1. Introduction
This Privacy Policy explains how Edj Tabuk Investments Inc. handles personal information. The policy is issued by the company and it describes the practices of the developer name EDJ Tabuk, which operates the office and the website on behalf of Edj Tabuk Investments Inc. When this policy says we, us or the Company, it refers to Edj Tabuk Investments Inc., a private investment holding seated at 6836 Round Leaf Crt, Mississauga - L5N 6X6, Canada (CA), and to the individuals who work in that office under the developer name EDJ Tabuk.
The holding is small, private and deliberately slow. It holds its own stakes rather than managing money for the public, and it does not accept external capital. Even so, a private holding still receives names, contact details, correspondence, documents and financial information from the people who hold or share a file with it. We take that responsibility seriously, and this policy sets out exactly what we collect, why we collect it, how long we keep it and how a person can ask us to change or delete it.
We have written this policy in plain English on purpose. Legal language is sometimes used to obscure rather than to clarify, and we would rather be understood than impressive. If any part of this policy is unclear, the office can be reached at reception@edjtabuk.buzz or by telephone at +15392826313, and a member of the team will explain the relevant practice in ordinary words.
By using the website at www.edjtabuk.buzz, by sending a note to the office, or by sharing a document with us in connection with a review, you acknowledge that you have read this policy. You do not need to consent to anything beyond what is required for us to answer you, and the sections below explain the choices that are available.
2. Scope of This Policy
This policy applies to personal information that we collect through the public website, through email and telephone communication, through the contact form, through documents that a holder or a counterparty sends to the office, and through any written correspondence that relates to a review, an audit, a partnership file or an estate file. It also applies to information that we receive from a professional adviser, such as a lawyer, an accountant or a surveyor, where that information relates to a file we are reading.
This policy does not apply to information that is not personal information. A property description, a corporation number, a public title record or a published address of a business is generally not personal information, and we may use and retain such records freely where the law allows. A document can contain both kinds of information at once, and in that case we treat the whole document with the care that personal information requires.
This policy does not cover websites, applications or services that we do not control. If a link on our website leads to a third party, that third party has its own privacy practice, and we cannot promise anything about it. Section 20 describes how we handle those links in more detail.
This policy does not create any right to have a file read, to receive advice, or to become a partner or a counterparty of the holding. Those matters are governed by the Terms of Service and by whatever written arrangement is agreed for a particular file.
3. Who We Are and Where We Operate
Edj Tabuk Investments Inc. is a private investment holding engaged in the review and stewardship of property stakes, quiet partnership positions, dividend routing arrangements, estate timelines, portfolio hygiene and founder loan restructuring. The holding is established in Canada and it works from a single office in Mississauga, in the province of Ontario.
The full office address is 6836 Round Leaf Crt, Mississauga - L5N 6X6, Canada (CA). The office is the place where documents are received, where the physical ledger is kept and where the reception desk is staffed. Visits are arranged in advance so that the counter is clear and the file is ready when a visitor arrives.
The office telephone number is +15392826313 and the office email address is reception@edjtabuk.buzz. Both channels reach the same small team that reads the files, so there is no separate call centre and no scripted response. A person who wishes to raise a privacy question may use either channel and ask for the privacy contact by name.
Because the holding is based in Ontario, our handling of personal information is guided by the federal privacy law of Canada and by the privacy law of Ontario that applies to commercial activity within the province. Where a holder or a counterparty is located in another jurisdiction that grants stronger rights, we will extend those rights where it is reasonable to do so, and we will not use a geographic difference to reduce the protection that a person would otherwise receive.
4. Information We Collect
We collect only the information that a file actually requires. Because the work is about stakes, partnerships and family timelines, the information we receive tends to be documentary rather than behavioural, and we would rather receive one accurate page than a large volume of data that we do not need.
Identification and contact details
This includes a name, a postal address, an email address, a telephone number, and, where relevant, the name of a corporation, a trust or an estate that a person represents. We also record the capacity in which a person writes, for example as a holder, a partner, an executor, an adviser or an authorised representative.
