Suite 307, 89 Canterbury St, Saint John NB E2L2C7

PRIVACY POLICY

Last Updated: 2026-01-01

NOCTURNE DELTA INC. (“NOCTURNE”, “we”, “us”, “our”) is committed to protecting the privacy of individuals who visit our website and engage with our consulting services.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in compliance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

By using our website (nocturne.ca) or engaging our services, you consent to the practices described in this policy.

1. INFORMATION WE COLLECT

Personal information you provide directly

When you interact with our website or services, you may provide personal information including:

Contact Forms and Inquiry Submissions:

  • Name
  • Email address
  • Phone number
  • Organization name and role/title
  • Message content and specific inquiry details

Newsletter Subscriptions:

  • Email address
  • Name (optional)
  • Industry/sector interest
  • How you heard about us (optional)

Career Applications:

  • Resume/curriculum vitae
  • Cover letter
  • References (provided upon request)
  • Educational and professional background
  • Contact information

Consulting Engagements:

  • Business contact information
  • Project-specific information as relevant to service delivery
  • Communications regarding projects and deliverables

Information collected automatically

When you visit our website, certain information may be collected automatically:

Website Usage Data:

  • IP address
  • Browser type and version
  • Operating system
  • Pages visited and time spent on pages
  • Referring website/source
  • Date and timestamp of visits

Cookies and Tracking Technologies:

  • Session cookies (for website functionality)

We do not use advertising cookies or third-party tracking for marketing purposes.

Information we do not collect through our website

  • We do not collect sensitive personal information (health information, financial account information, social insurance numbers) through our public website
  • Sensitive information shared during consulting engagements is governed by separate confidentiality and consulting agreements
  • We do not knowingly collect information from individuals under 18 years of age

2. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

Primary purposes

Responding to Inquiries:

  • Processing and responding to contact form submissions
  • Answering questions about our services
  • Scheduling consultations and meetings

Providing Consulting Services:

  • Delivering consulting services to clients
  • Communicating about project scope, deliverables, and timelines
  • Invoicing and payment processing
  • Maintaining client relationships

Recruiting and Employment:

  • Processing job applications
  • Evaluating candidate qualifications
  • Conducting interviews and reference checks
  • Maintaining candidate database for future opportunities

Marketing Communications (with consent):

  • Sending newsletters and industry insights to subscribers
  • Communicating updates about our services and capabilities
  • Sharing relevant industry information and resources

Website Improvement:

  • Analyzing website traffic and user behaviour
  • Identifying technical issues and improving functionality
  • Enhancing user experience and content relevance

Legal and Compliance:

  • Complying with legal obligations under Canadian law
  • Protecting our legal rights and interests
  • Preventing fraud or misuse of our services
  • We will only send marketing communications (newsletters, service updates) if you have provided consent
  • You may withdraw consent at any time by using the unsubscribe link in emails or contacting us directly
  • Withdrawal of marketing consent does not affect our ability to communicate with you regarding active consulting engagements

3. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your information in the following limited circumstances:

Service providers

We may share personal information with trusted service providers who assist us with:

  • Website hosting: Web Hosting Canada
  • Email delivery and newsletter management: Web Hosting Canada
  • Cloud storage and collaboration tools: Sync.com (Canadian cloud hosting service). Microsoft.com (only if authorized by the client).

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

We may disclose personal information if required by:

  • Canadian law or legal process (court orders, subpoenas)
  • Government authorities or regulators making requests in accordance with legislated obligations
  • Protection of our legal rights or defence against legal claims
  • Prevention of fraud, illegal activity, or threats to safety

Business transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring organization. You will be notified of any such transfer via email or prominent notice on our website.

We may share your information with third parties when you have provided explicit consent for such sharing.

4. DATA STORAGE, SECURITY, AND RETENTION

Security measures

We implement reasonable administrative, technical, and physical safeguards to protect your personal, protected and commercially sensitive information from unauthorized access, use, disclosure, or loss:

Technical Measures:

  • Encryption of data transmission using SSL/TLS protocols
  • Secure password practices and access controls
  • Regular security assessments and updates
  • Secure-by-design systems
  • Sovereign control of encryption keys

Administrative Measures:

  • Staff training on privacy and confidentiality
  • Access to personal information limited to authorized personnel as required to perform operational functions
  • Confidentiality agreements with employees and contractors
  • Definitive policies and safeguards to control access of AI tools to data repositories and client data

Physical Measures:

  • Secure facilities and controlled access to physical records

Limitations: Despite our security measures, no internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security of your personal information.

Data location and sovereignty

As a Canadian organization, we prioritize Canadian data storage where feasible:

  • Website hosting: Hosted on Canadian servers operated by Web Hosting Canada.
  • Email and communications: Hosted on Canadian servers operated by Web Hosting Canada, using end-to-end encrypted communications systems such as Signal, or WITH CONSENT using commercially secure systems such as Microsoft Teams.
  • Client project data: Stored according to consulting agreement terms, with Canadian-hosted zero-trust encrypted storage prioritized.

