JS Digital Incorporated

Effective Date: August 11, 2026
Last Updated: August 11, 2026

1. INTRODUCTION

JS Digital Incorporated (“JS Digital”, “we”, “us”, or “our”) respects the privacy of our clients, prospective clients, website visitors, business partners, contractors, users, and other individuals whose personal information we handle.

This Privacy Policy explains how JS Digital collects, uses, stores, processes, protects, transfers, and discloses personal information in connection with our website, services, business operations, communications, software development activities, consulting engagements, cloud and data services, artificial intelligence services, automation services, technical support, and other professional services.

This Privacy Policy applies to information processed through our website at jsdigital.ca and through our interactions with clients and other individuals.

Our privacy practices are designed to comply with applicable Canadian privacy legislation, including the British Columbia Personal Information Protection Act (“BC PIPA”) and, where applicable, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Where services are provided to individuals in other jurisdictions, additional privacy laws may apply.

This Policy should be read together with our Terms of Service, applicable service agreements, statements of work, data processing agreements, and other contractual terms.

2. WHO WE ARE

JS Digital Incorporated is a Canadian information technology consulting and software services company.

Our services may include:

custom software development;
web and mobile application development;
application programming interfaces and integrations;
cloud architecture and cloud services;
data engineering and database services;
artificial intelligence services;
workflow automation;
systems integration;
IT consulting;
technical support;
software maintenance;
infrastructure management;
security hardening;
monitoring and optimization;
performance optimization; and
related technology services.

For privacy questions or requests, contact:

JS Digital Incorporated
Nanaimo, British Columbia, Canada

Email: info@jsdigital.ca

Telephone: 250-797-4649

Privacy inquiries should include “Privacy Request” in the subject line where possible.

3. OUR ROLE WHEN PROCESSING INFORMATION

Depending on the circumstances, JS Digital may act either as an organization responsible for determining how personal information is handled, or as a service provider processing information on behalf of a client.

3.1 Information We Control

JS Digital generally determines the purposes for processing information relating to:

website visitors;
prospective clients;
enquiries;
consultation requests;
business contacts;
vendors;
contractors;
billing contacts;
marketing subscribers; and
individuals communicating directly with JS Digital.

3.2 Information Processed for Clients

During software development, cloud, integration, automation, data, AI, maintenance or technical-support engagements, JS Digital may receive access to information controlled by a client.

In these circumstances, JS Digital may process the information primarily on the client’s instructions and subject to the applicable agreement.

Requests concerning information controlled by one of our clients may need to be directed to that client.

4. WHAT IS PERSONAL INFORMATION?

Personal information generally means information about an identifiable individual.

Depending on applicable law, this may include:

name;
address;
email address;
telephone number;
online identifiers;
IP address;
account identifiers;
billing information;
employment information;
device information;
communications;
usage information; and
other information that identifies or can reasonably be associated with an individual.

Information that has been irreversibly anonymized so that an individual cannot reasonably be identified may not constitute personal information under applicable law.

5. INFORMATION WE COLLECT

The information collected depends upon how you interact with JS Digital.

5.1 Information You Provide Directly

We may collect information that you voluntarily provide, including:

first and last name;
business name;
job title;
email address;
telephone number;
mailing or business address;
project information;
service requirements;
consultation requests;
quote requests;
messages;
support requests;
feedback;
correspondence;
documents;
files;
technical information;
account information;
billing information; and
other information you choose to provide.

Please avoid submitting sensitive personal information through general website contact forms unless it is reasonably necessary.

6. WEBSITE ENQUIRIES AND CONSULTATION REQUESTS

When you submit an enquiry, request a quote, request a consultation or otherwise contact us through our website, we may collect information including your:

name;
email address;
telephone number;
organization;
requested service;
project description;
message; and
other information included in your submission.

We use this information to respond to you, assess your requirements, prepare proposals or quotations, establish a business relationship and maintain records relating to the interaction.

