators, email service providers, analytics providers). These providers are contractually obligated to protect Your information.
  • Publicly Available Information: Information You submit for Our online Directory, or public portions of Your WHOIS data, will be publicly accessible.
  • Legal Requirements & Harm Prevention: If required by law or if We believe in good faith that disclosure is necessary to comply with a legal obligation, protect Our rights or property, prevent fraud or abuse, or protect the safety of Our users or the public.
  • Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of Our business.
  • With Your Consent: For any other purpose disclosed to You at the time We collect Your information or pursuant to Your consent.

6. Data Security and Client Content (Hosting)

  • We implement reasonable administrative, technical, and physical security measures designed to protect Your personal information and Client Content from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.
  • While We provide tools and infrastructure for hosting, You are primarily responsible for the security of Your Client Content, including implementing strong passwords, keeping software updated, and maintaining appropriate backups.
  • Our access to Your Client Content is limited to what is necessary to provide the hosting Services, for troubleshooting, or as required by law.

7. Data Retention We will retain Your personal information and Client Content for as long as necessary to fulfill the purposes for which it was collected, to provide Our Services, to comply with Our legal obligations (e.g., financial record-keeping, domain registration data), resolve disputes, and enforce Our agreements. Specific retention periods for Client Content on hosting servers may be outlined in Our Hosting Agreement or AUP.

8. International Data Transfers Your information, including personal data and Client Content, may be transferred to — and maintained on — computers and servers located outside of Your province or country where the data protection laws may differ. Our primary data centers may be in Canada or the USA. By using Our Services, You consent to this transfer, processing, and storage of Your information in these locations.

9. Your Privacy Rights (Access, Correction, Withdrawal of Consent) You have the right to:

  • Access the personal information We hold about You.
  • Request correction of any inaccurate personal information.
  • Withdraw Your consent to Our collection, use, or disclosure of Your personal information at any time, subject to legal or contractual restrictions (e.g., ICANN requirements for domain data). To exercise these rights, please contact Our Privacy Officer using the details below.

10. Children’s Privacy Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

11. Changes to This Privacy Policy We may update this Privacy Policy from time to time. We will notify You of any significant changes by posting the new Privacy Policy on this page and updating the “Last Updated” date, and/or by sending You an email or other notification.

12. Contact Us / Privacy Officer If you have any questions, concerns, or complaints about this Privacy Policy, Our data practices, or if You wish to exercise Your privacy rights, please contact Our Privacy Officer: Privacy Officer Miller Trades (c/o Alex Miller) admin@millertrades.ca

If You are not satisfied with Our response, You have the right to contact the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario.

Key Areas for Legal Review Specific to millertrades.ca (Hosting/Domain/Directory Version):

  • Accuracy of Business Details: Ensure your legal business name and contact details are correct.
  • Relationship with Domain Registrars: Clearly define your role as a reseller and point to the primary registrar’s policies. Detail how WHOIS privacy services work if you offer them.
  • Acceptable Use Policy (AUP) for Hosting: This is critical and should be a detailed, separate document incorporated by reference. It should cover prohibited content/activities, resource abuse, security obligations, email usage, etc.
  • Service Level Agreements (SLAs): If you offer uptime guarantees or specific support response times, these need to be clearly defined.
  • Backup Policies for Hosting: Clearly state who is responsible for backups (client or you), frequency, retention, and any fees for restoration.
  • Data Security Measures for Hosting: Provide more detail on the types of security measures you implement for your servers.
  • Specifics of Directory Listings: Moderation process, reasons for rejection/removal, dispute handling.
  • CASL Compliance: For all commercial electronic messages (CEMs), including newsletters, promotional offers, and even some transactional messages.
  • Payment Processor Integration: How data is shared and secured with your payment gateway.
  • Data Breach Notification Plan: While not in the policy itself, you need an internal plan and to understand your legal obligations for notification.