Correspondence and file content
This includes the text of notes sent through the contact form, the content of emails and letters, and the documents that a person chooses to share, such as a deed, a survey, a partnership agreement, a loan instrument, a distribution statement or an estate schedule. We ask holders not to send sensitive documents until the office requests them, because the first note is meant to be a description rather than a disclosure.
Financial and asset information
Where a review requires it, we may receive information about the value of a stake, the terms of a partnership, the route of a distribution, the maturity of a loan or the value of an estate. This information is treated as confidential and it is kept inside the file to which it belongs.
Technical information from the website
When a person visits the website, the hosting service may record standard technical information such as the type of browser, the general region from which the request came, and the page that was requested. We use this information only for the reliability and security of the site. We do not build advertising profiles and we do not sell technical information to anyone.
Information we do not seek
We do not seek government identification numbers, health records, biometric data, precise location data or any special category of information that a file does not require. If such information arrives unexpectedly, we will note its arrival, keep it with the file, and ask the sender whether it should be returned or destroyed.
5. How We Collect Information
Most information arrives directly from the person it concerns. A holder writes a note, completes the contact form, sends an email, telephones the office or posts a document. In each case the person is choosing to share something with us, and the choice is understood as being made for the purpose of having the file read.
Some information arrives from a third party. A lawyer may send a copy of a title, an accountant may send a distribution statement, a surveyor may send a plan, or a partner may send a notice that affects a shared position. When we receive personal information from a third party in this way, we record where it came from, and we use it only for the file to which it relates.
A small amount of information is generated automatically by the website and by ordinary office systems. The hosting service records technical requests, the email system records the sender and the time of a message, and the telephone system records the number that called. These records are used for reliability, for security and for answering a person who asks whether a message was received.
We do not buy personal information from data brokers. We do not scrape social media profiles. We do not use tracking pixels for advertising. If that ever changes, this policy will be updated before the change takes effect, and the update will be described in Section 21.
6. Why We Use Information
We use personal information for a small number of clearly defined purposes. Each purpose is connected to the work of the holding, and we do not repurpose information for an unrelated activity without telling the person concerned.
- To answer a note, a question or a request that has been sent to the office.
- To read a file and to prepare a written note about it, including the questions that must be answered before an opinion can be offered.
- To arrange a visit, a call or a meeting at the office in Mississauga.
- To maintain the physical ledger and the digital index that record which files exist and which decisions have been made.
- To comply with a legal obligation, such as a tax filing, a court order or a lawful request from a public authority.
- To detect and prevent fraud, misuse of the website, or unauthorised access to office systems.
- To improve the clarity of our own documents, by reviewing the questions that holders most often ask and by rewriting our guidance so that the next holder has an easier start.
We do not use personal information to make an automated decision that would have a legal or similarly significant effect on a person. Section 18 explains this in more detail. We do not use personal information to train a public artificial intelligence model, and we do not send file content to a third party tool that retains it for that purpose.
Where a purpose requires a higher level of care, such as a review that involves a family estate or a founder loan, we limit access to the individuals who are actually working on the file. The reception desk can confirm who is working on a file, and a holder may ask that a particular member of the team be excluded where it is practical to do so.
7. Legal Basis for Processing
Under Canadian privacy law, a private organisation may collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances, and only with the knowledge and consent of the individual, except where the law provides an exemption. We rely on that principle for most of what we do.
Where a person sends a note, the consent is implied by the act of sending it for the stated purpose. Where a person shares a document for a review, the consent is implied by the request for the review. Where we must keep a record for a legal or tax obligation, the law provides the basis and the consent of the individual is not required for that specific retention.
Where the law of another jurisdiction applies, we map our practice to the closest equivalent basis. For a person in a jurisdiction that requires explicit consent, we will ask for that consent before the relevant collection takes place. For a person in a jurisdiction that grants a right to object, we will honour the objection and will record it in the file so that the preference is not forgotten.
A person may withdraw consent at any time, subject to a legal or contractual restriction and to reasonable notice. Withdrawal does not affect the lawfulness of processing that took place before the withdrawal, and it may mean that we can no longer continue to read a file. If a withdrawal has that consequence, the office will explain it in writing before the file is closed.