7. CLIENT AND PROJECT INFORMATION

When providing professional services, we may receive information relating to a client’s business, employees, contractors, customers or systems.

Depending upon the engagement, this may include:

user account information;
application data;
databases;
API data;
system logs;
configuration files;
source code;
infrastructure information;
technical credentials;
customer records;
support tickets;
transaction information;
analytics data;
documents;
files; and
other information necessary to perform contracted services.

We seek to access only the information reasonably required to perform the applicable services.

Additional contractual protections may apply through a master services agreement, statement of work, confidentiality agreement, data processing agreement or similar agreement.

8. PAYMENT AND BILLING INFORMATION

If you purchase services from JS Digital, we may collect information required for invoicing, accounting and payment administration.

This may include:

billing name;
business name;
billing address;
invoice information;
transaction references;
tax information;
payment status; and
payment-related correspondence.

Where payments are processed through a third-party payment processor, payment card or banking information may be provided directly to that processor rather than stored by JS Digital.

We do not intentionally collect or store complete payment card information unless necessary and appropriate security controls are implemented.

9. INFORMATION COLLECTED AUTOMATICALLY

When you access our website or online services, certain technical information may be collected automatically.

This may include:

IP address;
browser type;
browser version;
device type;
operating system;
referring URL;
pages viewed;
links clicked;
approximate geographic region derived from IP address;
timestamps;
session information;
website performance information;
error information;
security events; and
diagnostic information.

This information may be collected through server logs, cookies, pixels, scripts, analytics technologies or similar technologies.

10. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small files or identifiers stored on or associated with your device.

JS Digital may use cookies and similar technologies for purposes including:

operating the website;
maintaining security;
preventing abuse;
remembering preferences;
understanding website performance;
measuring traffic;
diagnosing technical issues;
improving usability; and
understanding how visitors interact with our website.

Cookies may be classified as:

Strictly Necessary Cookies

These support functions necessary for website operation, security, forms and network management.

Functional Cookies

These remember preferences and provide enhanced website functionality.

Analytics Cookies

These help us understand website traffic, performance and usage patterns.

Advertising or Marketing Cookies

If JS Digital implements advertising, remarketing or similar technology, such cookies may be used to measure advertising effectiveness or provide relevant advertising.

Where applicable law requires consent before non-essential cookies are placed, JS Digital will seek the appropriate consent.

Users may also control cookies through browser settings and, where available, our cookie-management interface.

Blocking certain cookies may affect website functionality.

11. ANALYTICS

We may use analytics services to understand how visitors interact with our website.

Analytics providers may receive information such as IP addresses, device information, browser information, referring pages, pages visited, approximate location and interaction information.

Where required, analytics technologies will be activated only after appropriate consent.

We seek to configure analytics services using privacy-conscious settings where reasonably practical.

12. ARTIFICIAL INTELLIGENCE SERVICES

Because JS Digital provides artificial intelligence and automation services, certain projects may involve AI technologies.

Depending on the engagement, information may be processed using machine-learning models, large language models, AI APIs, automation platforms or other computational systems.

Where client information is processed using third-party AI services, the handling of such information may also be subject to contractual restrictions, provider terms, security controls and the client’s instructions.

JS Digital does not intend to submit confidential client information, personal information or sensitive information to public AI systems for unrestricted model training unless such processing is specifically authorized and legally permitted.

Where AI processing involves personal information, we seek to apply principles of:

data minimization;
purpose limitation;
access control;
confidentiality;
appropriate vendor assessment;
human oversight where appropriate; and
security proportionate to the sensitivity of the information.

Specific AI projects may be governed by additional contractual terms.

13. SOURCE CODE AND DEVELOPMENT DATA

Software development engagements may require JS Digital personnel or approved service providers to access:

source code;
repositories;
development environments;
test data;
staging environments;
deployment systems;
API credentials;
databases;
cloud infrastructure; and
development tools.

