Kurtz Orchards Privacy Policy

Last Updated: April 22, 2025

1. Introduction & Scope

At Kurtz Orchards (“the Company”), we understand that your privacy is of utmost importance. This comprehensive Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you engage with our wedding venue services, gourmet food products, and digital platforms.

Our Compliance Framework:

CASL: Compliance with Canada’s Anti-Spam Legislation for all electronic communications
PIPEDA: Adherence to Canada’s Personal Information Protection and Electronic Documents Act
GDPR: For European Union residents
CCPA: For California residents

Corporate Structure:
The Company serves as Controller (as defined in GDPR) for your personal data and is one of several affiliated entities owned by 954521 Ontario Ltd. (the “Parent”). While we share certain operational resources within this corporate group, we maintain strict data separation and protection protocols across all entities.

CASL-Specific Provisions:
We strictly comply with Canada’s Anti-Spam Legislation by:

Obtaining express consent for commercial electronic messages
Providing clear identification in all communications
Including immediate unsubscribe options
Maintaining consent records for 3+ years
Ensuring third-party partners meet CASL requirements

This policy applies to:

Visitors to KurtzOrchards.com
Wedding venue clients
Gourmet food customers
Newsletter subscribers
Customer service interactions

Our Commitment:

Transparent data practices
Industry-standard security measures
Respect for your privacy rights
Regular policy reviews and updates

2. Data Controller & Corporate Structure

Kurtz Orchards (the “Company”) serves as the data controller (as defined in the GDPR) for all personal information collected through our services. As controller, we determine the purposes and means of processing your personal data and are fully responsible for its protection.

The Company operates as part of a family of affiliated businesses owned directly or indirectly by 954521 Ontario Ltd. (the “Parent Company”). This corporate structure includes:

Shared administrative services
Integrated business operations
Coordinated customer service standards

While we may share certain operational resources within this corporate group, your personal data:

Remains protected under this Privacy Policy
Is never shared beyond what is necessary for service delivery
Maintains the same security standards across all entities

For all privacy-related inquiries:
📧 Email: info@kurtzorchards.com
📞 Phone: 905-468-2937
📬 Mailing Address:
16006 Niagara River Parkway, P O Box 457
Niagara-on-the-Lake, ON, CANADA, L0S 1J0

Our privacy team oversees compliance across all affiliated entities and ensures consistent application of this policy throughout our corporate structure.

3. Detailed Breakdown of Collected Data

A. Information Provided Directly by You

We collect various types of personal data that you voluntarily provide when:

Booking our wedding venue: Includes names, contact details, event dates, guest counts, and special requests
Purchasing gourmet products: Includes delivery addresses, payment information, and dietary preferences
Creating an account: Includes login credentials and profile information
Subscribing to communications: Includes email preferences and marketing consent
Contacting customer service: Includes communication records and issue details

B. Information Collected Automatically

Our systems automatically gather:

Device and technical data: IP addresses, browser types, operating systems, and device identifiers
Usage analytics: Pages visited, time spent, click patterns, and navigation paths
Location data: Generalized geographic information (city/region level) for service customization
Cookie data: As detailed in Section 7 below

C. Information from Third Parties

We may receive data from:

Event planning partners: When you book through affiliated planners
Social media platforms: When you interact with our profiles or use social login features
Payment processors: Transaction confirmations and fraud prevention data
Marketing partners: Aggregated campaign performance data

4. Comprehensive Data Usage Purposes

Electronic Communications Compliance (Canada’s Anti-Spam Legislation – CASL)

We strictly comply with Canada’s Anti-Spam Legislation (CASL) regarding commercial electronic messages:

Express Consent Required: We only send commercial emails/texts to individuals who have explicitly opted in
Clear Identification: All messages include our full contact information:
Kurtz Orchards
16006 Niagara River Parkway, P O Box 457
Niagara-on-the-Lake, ON L0S 1J0
905-468-2937
Unsubscribe Mechanism: Every email contains a prominent, working unsubscribe link
Record Keeping: We maintain detailed records of consent for 3 years after withdrawal
Third-Party Marketing: Any shared marketing complies with CASL’s disclosure requirements

Violations of CASL can result in investigations by the CRTC and penalties up to $10 million CAD. We maintain internal CASL compliance training for all staff handling communications.

5. Expanded Data Sharing Practices

A. Essential Service Providers

We work with carefully vetted partners who assist in:

Payment processing: Secure transaction handling
Event coordination: Caterers, florists, and other wedding vendors
Digital services: Website hosting, analytics, and marketing tools
Logistics: Delivery and shipping providers

All third parties must sign strict data protection agreements and may only process data for specified purposes.

B. Legal Disclosures

We may disclose information when legally required to:

Comply with court orders or government requests
Protect against legal liability
Prevent fraudulent or harmful activities
Enforce our terms and policies

C. Business Transitions

In the event of a merger, acquisition, or sale of assets, customer information may be transferred as part of the business assets. All such transfers would maintain the confidentiality protections outlined in this policy.

6. International Data Transfers & Safeguards

For our international clients, particularly those in the European Union, we implement robust safeguards for any cross-border data transfers:

Standard Contractual Clauses: With all non-EEA service providers
Data Minimization: Only transferring necessary information
Encryption Protocols: For all international data transmissions

EU residents have the right to request information about these safeguards by contacting us at info@kurtzorchards.com.