10. Service Providers and Processors
A small office still depends on a few service providers. The website is hosted by a hosting service, the email is carried by an email provider, and the office keeps a digital index on a computer system that is maintained by a supplier. Each of these providers processes information on our behalf rather than for its own purposes, and each is bound by a written arrangement that sets out the limits of its access.
We choose providers that offer a reasonable standard of security, that store information in jurisdictions with comparable privacy protection, and that agree to notify us promptly if they become aware of an incident affecting our information. We review those arrangements from time to time, and we replace a provider if its practice falls below the standard we require.
A provider may use a subcontractor for a narrow technical function, such as backup storage or network protection. Where that happens, the provider remains responsible to us for the subcontractor, and the same limits apply. We do not authorise a provider to use our information for its own marketing, for product development or for training a public model.
If a person wishes to know which categories of provider are involved in a particular file, the office can describe them on request. We will not name a provider where doing so would create a security risk, but we will always explain the role that the provider plays and the safeguard that applies.
11. International Transfers
The office is in Mississauga, Ontario, and the physical ledger stays there. Digital copies may be stored by a hosting or email provider whose servers are located in Canada or in another country with a comparable privacy regime. Where information leaves Canada, we take reasonable steps to ensure that it remains protected by an arrangement that is comparable to the protection it would receive at home.
Before a transfer to a new jurisdiction, we consider the sensitivity of the information, the purpose of the transfer, the law of the destination country and the contractual protections that the provider offers. If the destination does not offer adequate protection, we will either keep the information in Canada or obtain the explicit consent of the person concerned after explaining the risk.
A holder may ask where a file is stored and may ask that a digital copy be kept only in Canada where it is practical to do so. We will accommodate such a request where the technical arrangement allows it, and we will explain any limitation honestly rather than promising a location that we cannot guarantee.
Transfers between our own office systems are protected by encryption in transit and at rest. A transfer to a professional adviser is made through a channel agreed with the holder, and we do not send a sensitive document through an open link without confirmation that the recipient is expecting it.
12. Retention of Information
We keep personal information only for as long as it is needed for the purpose for which it was collected, or for as long as a legal obligation requires. A file that has been closed and that carries no ongoing legal or tax consequence is generally kept for seven years from the date of the last entry in the ledger, because that period covers the ordinary limitation and audit windows that apply to the work of a holding in Ontario.
A contact form submission that does not lead to a file is kept for two years and then deleted, so that the office can answer a follow up question without reconstructing the conversation from memory. A note that leads to a file becomes the first page of that file and follows the retention period of the file itself.
Where the law requires a longer period, for example for a tax record or for a matter that is under a legal hold, we keep the information for the required period and we limit access to the individuals who need it. Where a shorter period is appropriate, for example for a routine enquiry that has been fully answered, we delete the information earlier.
When a retention period ends, we destroy the information in a way that prevents reconstruction. Paper is shredded and the shredding is recorded. Digital records are deleted from the active system and from the scheduled backups within the cycle of the backup system. A person may ask for earlier deletion where no legal or contractual obligation requires retention, and we will confirm the deletion in writing where it is safe to do so.
13. How We Protect Information
We protect information through a combination of physical, technical and organisational measures. The physical room was designed around the work: there is a burl reception counter where documents are signed, a fern vault grille over the archive window, and a brass cap rail that runs along the wall. The grille is opened twice a year for the review windows and closed the rest of the time, and the archive is not left unattended during a visit.
On the technical side, office systems are protected by individual accounts, strong passwords, a second factor for remote access, encryption in transit and at rest, and a backup routine that is tested. Access to a file is limited to the people who are actually working on it, and access is removed when a person leaves the team or finishes a file.
On the organisational side, every member of the team is bound by a confidentiality undertaking, receives a short briefing on privacy at the start of their work, and is reminded of the practice at each review window. A file is not discussed in a public place, a document is not left on a printer, and a sensitive message is not sent from a personal account.
No arrangement is perfect, and we do not claim that a breach is impossible. What we can promise is that the safeguards are real, that they are reviewed, and that a person will be told promptly if something goes wrong in a way that creates a real risk of significant harm. Section 19 describes the response that follows a breach.
14. Your Rights
Subject to the law of the jurisdiction that applies to you, you have a number of rights in relation to the personal information that we hold about you. The office will explain which rights apply in your case and will help you use them.
