Privacy Policy
Effective Date: August 26, 2026
 
Last Updated: August 26, 2026
 
Gray HR Solutions (“we”, “us”, or “our”) operates the website GrayHRSolutions.ca (the “Website”) and provides human resources consulting, advisory, and talent management services (the “Services”).
 
We are committed to protecting the privacy, accuracy, and security of the personal information entrusted to us. This Privacy Policy outlines our practices regarding the collection, use, disclosure, and safeguarding of personal information in compliance with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
 
1. Scope of this Policy
This Privacy Policy applies to personal information collected by Gray HR Solutions through:
 

• Our Website (GrayHRSolutions.ca);

• Direct communications (email, phone, contact forms, discovery calls);

• Consultations, proposals, and service agreements with prospective and active clients.

 
This policy does not apply to third-party websites or services linked to or from our Website.
 
2. Personal Information We Collect
We collect only the personal information necessary to deliver our consulting services, operate our website, and communicate with you.
 
a. Information You Provide Directly

• Contact Details: Name, email address, phone number, job title, and company name when you fill out an inquiry form, request a consultation, or subscribe to communications.

• Business & Consulting Intake Information: General workforce details, policy inquiries, organizational challenges, or job specifications shared during preliminary inquiries or discovery sessions.

• Billing Information: Invoicing details, billing addresses, and payment confirmations necessary to process service fees.

 
b. Client & Employee Data (Service Engagements)
In the course of providing HR advisory services, clients may provide us with organizational data and employee-related information. We handle all such information under strict professional confidentiality agreements and data processing terms established in our individual client service agreements.
 
c. Automatically Collected Information (Website Usage)
When you visit GrayHRSolutions.ca, we may automatically collect standard technical information, including:
 

• IP address, browser type and version, operating system, device identifiers;

• Pages viewed, time spent on pages, referral source, and navigation paths;

• Cookies and similar tracking tools (see Section 8: Cookies & Tracking).
   

3. How We Use Your Information
We use collected information for legitimate business purposes, including:
 

• Service Delivery: Providing HR advisory, workplace assessments, documentation review, and talent consulting;

• Client Communications: Responding to inquiries, scheduling consultations, providing proposals, and sending administrative notices;

• Billing & Administration: Processing payments, managing accounts, and maintaining required financial records;

• Marketing & Insights: Sending newsletters, HR regulatory updates, or event invitations (only where express or implied consent exists under Canadian Anti-Spam Legislation / CASL);

• Website Optimization: Monitoring traffic trends, diagnosing technical issues, and enhancing user experience;

• Legal Compliance: Complying with applicable legal, regulatory, and tax obligations.

4. Consent
We collect, use, and disclose personal information only with your knowledge and consent, except where permitted or required by law.
 

• Express Consent: Obtained when you explicitly agree to data collection (e.g., ticking an opt-in box on a contact form or signing a service contract).

• Implied Consent: Inferred when you provide contact details specifically to request a quote, download a resource, or initiate an inquiry where the purpose is obvious.

 
You may withdraw your consent at any time, subject to legal or contractual restrictions, by contacting us.
 
5. Disclosure of Personal Information
We do not sell, rent, trade, or lease personal information to third parties. We may disclose personal information only in the following limited circumstances:
 

• Service Providers & Subprocessors: Trusted third-party vendors who perform services on our behalf (e.g., website hosting, CRM platforms, email delivery systems, cloud document storage, and accounting software). These providers are contractually bound to maintain strict confidentiality and data protection standards.

• Professional Advisors: Accountants, legal counsel, and insurers where necessary for compliance or risk management.

• Legal Requirements: When required or authorized by law, such as in response to a court order, regulatory audit, or valid legal inquiry.

• Business Transfers: In connection with a merger, reorganization, or sale of business assets, subject to standard confidentiality protections.

 
6. Data Storage and Cross-Border Transfers
Your personal information is primarily stored and processed within Canada. However, some of our service providers (e.g., cloud hosting, email systems) may maintain servers in other jurisdictions, including the United States.
 
Where information is transferred outside Canada, it is subject to the laws of that jurisdiction and may be accessible to foreign courts, law enforcement, and national security authorities under lawful orders.
 
7. Data Security & Retention
We maintain appropriate physical, organizational, and technological safeguards to protect personal information against unauthorized access, loss, theft, alteration, or disclosure. These measures include:
 

• SSL/TLS encryption for all website communications;

• Restricted access controls and multi-factor authentication for business systems;

• Secure document storage and regular system security updates;

• Confidentiality obligations for all internal personnel and contractors.

 
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, resolve disputes, and comply with legal, tax, and regulatory retention requirements.
 
8. Cookies and Tracking Technologies
GrayHRSolutions.ca uses cookies and similar technologies to ensure core website functionality and analyse aggregate visitor traffic.
 

• Essential Cookies: Necessary for the website to function properly.

• Analytics Cookies: Help us understand how visitors interact with the site so we can improve usability and content.

 
You can set your browser to refuse cookies or alert you when cookies are being sent. Note that certain features of the Website may not function optimally if cookies are disabled.
 
9. Your Rights and Access
Under Canadian privacy legislation, you have the right to:
 

• Request access to the personal information we hold about you;

• Request corrections to inaccurate, incomplete, or outdated personal information;

• Withdraw your consent to our continued collection, use, or disclosure of your data;

• Unsubscribe from marketing communications at any time using the "unsubscribe" link provided in our emails.

 
To exercise any of these rights, please submit a written request to our Privacy Officer. We will respond within 30 days as required by law.
 
10. Third-Party Links
Our Website may contain links to third-party websites (e.g., regulatory bodies, industry associations, partner platforms). We are not responsible for the privacy practices, policies, or content of third-party websites. We encourage you to read the privacy statements of any external site you visit.
 
11. Changes to this Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our operational practices, services, or legal obligations. When changes are made, the “Last Updated” date at the top of this page will be revised. We encourage you to review this policy periodically.