We seek to minimize the use of production personal information in development and testing environments.

Where reasonably possible, test, synthetic, anonymized or pseudonymized information should be used instead of production personal information.

14. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

operate our website;
respond to enquiries;
schedule consultations;
prepare proposals;
provide quotations;
establish client relationships;
perform contracts;
provide software and consulting services;
provide technical support;
develop and maintain software;
configure systems;
manage cloud infrastructure;
perform integrations;
provide AI and automation services;
troubleshoot problems;
communicate with clients;
administer accounts;
process billing;
maintain accounting records;
manage vendors;
improve our services;
perform analytics;
maintain security;
prevent fraud and abuse;
enforce contracts;
establish, exercise or defend legal claims;
comply with legal requirements; and
carry out other purposes disclosed when information is collected.

We will not use personal information for materially different purposes without appropriate authority, notice or consent where required.

15. CONSENT

Where consent is required, we seek consent appropriate to the nature and sensitivity of the information and the reasonable expectations of the individual.

Consent may be express or implied where permitted by applicable law.

We may seek express consent when:

sensitive information is involved;
processing falls outside reasonable expectations;
information is being used for a materially new purpose; or
applicable law otherwise requires express consent.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent may prevent us from providing services that reasonably require the affected information.

16. OTHER LEGAL GROUNDS FOR PROCESSING

Where laws such as the GDPR or UK GDPR apply, JS Digital may rely upon one or more legal grounds for processing, including:

Consent

You have consented to specified processing.

Contract

Processing is necessary to enter into or perform a contract with you.

Legal Obligation

Processing is necessary to comply with applicable legal obligations.

Legitimate Interests

Processing is necessary for legitimate business interests, provided those interests are not overridden by applicable privacy rights.

Legitimate interests may include:

operating our business;
maintaining network and information security;
preventing fraud;
improving services;
responding to business enquiries;
maintaining business relationships; and
protecting legal rights.

Other lawful grounds may apply where permitted by law.

17. LIMITING COLLECTION

We seek to collect only information reasonably necessary for legitimate and identified business purposes.

Employees, contractors and service providers should not collect personal information merely because it may potentially be useful in the future.

18. HOW WE DISCLOSE INFORMATION

We do not disclose personal information indiscriminately.

Information may be disclosed to:

employees;
contractors;
consultants;
professional advisers;
hosting providers;
cloud providers;
software vendors;
analytics providers;
communications providers;
payment processors;
accounting providers;
security providers;
infrastructure providers;
AI service providers;
development platforms;
government authorities; and
other parties where reasonably necessary and legally permitted.

Access should be limited to information reasonably required for the recipient’s function.

19. SERVICE PROVIDERS

We may engage third-party service providers to perform functions on our behalf.

Depending upon our technology stack and client requirements, these providers may support:

website hosting;
cloud computing;
database hosting;
email delivery;
customer communications;
analytics;
cybersecurity;
source-code management;
project management;
payments;
accounting;
monitoring;
backups;
AI processing;
infrastructure;
file storage; and
collaboration.

Service providers may process information only as necessary to perform their services, subject to applicable agreements and legal obligations.

The specific providers used may change as our infrastructure and services evolve.

20. CLIENT-DIRECTED INTEGRATIONS

Some projects integrate client systems with third-party services.

Examples may include:

accounting systems;
payment providers;
CRM platforms;
cloud services;
identity providers;
email services;
analytics services;
business automation tools; and
AI providers.

Where a client directs JS Digital to integrate with a third-party service, the client’s relationship with that third party may be governed by that provider’s own terms and privacy practices.

21. INTERNATIONAL AND CROSS-BORDER PROCESSING

JS Digital is based in Canada.

However, some service providers, cloud infrastructure or systems used by JS Digital or its clients may process or store information outside British Columbia or Canada.

As a result, personal information may be processed in jurisdictions including Canada, the United States or other countries.

Information stored or processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or governmental authorities where legally authorized.