7. Cookies & Tracking Technologies – Detailed Explanation

A. Essential Cookies

These strictly necessary cookies enable core website functionality:

Session maintenance for booking processes
Shopping cart retention
User authentication

B. Performance Cookies

These analytical cookies help us improve our services:

Google Analytics for traffic measurement
Heat mapping tools for user behavior analysis

C. Marketing Cookies

Used for personalized advertising (only with consent):

Facebook Pixel for retargeting
Email campaign tracking

Cookie Management Options:

Browser settings (disable/enable all cookies)
Granular controls via our cookie consent banner
Opt-out tools for specific advertising networks

8. Data Retention & Security Protocols

A. Retention Periods

We retain personal data only as long as necessary:

Data Type	Retention Period
Booking records	7 years (tax compliance)
Customer service interactions	3 years
Marketing consents	Until withdrawal
Financial transactions	7 years

B. Security Measures

Our multi-layered security approach includes:

Network Security: Firewalls and intrusion detection systems
Data Encryption: SSL/TLS for all transmissions
Access Controls: Role-based permissions and multi-factor authentication
Regular Audits: Vulnerability assessments and penetration testing

9. Your Privacy Rights Under Canadian & International Laws

A. Your Rights Under PIPEDA (Canada’s Privacy Law)

Right to Access:
- Request copies of your personal information we hold
- Receive explanation of how it’s being used
- Be informed of third parties with whom we’ve shared it
Right to Correction:
- Challenge accuracy/completeness of your information
- Request amendments to inaccurate data
- Have corrected information transmitted to third parties when appropriate
Right to Withdraw Consent:
- Revoke consent for continued use/disclosure of your information
- Exceptions apply for legal/contractual requirements
Right to File a Complaint:
- Contact our Privacy Officer at info@kurtzorchards.com
- Escalate to the Office of the Privacy Commissioner of Canada if unresolved

B. Your Protections Under CASL (Canada’s Anti-Spam Law)

Consent Requirements:
- Express opt-in consent for all commercial electronic messages (CEMs)
- Clear documentation of consent method/timing
- Separate consent obtained for different message types
Identification & Unsubscribe:
- All CEMs include our full contact information:
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Kurtz Orchards
16006 Niagara River Parkway, P.O. Box 457
Niagara-on-the-Lake, ON L0S 1J0
905-468-2937
info@kurtzorchards.com
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- One-click unsubscribe mechanism in every email
- Processed within 10 business days
CASL-Specific Rights:
- Request proof of your consent
- Report suspected violations to info@kurtzorchards.com
- Access our CASL compliance policies

C. Additional International Rights

For EU Residents (GDPR):

Right to Access: Receive a copy of your personal data
Right to Rectification: Correct inaccurate information
Right to Erasure: Request deletion under certain conditions
Right to Restriction: Limit processing in specific circumstances
Right to Data Portability: Receive your data in a transferable format
Right to Object: Opt out of certain processing activities

For California Residents (CCPA):

Right to know what personal information is collected
Right to delete personal information (with exceptions)
Right to opt-out of “sales” (though we do not sell data)
Right to non-discrimination for exercising rights

D. How to Exercise Your Rights

For PIPEDA Requests:
📧 Email: info@kurtzorchards.com
📞 Phone: 905-468-2937 (ext. 2 for Privacy Officer)
📬 Mail: Attn: Privacy Compliance
16006 Niagara River Parkway, P.O. Box 457
Niagara-on-the-Lake, ON L0S 1J0

For CASL Requests:
📧 Email: info@kurtzorchards.com
📞 Phone: 905-468-2937 (ext. 3 for Marketing)

Response Timelines:

PIPEDA access requests: 30 days
CASL unsubscribe: 10 business days
Complaint acknowledgment: 3 business days

E. Canadian Enforcement & Recourse

PIPEDA Oversight:
- Office of the Privacy Commissioner of Canada
- Potential Federal Court applications for enforcement
CASL Enforcement:
- CRTC investigations
- Penalties up to $10 million CAD for violations
- Private right of action available
Our Compliance Commitment:
- Annual staff training on PIPEDA/CASL
- Regular compliance audits
- Designated Privacy Officer oversight

10. Children’s Privacy Protection

Our services are strictly designed for users aged 18 and older. We:

Do not knowingly collect data from minors
Immediately delete any inadvertently collected minor data
Require age verification for certain services

Parents/guardians may contact us at info@kurtzorchards.com regarding any concerns.

11. Policy Updates & Notification

We regularly review and update this policy to reflect:

Changes in our services
New legal requirements
Industry best practices

Notification Methods for Changes:

Website banners for significant updates
Email notifications for subscribed users
Updated “Last Revised” date at policy header

12. Contact Us – Multiple Options

For any privacy-related questions or concerns:

Primary Contact:
📧 info@kurtzorchards.com
📞 905-468-2937 (Mon-Fri, 9am-5pm EST)

Written Correspondence:
Kurtz Orchards Privacy Office
16006 Niagara River Parkway, P O Box 457
Niagara-on-the-Lake, ON, CANADA, L0S 1J0

In-Person Inquiries:
[By appointment at our Niagara-on-the-Lake location]

We take all privacy matters seriously and strive to resolve any concerns promptly and thoroughly.

End of Privacy Policy
This document represents our complete privacy commitment to you, our valued customers and website visitors. We appreciate the trust you place in Kurtz Orchards and are dedicated to protecting your personal information with the highest standards of care and security.

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