Privacy Policy

World Food Equipment Inc. ("WFE," "we," "us," or "our") is committed to protecting the personal information of the customers, prospective customers, suppliers, partners, and website visitors who interact with our business. This Privacy Policy describes the categories of personal information we collect, how we use and disclose that information, how we safeguard it, how long we keep it, and your rights to access, correct, and challenge our handling of your information. We operate under the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (PIPEDA), the federal Canadian law that governs commercial collection, use, and disclosure of personal information.

1. Definitions

For the purposes of this Policy:

• Personal Information means information about an identifiable individual, as defined under PIPEDA. It does not include the name, title, business address, or business telephone number of an employee of an organization.
• Processing means any operation performed on Personal Information, including collection, recording, organization, storage, use, disclosure, transfer, and destruction.
• Service Provider means a third party that processes Personal Information on our behalf under contractual obligations to protect that information.
• Site means worldfoodequipment.com, including all subpages, the 3D walk-in configurator, and any forms or interactive features.
• You means an individual whose Personal Information we collect, including website visitors, prospective customers, customers, suppliers, and contact persons at corporate customers.

2. Scope of This Policy

This Policy applies to all Personal Information collected by WFE in the course of our commercial activities, whether collected through the Site, by telephone, by email, in person, or through any other channel. It does not apply to:

• Information that does not identify an individual or cannot reasonably be combined with other available information to identify an individual (anonymous and aggregated data);
• The business contact information of employees of corporate customers used solely for the purpose of communicating with that employee in their professional capacity (PIPEDA s. 4.01);
• Information collected by third-party websites linked from our Site, whose privacy practices are governed by their own policies.

3. Accountability and Privacy Officer

WFE is responsible for the Personal Information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Policy and with PIPEDA. The Privacy Officer's contact information is set out in Section 21.

Our employees and contractors who handle Personal Information receive instruction on their obligations under this Policy. Service Providers who process Personal Information on our behalf are contractually required to maintain a comparable level of protection.

4. Personal Information We Collect

We collect Personal Information directly from you, automatically when you interact with the Site, and (occasionally) from third parties such as referral sources or credit reporting agencies (only with your knowledge and consent, where required). The categories of Personal Information we may collect include:

4.1 Information you provide to us directly:

• Identification and contact information: name, business name, role/title, mailing address, business address, email address, and telephone number;
• Project information: location of the proposed installation, building type, walk-in dimensions, refrigeration preferences, temperature requirements, door configuration, budget range, project timeline, and any other details you submit through our forms, the 3D walk-in configurator, telephone calls, emails, or in-person meetings;
• Financial information: only as required to facilitate a financing application through one of our equipment finance partners, and only with your explicit consent for that specific purpose;
• Communications history: the content of emails, contact-form submissions, text messages, and call notes between you and our team;
• Telephone calls: when you call the number shown on this Site or in our advertising, the call is routed through a tracking number to our office. Calls may be recorded and transcribed so that project details you give us by phone are captured accurately. You hear a short notice before the call connects. Recordings, transcripts, and an automated summary are stored in our CRM and are used only to serve your inquiry;
• Marketing preferences: your express or implied consent to receive commercial electronic messages, and your preference history (subscribe, unsubscribe, channel preferences).

4.2 Information collected automatically when you use the Site:

• Device and connection information: IP address, browser type and version, device type, operating system, language preference, and screen resolution;
• Usage information: pages viewed, links clicked, time on page, referring URL, exit pages, configurator interactions (dimensions selected, finishes chosen, save events), and session duration;
• Approximate geographic location derived from your IP address (city-level, not precise location);
• Information collected through cookies and similar technologies, as described in Section 9.

4.3 Information collected from third parties:

• Referral sources: when an existing customer, partner, or supplier refers you to us, we may receive your name and contact information from that source to facilitate an introduction. We will tell you the source on first contact and obtain your consent before continuing to use that information;
• Publicly available information: business information available from public registries (corporate registries, business directories), and information you have published yourself (company website, social media profiles in a professional capacity);
• Credit and financing partners: where you apply for financing through one of our equipment finance partners, the partner may share with us the outcome of your application (approved, declined, pending) but not the underlying credit information.

5. Purposes for Which We Use Personal Information

We use Personal Information for the following identified purposes. We do not use Personal Information for purposes other than those listed without first obtaining your additional consent.

• To respond to inquiries and quote requests: contacting you to discuss your project, schedule site visits, prepare written quotes, and answer questions about our products and services;
• To fulfill contracts: coordinating site assessments, design work, equipment ordering, installation scheduling, project communications, commissioning, warranty registration, and post-install service relating to a signed installation contract;
• To administer the customer relationship: maintaining accurate records of your project, billing, payments, warranty claims, and service history;
• To send transactional and service messages: appointment confirmations, schedule changes, service reminders, warranty notices, invoice and payment communications;
• To send commercial electronic messages (CEMs) where we have your express or implied consent under the Canadian Anti-Spam Legislation (CASL), as described in Section 15;
• To improve the Site and our services: analyzing usage patterns, testing changes to the configurator and quote forms, measuring marketing performance;
• To prevent fraud and protect our business: verifying the legitimacy of inquiries, preventing fraudulent quote requests, protecting our systems and content from misuse;
• To comply with legal and regulatory obligations: tax record-keeping, contract documentation, warranty record retention, response to lawful demands by government or law enforcement, and compliance with PIPEDA, CASL, the Income Tax Act, the Excise Tax Act, the Ontario Sale of Goods Act, the Ontario Consumer Protection Act, 2002, and other applicable laws.

6. Legal Basis for Processing (Knowledge and Consent)

Under PIPEDA, we are required to obtain your knowledge and consent for the collection, use, or disclosure of Personal Information, except in specific circumstances permitted or required by law. We rely on the following forms of consent:

• Express consent: where you affirmatively agree (for example, by checking an opt-in box for marketing emails, or by providing your information in a quote-request form for the explicit purpose of receiving a quote);
• Implied consent: where consent can reasonably be inferred from your conduct (for example, providing your business card during a sales meeting implies consent to use that information to follow up on the meeting);
• Opt-out consent: for certain ongoing communications of similar character to those you have already received, in accordance with PIPEDA Principle 3 and the CASL implied-consent exceptions.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide certain services to you. To withdraw consent, contact our Privacy Officer using the contact information in Section 21.

7. Disclosure of Personal Information

We do not sell or rent Personal Information. We disclose Personal Information only in the following circumstances:

• To Service Providers that process information on our behalf (see Section 8), under contractual obligations to maintain confidentiality and use the information only for the purposes we specify;
• To project partners when fulfilling your project requires referral to a refrigeration repair partner, equipment finance partner, freight carrier, panel manufacturer, or refrigeration component supplier. We disclose only the minimum information necessary, and we tell you when we do so;
• To financial institutions and payment processors for the limited purpose of processing payments you make to us;
• To our professional advisors (legal counsel, accountants, auditors, insurers) under their professional duty of confidentiality, only as needed for them to advise us;
• To government authorities or law enforcement where required by law, court order, subpoena, or warrant, or where we believe in good faith that disclosure is necessary to protect our legal rights, prevent fraud, or address an imminent threat to safety;
• In connection with a business transaction: if WFE is involved in a merger, acquisition, financing, reorganization, or sale of all or part of our business or assets, Personal Information may be transferred to the counterparty subject to appropriate confidentiality protections and PIPEDA compliance. You will be notified of any such transfer that materially changes how your information is handled;
• With your express consent for any other disclosure not described above.

8. Service Providers and Sub-Processors

We rely on Service Providers to deliver parts of our operations. Each Service Provider listed below has been engaged under a written agreement that requires them to safeguard your Personal Information and use it only for the purposes we have specified. Most of these Service Providers operate servers in the United States; see Section 10 for our disclosures about cross-border data transfers.

We periodically review our Service Providers' privacy and security practices and update this list when material changes occur.

9. Cookies and Similar Technologies

A cookie is a small text file placed on your device by a website you visit. We and our Service Providers use cookies and similar technologies (web beacons, pixel tags, local storage) on the Site for the purposes described below.

You can control cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified before a cookie is set. The Site does not currently respond to Do-Not-Track signals because there is no industry standard for how such signals should be interpreted.

10. Cross-Border Data Transfers

Several of our Service Providers operate servers outside Canada, primarily in the United States. When your Personal Information is processed by a Service Provider in another country, it is subject to the laws of that country, which may permit access to that information by foreign government authorities under conditions different from Canadian law. By submitting Personal Information through the Site or by otherwise providing it to us, you acknowledge and consent to the cross-border transfer of your Personal Information to our Service Providers for the purposes described in this Policy.

We require our cross-border Service Providers, by contract, to provide a comparable level of protection to that required under PIPEDA. The Office of the Privacy Commissioner of Canada provides further guidance on cross-border transfers at priv.gc.ca.

11. Retention of Personal Information

We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected, to meet our legal and contractual obligations, and to enforce our agreements. The following retention schedule applies:

When the retention period expires, we securely delete the Personal Information or anonymize it so that it can no longer be associated with you.

12. Safeguards

We protect Personal Information with safeguards appropriate to its sensitivity, in accordance with PIPEDA Principle 7. Our safeguards include:

• Physical safeguards: locked premises, restricted access to file cabinets containing paper records, secure disposal of paper records;
• Technical safeguards: encrypted data transmission (HTTPS / TLS), encrypted database storage of sensitive fields, access controls and role-based permissions on our CRM, multi-factor authentication on administrative accounts, security patches applied promptly;
• Organizational safeguards: employee and contractor confidentiality obligations, instruction on privacy practices, contractual safeguards with Service Providers, regular review of access permissions, incident response procedures.

No system is perfectly secure, however, and we cannot guarantee absolute security of information transmitted over the internet or stored electronically. If you have reason to believe that your information has been compromised, contact our Privacy Officer immediately using the information in Section 21.

13. Your Rights Under PIPEDA

Under PIPEDA, you have the following rights with respect to your Personal Information:

• Right of access: to be informed of the existence, use, and disclosure of your Personal Information, and to be given access to that information;
• Right of correction: to challenge the accuracy and completeness of Personal Information and have it amended as appropriate;
• Right to withdraw consent: subject to legal or contractual restrictions and reasonable notice, you may withdraw consent for our ongoing collection, use, or disclosure of your Personal Information;
• Right to challenge compliance: to make a complaint about our compliance with PIPEDA to our Privacy Officer, and ultimately to the Office of the Privacy Commissioner of Canada (see Section 22).

14. How to Exercise Your Rights (Data Subject Requests)

To exercise any of the rights described in Section 13, submit a written request to our Privacy Officer using the contact information in Section 21. To allow us to respond appropriately, please:

• State clearly which right you are exercising (access, correction, withdrawal of consent);
• Provide sufficient information to identify yourself and to locate the relevant records (your full name, the approximate date(s) of your interaction with WFE, and any project or invoice numbers if applicable);
• Specify what information you are seeking, correcting, or withdrawing consent for.

We will respond to your request within 30 days of receipt, as required by PIPEDA. If we need additional time, we will notify you of the extension and the reason within the initial 30-day period. Most responses are provided without charge; if a request is unusually broad or requires significant effort to fulfill, we may charge a reasonable fee and will provide a cost estimate before proceeding.

We may decline a request in limited circumstances permitted by PIPEDA (for example, where granting access would reveal Personal Information about another individual, where the information is subject to solicitor-client privilege, or where the request is frivolous or vexatious). If we decline, we will explain the reason and inform you of your right to challenge the refusal.

To verify your identity before releasing Personal Information, we may ask you to provide reasonable proof of identity.

15. Commercial Electronic Messages (CASL)

The Canadian Anti-Spam Legislation (CASL), S.C. 2010, c. 23, regulates the sending of commercial electronic messages (CEMs) to electronic addresses in Canada. We send CEMs only where we have your express consent, your implied consent under a CASL exemption (such as an existing business relationship), or where the message itself falls outside CASL (such as transactional or warranty-related messages relating to a signed contract).