Where required by applicable law, JS Digital will use appropriate contractual, organizational or technical safeguards for international transfers.

22. DATA SECURITY

JS Digital takes reasonable administrative, technical and physical measures designed to protect personal information against:

unauthorized access;
unauthorized disclosure;
misuse;
loss;
alteration;
destruction;
theft; and
other security threats.

Depending on the nature of the information and system, safeguards may include:

encryption in transit;
encryption at rest where appropriate;
access controls;
role-based permissions;
multi-factor authentication;
secure credential management;
network controls;
system monitoring;
logging;
backups;
vulnerability management;
patch management;
secure software development practices;
least-privilege access;
environment separation;
incident-response procedures; and
employee or contractor confidentiality requirements.

No system connected to the Internet can be guaranteed to be completely secure.

Accordingly, while we take reasonable precautions, JS Digital cannot guarantee absolute security.

23. PASSWORDS, API KEYS AND CREDENTIALS

Where JS Digital receives credentials necessary to perform services, we seek to handle them using appropriate security practices.

Clients should use secure methods when sharing:

passwords;
API keys;
private keys;
database credentials;
cloud credentials;
access tokens; and
other secrets.

Credentials should not be transmitted through unsecured communication channels where secure alternatives are available.

Access credentials should be rotated or revoked when no longer required.

24. DATA BREACHES AND SECURITY INCIDENTS

JS Digital maintains procedures intended to identify, investigate and respond to suspected privacy and security incidents.

Where an incident involving personal information occurs, we will assess:

the nature of the information;
the circumstances of the incident;
potential consequences;
likelihood of misuse;
individuals affected;
containment requirements; and
applicable notification obligations.

Where required by applicable law, JS Digital will notify affected individuals, clients, regulators or other appropriate parties.

Where JS Digital processes information on behalf of a client, we will seek to notify the client in accordance with applicable contractual and legal obligations.

25. DATA RETENTION

We retain personal information only for as long as reasonably necessary for:

the purpose for which it was collected;
providing services;
maintaining business records;
resolving disputes;
enforcing agreements;
meeting tax and accounting obligations;
security;
regulatory requirements; and
applicable limitation periods.

Different categories of information may have different retention periods.

When information is no longer reasonably required, we may securely delete, destroy or anonymize it, subject to legal, contractual, backup and technical requirements.

Information stored in backups may remain until the applicable backup cycle expires.

26. MARKETING COMMUNICATIONS AND CASL

JS Digital may send commercial electronic communications where permitted by law.

For Canadian recipients, we seek to comply with Canada’s Anti-Spam Legislation (“CASL”).

Where required, commercial electronic messages will:

be sent with appropriate consent or other lawful authority;
identify JS Digital or the applicable sender;
provide required contact information; and
contain an effective unsubscribe mechanism.

You may unsubscribe from marketing communications using the unsubscribe mechanism contained in the communication or by contacting us.

Transactional, security, service, billing and other non-marketing communications may continue where necessary.

27. DO NOT SELL OR RENT PERSONAL INFORMATION

JS Digital does not operate as a data broker.

We do not intend to sell personal information to third parties for monetary consideration.

If our practices materially change, this Privacy Policy and any legally required choices will be updated before such practices are implemented.

Certain privacy laws define “sale” or “sharing” more broadly than an exchange for money. Where such laws apply, JS Digital will provide legally required rights and opt-out mechanisms.

28. PRIVACY RIGHTS

Depending upon where you reside and the applicable law, you may have rights concerning your personal information.

These may include the right to:

request access to personal information;
obtain information concerning its use;
request correction;
challenge the accuracy of information;
withdraw consent;
request deletion where applicable;
request restriction of processing where applicable;
object to certain processing where applicable;
receive portable information where applicable;
opt out of certain marketing;
opt out of certain targeted advertising, sale or sharing where applicable; and
complain to an appropriate privacy regulator.

These rights are not absolute and may be subject to exceptions.