- The right to be informed about how your information is collected and used.
- The right to access the personal information that we hold about you.
- The right to ask that inaccurate or incomplete information be corrected.
- The right to withdraw consent to a use that relies on consent.
- The right to ask for deletion where no legal or contractual obligation requires retention.
- The right to object to a particular use, and to have that objection recorded.
- The right to ask for a copy of information in a portable format where the law provides it.
- The right to complain to a privacy regulator, and to be told how to do so.
A person does not have to pay to exercise these rights, although a reasonable fee may be charged for a request that requires a large amount of copying, and any such fee will be explained before the work begins. A request will be answered within thirty days where the law requires that period, and where more time is needed the office will explain why and give a new date.
Where a request concerns a document that belongs to another person, such as a partner or a counterparty, we may need to remove the information that belongs to that other person before providing a copy. We will always explain what has been removed and why, because an unexplained redaction is almost as unhelpful as a refusal.
15. Making an Access or Correction Request
An access or correction request should be sent in writing to reception@edjtabuk.buzz, or by post to Edj Tabuk Investments Inc. at 6836 Round Leaf Crt, Mississauga - L5N 6X6, Canada (CA). The request should state the name of the person making it, the contact details for the reply, and enough information about the file to allow the office to locate it. A request may also be made by telephone at +15392826313, and the office will confirm the written details afterward.
Before providing access, we may ask for reasonable proof of identity, because a file often contains information about other people. The proof should be the minimum needed to confirm identity, and it should not be a document that contains sensitive information that we do not need. A copy of a document is not kept after identity has been confirmed unless the law requires it.
Once identity is confirmed, we search the ledger and the digital index, collect the information that relates to the person, review it for the information of third parties, and prepare a response. Where the request is for a correction, we will either make the correction and notify anyone to whom the information was disclosed, or explain why the correction was not made and record the disagreement in the file.
A person who is not satisfied with the response may ask the office to review the decision internally, and may also complain to the Office of the Privacy Commissioner of Canada or to the Information and Privacy Commissioner of Ontario. The office will provide the relevant contact details on request and will not discourage a person from using them.
16. Privacy for Children
The website and the services of the holding are intended for adults who hold or who administer a stake, a partnership, an estate or a loan. We do not knowingly collect personal information from a child, and we do not direct any part of the site at children. A child who wishes to reach the office should ask a parent or a guardian to make the contact.
An estate file sometimes contains information about a minor, for example where a minor is a beneficiary. We handle that information with particular care, we limit access to the individuals who are actually working on the estate, and we do not share it with a counterparty unless the law requires it or the executor authorises it in writing.
If we discover that we have collected information about a child without the knowledge of a parent or guardian, we will delete the information promptly and will notify the parent or guardian where contact details are available. A parent or guardian may contact reception@edjtabuk.buzz at any time to ask what information, if any, we hold about a child and to request its deletion.
17. Direct Marketing and Communication Preferences
We do not operate a marketing list. A person who writes to the office receives a reply about the file and nothing else. We do not add a contact to a newsletter, we do not send promotional offers, and we do not share a contact with a marketing partner.
The annual spring review window is announced on the public website rather than by a bulk email. A holder who has an open file may receive a short note when the review window opens, because the note is part of the file rather than a marketing message. That note will always be sent from the office address and will always carry a way to decline further notes.
A person may ask at any time to receive no further communication, and the office will record the preference in the file and honour it. Where a legal obligation requires a particular notice, that notice will still be sent, and the office will explain the reason. A request to stop marketing will never be treated as a request to close a file or to stop a legally required communication.
We do not use a telephone number for an automated marketing call. A call from the office is made by a person, is connected to a file that is already open, and can be traced to the ledger entry that prompted it.
18. Automated Review and Decision Support
Some parts of a review involve software that helps to organise documents, to search for a name or a date, or to compare the terms of two agreements. Software of this kind supports the reading rather than replacing it. A person reads the document, a person forms the opinion, and a person signs the note in the ledger.
We do not make an automated decision that would have a legal or similarly significant effect on a person. We do not use software to rank people, to score a claimant or to decide whether a file is worthy of attention. A decision about a file is made by a member of the team, is recorded in writing, and can be reviewed by a person who was not involved in the original reading.