Important Note on Data Sovereignty: Some service providers we use may be subject to foreign laws (for example, US-based companies subject to US CLOUD Act). Where personal information is stored or processed by such providers, we ensure appropriate contractual safeguards are in place. If you have specific data sovereignty requirements, please contact us to discuss options.

Data retention

We retain personal information only as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law:

Contact Form Inquiries: Retained until inquiry is resolved, then deleted within two years unless an ongoing relationship develops.

Newsletter Subscriptions: Retained until you unsubscribe or request deletion

Career Applications: Retained for two years to consider candidates for future opportunities, unless you request earlier deletion

Client Information: Retention governed by consulting agreements and professional obligations (typically one year) for compliance and legal purposes)

Website Analytics: Aggregated and anonymized data may be retained indefinitely; IP addresses and identifiable data retained for appropriate periods.

5. YOUR PRIVACY RIGHTS UNDER PIPEDA

You have the following rights regarding your personal information:

Right to access

You may request access to the personal information we hold about you. We will provide this information in an understandable format within a reasonable timeframe (typically 30 days).

Right to correction

If you believe personal information we hold about you is inaccurate or incomplete, you may request correction. We will correct verified inaccuracies promptly.

You may withdraw consent for certain uses of your personal information:

  • Marketing communications: Unsubscribe using the link in emails or contact us directly
  • Website cookies: Disable through browser settings (may affect website functionality)
  • Consulting services: Note that withdrawal of consent may limit our ability to provide services

Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

Right to complain

If you have concerns about our privacy practices:

  1. Contact us first: We will investigate and respond to your complaint
  2. Office of the Privacy Commissioner of Canada: If not satisfied with our response, you may file a complaint with the federal Privacy Commissioner (www.priv.gc.ca) or applicable provincial privacy commissioner

How to exercise your rights

To exercise any of these rights, contact us at:

Email: support@nocturne.ca

Mail: NOCTURNE DELTA INC., Suite 307, 89 Canterbury St, Saint John NB E2L 2C7 Canada

We will respond to requests within 30 days as required by PIPEDA. We may require verification of your identity before providing access to personal information.

6. COOKIES AND TRACKING TECHNOLOGIES

What cookies we use

Session Cookies (Required):

  • Purpose: Enable website functionality and user session management
  • Duration: Deleted when you close your browser
  • Can be disabled: No (required for website operation)

Analytics Cookies:

  • Purpose: Understand website traffic, user behaviour, and improve user experience
  • Information collected: Page views, time on site, navigation patterns, referring sources
  • Can be disabled: Yes (see below)

Managing cookies

Browser Settings: You can control cookies through your browser settings:

  • Block all cookies
  • Block third-party cookies only
  • Delete cookies after each browsing session

Note: Disabling cookies may affect website functionality.

Do Not Track signals

Where technically practical, NOCTURNE will configure systems to honour Do Not Track signals and preferences set by users.

Our website may contain links to third-party websites (for example, LinkedIn, industry associations, client websites, reference materials).

Important:

  • We are not responsible for the privacy practices of external websites
  • Third-party sites have their own privacy policies
  • We encourage you to review privacy policies before providing personal information to any website

Linking to a third-party website does not constitute endorsement of that website’s privacy practices.

8. INTERNATIONAL DATA TRANSFERS

NOCTURNE primarily serves Canadian clients and prioritizes Canadian data storage. However, some service providers may be located outside Canada.

Cross-Border Transfers:

  • Personal information may be processed by service providers in [SPECIFY COUNTRIES IF KNOWN, e.g., “the United States”]
  • When information is transferred outside Canada, it is subject to the laws of that jurisdiction
  • We ensure contractual safeguards are in place with all service providers handling personal information

Your Rights: You have the right to ask about cross-border transfers of your personal information and the safeguards we have implemented.

9. CHILDREN’S PRIVACY

Our website and services are not directed to individuals under 18 years of age.

We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from someone under 18, we will delete it promptly.

If you believe we have collected information from a minor, please contact us immediately at support@nocturne.ca.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect:

  • Changes in our information practices
  • New legal or regulatory requirements
  • Feedback from privacy authorities or clients
  • Evolving privacy best practices

Notification of Changes:

  • Updated Privacy Policy will be posted on this page with a revised “Last Updated” date
  • Material changes will be communicated via:
    • Email to newsletter subscribers
    • Prominent notice on our website homepage

Your Continued Use: Your continued use of our website or services after changes become effective constitutes acceptance of the updated Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

11. CONTACT US

Privacy questions, requests or complaints

Privacy Officer / Contact: Dave Drinnan

Email: support@nocturne.ca

Mail: NOCTURNE DELTA INC., Suite 307, 89 Canterbury Street, Saint John New Brunswick, Canada, E2L 2C7

Phone: 506-643-8490

Response Time: We will acknowledge receipt of your inquiry within [SPECIFY, e.g., “5 business days”] and provide a substantive response within 30 days as required by PIPEDA.

General inquiries

Contact us for non-privacy inquiries about our services.

12. EFFECTIVE DATE

This Privacy Policy is effective as of 2026-01-01.

ACKNOWLEDGEMENT

By using our website or services, you acknowledge that you have read, understood, and agree to this Privacy Policy and our practices regarding your personal information.