29. ACCESS REQUESTS

You may request access to personal information that JS Digital holds about you.

Requests should be submitted to:

info@jsdigital.ca

Please use the subject:

Privacy Request

We may request information reasonably necessary to verify your identity before responding.

We will respond within the timeframe required by applicable law.

Certain information may be withheld where permitted or required by law, including information that would reveal personal information about another individual, legally privileged information or information subject to another lawful restriction.

30. CORRECTION REQUESTS

If you believe information we hold about you is inaccurate or incomplete, you may request correction.

Where appropriate, we will correct the information or annotate the record as required by applicable law.

31. DELETION REQUESTS

Where applicable law provides a deletion right, you may request deletion of eligible personal information.

We may retain information where necessary to:

comply with legal obligations;
perform contractual obligations;
maintain required financial records;
establish or defend legal claims;
protect security;
prevent fraud;
complete transactions; or
exercise other rights permitted by law.

32. EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

Where the GDPR or UK GDPR applies, individuals may have additional rights including:

access;
rectification;
erasure;
restriction;
objection;
data portability;
withdrawal of consent; and
the right to lodge a complaint with an appropriate supervisory authority.

Where processing is based on consent, withdrawal of consent does not affect processing lawfully performed before withdrawal.

Where processing is based on legitimate interests, individuals may have the right to object in accordance with applicable law.

33. CALIFORNIA AND OTHER UNITED STATES PRIVACY LAWS

If JS Digital becomes subject to a United States state privacy law applicable to a particular individual, that individual will receive the rights required by that law.

Depending upon the jurisdiction and applicable thresholds, these rights may include:

confirmation of processing;
access;
correction;
deletion;
data portability;
opt-out of sale;
opt-out of targeted advertising;
opt-out of certain profiling;
limitation concerning sensitive information; and
freedom from unlawful discrimination for exercising privacy rights.

Nothing in this section represents that a particular US privacy statute necessarily applies to JS Digital when statutory applicability thresholds have not been met.

34. CHILDREN

JS Digital’s website and professional services are primarily directed toward businesses and adults.

We do not knowingly seek to collect personal information from children through the general JS Digital website.

If we discover that personal information concerning a child has been collected without appropriate authorization where such authorization is legally required, we will take reasonable steps to address the information.

Parents or guardians who believe a child has submitted personal information may contact us.

35. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites, services or platforms.

JS Digital does not control the privacy practices of independent third parties.

This Privacy Policy does not govern information collected directly by third parties.

We recommend reviewing the privacy policies of external websites and services before providing personal information.

36. SOCIAL MEDIA

JS Digital may maintain profiles on third-party social networks and professional platforms.

Information you provide through those platforms may be processed by both JS Digital and the platform provider.

Your use of those platforms is also governed by their respective privacy policies and terms.

37. BUSINESS TRANSFERS

If JS Digital undergoes a merger, acquisition, financing, restructuring, sale of assets or similar corporate transaction, information may be disclosed to potential or actual parties to the transaction where legally permitted.

Appropriate confidentiality and privacy safeguards will be used where required.

38. LEGAL DISCLOSURES

We may disclose information where we reasonably believe disclosure is necessary to:

comply with applicable law;
comply with a court order;
respond to lawful governmental requests;
comply with legal process;
investigate fraud;
address cybersecurity threats;
protect our legal rights;
protect individuals from harm;
enforce contractual rights; or
establish, exercise or defend legal claims.

We will seek to limit disclosures to information reasonably necessary under the circumstances.

39. AGGREGATED, DE-IDENTIFIED AND ANONYMIZED INFORMATION

Where permitted by law, we may create aggregated, de-identified or anonymized information from information in our possession.

We may use such information for:

statistical analysis;
security analysis;
service improvement;
performance measurement;
capacity planning;
research; and
business analysis.

We will not intentionally attempt to re-identify properly anonymized information except where legally permitted for security, validation or other legitimate purposes.

