Privacy Policy

01 Introduction

Robin Shaban and Ron Memmel (operating as 2R Strategy) are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, interact with us online, or engage our services.

This Policy complies with:

• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
• The EU General Data Protection Regulation (GDPR)
• The UK General Data Protection Regulation (UK GDPR)

By using this website, you agree to the practices described in this Policy.

02 Data Controller

The Data Controller is:

03 Information We Collect

3.1 Information You Provide Directly

We may collect personal information you voluntarily provide, such as:

• Name
• Email address
• Phone number
• Company or organization
• Information submitted through contact forms
• Information shared during consultations

3.2 Automatically Collected Information

We may automatically collect:

• IP address
• Browser type and version
• Device information
• Cookies and similar technologies
• Site usage details (pages viewed, time spent, referrers)

3.3 Cookies

We may use cookies for:

• Analytics
• Site functionality
• Preferences
• Security

You may disable cookies through your browser settings.

04 Legal Basis for Processing

For visitors from the EU/UK, we process personal data under the following lawful bases:

• Consent: When you opt in to receive communications or provide information voluntarily.
• Contract: When processing is necessary to provide requested services or respond to inquiries.
• Legitimate Interests: For analytics, website functionality, business operations, and service improvement.
• Legal Obligation: When compliance with applicable laws requires it.
• Vital Interests: In rare cases, to protect your or another person's safety.

05 How We Use Your Information

We use personal information to:

• Respond to inquiries or requests
• Provide advisory or consulting services
• Improve site performance and user experience
• Send updates or communications with your consent
• Maintain internal operations and analytics
• Comply with legal or regulatory obligations

We do not sell personal information.

06 How We Share Information

6.1 Service Providers

We may share data with trusted third parties (e.g., hosting providers, email services) who process data on our behalf under confidentiality and security obligations.

6.2 Legal or Regulatory Requirements

We may disclose information when required by law, regulatory authorities, or court orders.

6.3 Business Transactions

If we undergo a merger, acquisition, or restructuring, information may be transferred as permitted by law.

07 International Transfers (GDPR/UK GDPR)

Your personal information may be transferred to and processed in Canada or other jurisdictions that have different data protection laws from your home country.

For EU/UK visitors:

• Canada is recognized by the European Commission as providing adequate protection under PIPEDA.
• For transfers to third countries, we rely on safeguards such as:
  • Standard Contractual Clauses (SCCs)
  • Contractual necessity
  • Explicit consent

These measures ensure compliance with GDPR/UK GDPR requirements.

08 Data Retention

We retain personal information only as long as necessary for the purposes for which it was collected, or as required by law or professional obligations.

09 Your Rights

9.1 Under PIPEDA (Canada)

You may:

• Access your personal information
• Request correction
• Withdraw consent
• Challenge our data practices

9.2 GDPR/UK GDPR Rights

If you are located in the EU or UK, you have additional rights:

• Right of Access — request a copy of your data
• Right to Rectification — correct inaccurate data
• Right to Erasure ("Right to be Forgotten")
• Right to Restrict Processing
• Right to Data Portability
• Right to Object (including to legitimate interests)
• Right to Withdraw Consent at Any Time
• Right Not to Be Subject to Automated Decision-Making or Profiling (we do not use these)

To exercise these rights, contact us at: contact@2rstrategy.ca. You may also lodge a complaint with your local Data Protection Authority.

10 How We Protect Your Information

We use reasonable administrative, technical, and physical safeguards to protect your data from unauthorized access, alteration, or misuse. No method of electronic storage is completely secure; we cannot guarantee absolute security.

11 Third-Party Links

Our website may include links to other sites. We are not responsible for the privacy practices or content of those third parties.

12 Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect children's personal data. If this occurs, please contact us to remove the information.

13 Changes to This Privacy Policy

We may update this Policy periodically. Changes will be posted to this page with a new "Last updated" date.

14 Contact Us

For questions or privacy requests, please contact: