Privacy Policy

The Cluō Inc. organization will collect, and process personal information from its users. This document outlines how the Cluō Inc. Organization will collect, use and safeguard personal information gathered in the course of its activities.

This Privacy Policy may be updated from time to time in order to reflect changes in our privacy practices for operational, legal or regulatory reasons. If such changes are made, notice of such will be made by posting the revised policy on the website, and where appropriate, by other means. By continuing to use this website or Services after these changes are posted will be implied agreement on the part of the user to the revised policy.


Cluō Inc. is committed to safeguarding the personal information entrusted to the organization by our service users and visitors to our website.

We manage personal information in accordance with the Freedom of Information and Protection of Privacy Act (FIPPA), Personal Information Protection and Electronic Documents Act (PIPEDA) and other laws as they apply to the Cluō Inc. Organization. This policy outlines the principles and practices Cluō Inc. follows in protecting this personal information.

This policy applies to Cluō Inc. and to any person providing services on behalf of Cluō Inc.

Collection of Personal Information

Cluō Inc. may collect information that is needed for the purposes of:

  • Continuous awareness of who is visiting our website(s)/application(s)
  • Confirming identity of users
  • Contacting users
  • Providing users with advertising and marketing
  • Invoicing users
  • Complying with legal requirements

Cluō Inc. may store and use information collected from publicly available sources to fulfill the purposes of above. Even if identified from publicly available sources, once collected by Cluō Inc., the Organization will treat this data as personal information.

Cluō Inc. will inform users before or at the time of collecting personal information, for the purposes for which Cluō Inc. is collecting the information. The only time this notification will not be provided is when a user volunteers information for an obvious purpose, such as producing a credit card; the information will be used only to process the payment.


Cluō Inc. will ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. Cluō Inc. assumes consent is implied where a user volunteers their personal information such as when registering on the website.

Cluō Inc. assumes consent to continue to use and, where applicable, disclose personal information already collected, for the purpose for which the information was collected.

If Cluō Inc. asks for express consent for some purposes, Cluō Inc. may not be able to provide certain services if the person or persons are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, Cluō Inc. will ask for consent in writing (and as required by signing a consent form).

Withdrawal of consent to the use and disclosure of personal information can be done at any time, unless the personal information is necessary for Cluō Inc. to fulfil its legal obligations. Cluō Inc. will respect the individual’s decision, but Cluō Inc. will not be able to provide the individual with Cluō Inc. program services (access to programs) if it does not have the necessary personal information. Cluō Inc. may contact persons without a previous relationship to the organization with the intent of providing information about the organization and its activities. These persons will have the right to opt out of receiving future communication by contacting

Use and Disclosure of Personal Information

Cluō Inc. uses and discloses personal information only for the purpose for which the information was collected, except as authorized by law or as expressly outlined in this policy.

Personal Employee Information

Employee refers to any employee, volunteer or contractor carrying out the purposes of the Cluō Inc. Organization.

Personal employee information is personal information about an employee or volunteer which is collected, used, or disclosed solely for the purposes of establishing, managing, terminating an employment relationship or terminating a volunteer work relationship. Personal employee information may, in some circumstances, include a Social Insurance Number, a performance review, or other like information.

Cluō Inc. can collect, use and disclose personal employee information without consent only for the purposes of establishing, managing or ending the employment or volunteer relationship. Cluō Inc. will provide current employees and volunteers with prior notice about what information is collected, used or disclosed and our purpose for doing so.

Cluō Inc. may collect, use and disclose personal employee information to meet the following purposes:

  • Determining eligibility for employment or volunteer work, including verifying qualifications and references
  • Establishing training and development requirements
  • Assessing performance and managing performance issues if they arise
  • Administering pay and benefits (paid employees only)
  • Processing employee work-related claims (e.g. benefits, workers’ compensation, insurance claims) (paid employees only)
  • Complying with applicable laws (e.g. Canada Income Tax Act, Ontario Employment Standards Code)

Employment/Volunteer References

In some cases, after an employment relationship with Cluō Inc. ends, the organization will be contacted by other organizations and asked to provide a reference. Cluō Inc. will not disclose personal information about employees to other organizations who request references without consent. The personal information normally provided in a reference includes: Confirmation that an individual was an employee, including the position, and date range of the employment. General information about an individual’s job duties and information about the employee’s ability to perform job duties and success in the employment relationship.


Cluō Inc. will make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. Cluō Inc. uses appropriate security measures when destroying personal information, including shredding paper records, and permanently deleting electronic records. Cluō Inc. retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.


Individuals have a right to access their own personal information in a record that is in the custody or under the control of Cluō Inc., subject to some exceptions.

Cluō Inc. may refuse to provide access to personal information if that access would reveal personal information about another individual.


Any questions or concerns from an individual about their personal information or this policy, or to make a complaint about how the Cluō Inc. organization processes their personal information, please contact Cluō Inc. by email at or by using the contact information below.

An individual may also request information about how Cluō Inc. uses personal information and any disclosure of that information to persons outside the Cluō Inc. organization. In addition, an individual may request a correction of an error or omission in their personal information.

An individual may request that Cluō Inc. no longer contact them. However, Cluō Inc. will continue to retain personal information in accordance with this policy.

If an individual is not satisfied with a response, and wish to file a complaint with the Information and Privacy Commission of Ontario, they should fill out the Privacy Complaint Form: ( ) This form can be submitted to the IPC Registrar who will open a complaint file and assign an intake analyst to proceed with the complaint. Forms should be sent to:

Information and Privacy Commissioner of Ontario
2 Bloor Street East,
Suite 1400 Toronto, ON

HOW TO CONTACT Cluō Inc. Cluo Inc. Office Address: 13207 Lundy's Lane, Suite 4, Niagara Falls, ON L2E 6S4 Mailing Address: PO Box 70, Wainfleet, ON L0S 1V0

(Last modified: September 22nd, 2023)