Every CEM we send identifies WFE as the sender, includes our mailing address and a working contact method, and provides a clearly visible unsubscribe mechanism that operates within 10 business days. To unsubscribe, click the unsubscribe link in any marketing email, reply to the email asking to unsubscribe, or contact our Privacy Officer directly. Unsubscribing from marketing does not stop transactional or warranty-related communications relating to a signed installation contract.

16. Children's Privacy

The Site and our services are directed at commercial operators (restaurant operators, grocery operators, food processors, florists, pharmaceutical distributors, distribution centers) and are not intended for or marketed to children. We do not knowingly collect Personal Information from individuals under the age of 18. If we learn that we have collected Personal Information from a child under 18 without verified parental consent, we will delete that information promptly. If you believe we may have collected such information, please contact our Privacy Officer.

17. Automated Decision-Making

We do not use automated decision-making (including profiling) to make decisions that have legal effects or otherwise significantly affect you. Pricing, project acceptance, financing introductions, and warranty decisions are made by our employees, not by automated systems. The 3D walk-in configurator computes geometric and refrigeration-load estimates from the inputs you provide, but those outputs are reference information only and are reviewed by our team before any quote is issued.

18. Breach Notification

In the event of a breach of security safeguards involving Personal Information that creates a real risk of significant harm to an individual, we will:

• Notify the Office of the Privacy Commissioner of Canada as soon as feasible after determining that a reportable breach has occurred, as required by PIPEDA s. 10.1;
• Notify affected individuals directly and as soon as feasible, where the breach creates a real risk of significant harm;
• Maintain a record of all breaches of security safeguards involving Personal Information under our control, as required by PIPEDA, regardless of whether the breach meets the threshold for notification;
• Take reasonable steps to contain and mitigate the breach and to prevent recurrence.

19. Residents of Quebec

We are based in Ontario and our operations are primarily directed at Ontario customers. If you are a resident of Quebec and we collect or use your Personal Information in connection with a commercial transaction, you may have additional rights under Quebec's Act respecting the protection of personal information in the private sector (Law 25, formerly Bill 64), including the right to data portability and additional disclosures regarding automated decision-making. Where Quebec law applies to our handling of your Personal Information, we will comply with its additional requirements. Contact our Privacy Officer for further information about the application of Quebec law to your specific situation.

20. Third-Party Websites and Services

The Site may contain links to third-party websites (for example, manufacturer product pages, financing partner sites, social media platforms). This Policy does not apply to those websites. Their collection and handling of your information is governed by their own privacy policies, which we encourage you to review before submitting any information to them.

21. Contact: Privacy Officer

For privacy-related inquiries, to exercise any of the rights described in Sections 13 and 14, to withdraw consent, or to submit a complaint to WFE about our handling of your Personal Information, contact:

Privacy Officer
World Food Equipment Inc.
6265 Netherhart Rd
Mississauga, ON L5T 1A2
Email: [email protected]
Phone: (289) 813-5293

22. Complaints to Regulators

If you are not satisfied with our response to a privacy complaint, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Toll-free: 1-800-282-1376
Website: priv.gc.ca

Residents of Quebec may also file complaints with the Commission d'accès à l'information du Québec.

23. Changes to This Policy

We may amend this Policy from time to time to reflect changes in our practices, our Service Provider list, or applicable law. The version number and effective date at the top of this page indicate when the Policy was last revised. For material changes that affect how we use existing Personal Information, we will provide notice through the Site or by direct communication where appropriate and, where required by PIPEDA, we will obtain your consent before applying the change to your information.

24. Accessibility

WFE is committed to providing an accessible website and accessible communications in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA). If you require this Policy in an alternate accessible format, contact our Privacy Officer using the information in Section 21 and we will provide the document in a reasonable format and at no charge.

Version 1.2 · Effective November 3, 2026 · Last reviewed November 3, 2026