40. AUTOMATED DECISION-MAKING

The general JS Digital website does not currently rely upon solely automated decision-making that produces legal or similarly significant effects concerning website visitors.

Some client projects may involve automated systems or artificial intelligence.

In those circumstances, responsibility for the system, applicable disclosures and decision-making framework will depend upon the specific engagement and the roles of JS Digital and the client.

41. PRIVACY BY DESIGN

Where reasonably practical, JS Digital incorporates privacy and security considerations into the design and delivery of systems.

Depending upon the project, this may include:

collecting less personal information;
limiting permissions;
separating environments;
using secure defaults;
encrypting sensitive information;
pseudonymizing information;
anonymizing information;
establishing retention rules;
controlling administrative access;
maintaining audit logs; and
evaluating privacy risks before implementing significant processing activities.

42. CLIENT RESPONSIBILITIES

Clients remain responsible for ensuring that personal information they provide to JS Digital, or instruct JS Digital to process, has been collected and disclosed lawfully.

Unless otherwise agreed, clients are responsible for:

providing required privacy notices;
obtaining necessary consent;
establishing lawful authority for processing;
determining appropriate retention requirements;
responding to individuals whose information they control; and
ensuring their instructions comply with applicable law.

JS Digital reserves the right to decline instructions that we reasonably believe would require unlawful processing.

43. EMPLOYEE AND CONTRACTOR ACCESS

Access to personal information should be limited to personnel who reasonably require the information to perform their duties.

Personnel may be subject to:

confidentiality obligations;
access restrictions;
security requirements;
acceptable-use requirements; and
privacy and security procedures.

Access may be removed when no longer necessary.

44. SECURITY TESTING AND LOGGING

JS Digital may maintain logs and security information necessary to protect systems and investigate incidents.

Security information may include:

authentication events;
IP addresses;
administrative actions;
access events;
system errors;
API activity;
security alerts; and
infrastructure events.

Such information may be retained for security, troubleshooting, audit and compliance purposes.

45. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect:

changes in law;
changes in services;
changes in technology;
changes in service providers;
changes in business operations; or
changes in privacy practices.

The “Last Updated” date will indicate when the Policy was most recently revised.

Where a material change requires additional notice or consent under applicable law, we will provide such notice or obtain such consent as required.

Continued use of our website does not constitute consent to practices for which applicable law specifically requires separate consent.

46. QUESTIONS AND COMPLAINTS

Questions, concerns or complaints regarding this Privacy Policy or JS Digital’s handling of personal information may be directed to:

Privacy Officer
JS Digital Incorporated
Nanaimo, British Columbia, Canada

Email: info@jsdigital.ca

Telephone: 250-797-4649

Subject: Privacy Request

We will investigate privacy complaints and respond within a reasonable period and within any period required by applicable law.

If a concern cannot be resolved directly with JS Digital, individuals may have the right to contact the privacy regulator having jurisdiction over the matter.

47. GOVERNING PRIVACY FRAMEWORK

JS Digital’s privacy practices are principally designed around applicable Canadian private-sector privacy requirements, including British Columbia’s Personal Information Protection Act and, where applicable, Canada’s Personal Information Protection and Electronic Documents Act.

Other privacy and data protection legislation may apply depending upon:

the individual’s location;
the nature of the transaction;
where information is processed;
the services involved; and
JS Digital’s role in the processing activity.

Where another applicable privacy law imposes requirements that conflict with or exceed this Policy, JS Digital will comply with the applicable legal requirement.

48. CONTACT INFORMATION

For questions regarding privacy, personal information, security or this Privacy Policy:

JS Digital Incorporated
Nanaimo, British Columbia
Canada

Email: info@jsdigital.ca
Telephone: 250-797-4649
Website: jsdigital.ca

Privacy Contact: Privacy Officer, JS Digital Incorporated

Effective Date: April 11, 2025
Last Updated: August 11, 2026