Where software is used, it operates on a system that is controlled by the office, and the content of a file is not sent to a public model that retains it for training. A provider that supports the office is bound by the same confidentiality and retention limits described in Section 10.
A person may ask whether a particular decision was supported by software and may ask for a short explanation of how the decision was reached. The office will provide that explanation in plain language, and where the decision depends on a judgement rather than on a rule, the office will say so honestly.
19. Privacy Breach Response
A privacy breach is any loss, theft, unauthorised access, unauthorised disclosure or unauthorised use of personal information. We take the possibility seriously, and we have a short response plan so that a breach is handled quickly and without confusion.
When a breach is suspected, the person who notices it informs the office immediately, and the office secures the affected system or document, preserves the evidence, and begins a written record of what happened. The record includes the time of discovery, the information affected, the people involved and the steps taken. The record is kept even if the incident turns out not to be a breach, because a pattern is only visible when the near misses are written down.
We assess the risk of significant harm to the people whose information is affected. If a real risk of significant harm exists, we notify the affected people promptly, describe what happened, explain what we are doing about it and suggest the steps that a person can take to protect themselves. Where the law requires a report to a privacy regulator, we make that report within the required period.
After the immediate response, we review what allowed the incident and we change the practice so that it is less likely to recur. The review is recorded in the ledger, and a summary is kept for the retention period that applies to the file. A person who is affected may ask what changes were made, and the office will answer as openly as the law allows.
20. Third Party Sites and Links
The website contains a small number of links to other sites, for example to the site of a professional adviser or to a public registry. Those links are provided for convenience, and they do not mean that we control the destination or that we endorse its privacy practice.
When a person follows a link away from our site, the privacy policy of the destination applies. That policy may be different from ours, and it may allow uses that we would not permit. A person should read the policy of the destination before providing personal information to it, and should treat a request for sensitive information with care wherever it appears.
We do not embed a third party widget that collects information from a visitor without the visitor knowing. If a future version of the site includes an embedded service, the change will be described in this policy and a consent notice will appear where the law requires one.
A link from another site to our website does not mean that the other site has our approval or that it speaks for us. The only authoritative statement of our practice is this policy, as it appears on the website at www.edjtabuk.buzz.
21. Changes to This Policy
We review this policy at least once a year, usually in the same spring window in which the files are reviewed. A review may confirm the policy without change, or it may update a practice, a retention period or a contact detail. The date at the top of the page always shows the most recent version.
A material change will be announced on the homepage of the website before it takes effect, and a holder with an open file will receive a short note describing the change. A change that reduces a protection will not apply to information that was collected before the change unless the person concerned agrees, and the office will explain the choice in plain language.
A minor change, such as a corrected telephone number or a reworded sentence that does not alter a practice, may be made without a separate announcement. The date will still be updated so that a reader can tell that the document has been revised.
A previous version of the policy can be requested from reception@edjtabuk.buzz, and the office will provide a copy where the retention of that version is permitted by law. The current version on the website is always the authoritative one.
22. Questions and Complaints
A question about this policy, or a request to exercise a right, should be sent to reception@edjtabuk.buzz, or by post to Edj Tabuk Investments Inc. at 6836 Round Leaf Crt, Mississauga - L5N 6X6, Canada (CA). The office telephone number is +15392826313, and a person may call during business hours to ask for the privacy contact.
A complaint will be acknowledged within five business days and answered within thirty days, unless the investigation requires more time, in which case the office will explain the reason and give a new date. The complaint is recorded in the ledger, is investigated by a person who was not involved in the original handling, and receives a written response that sets out the finding and any change that will be made.
If a person is not satisfied with the response, they may ask for an internal review and may also complain to the Office of the Privacy Commissioner of Canada or to the Information and Privacy Commissioner of Ontario. The office will provide the relevant contact details and will cooperate fully with the regulator.
We would rather hear about a problem early than learn about it late. A short note describing what went wrong is enough to begin, and the office will treat the note with the same care that it treats a file. The goal of every complaint is a clear written answer and a practice that is less likely to cause the same problem again.