PRIVACY POLICY

1. Introduction & Commitment to Privacy

1.1 Corporate Commitment to Privacy. The Maynard Group is firmly committed to protecting the privacy, confidentiality, and security of the personal information of its Website visitors, existing clients, prospective clients, and business partners. We recognize the fundamental importance of privacy and conduct all data handling practices in strict compliance with Canada's Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 ("PIPEDA"), Canada's Anti-Spam Legislation, S.C. 2010, c. 23 ("CASL"), and all applicable laws of the Province of New Brunswick.

1.2 Purpose and Scope of This Policy. This Privacy Policy (the "Policy") explains in clear and transparent terms what Personal Information we collect, how and why that information is used, the limited circumstances under which it may be shared or disclosed, how long it is retained, the security measures we maintain to protect it, and how individuals can exercise their statutory rights regarding their Personal Information.

1.3 Corporate Accountability. In accordance with Principle 1 (Accountability) of Schedule 1 to PIPEDA, The Maynard Group is accountable for all Personal Information under its custody or control, including any Personal Information transferred to third-party service providers or subcontractors for processing or service delivery on our behalf.

1.4 Application to All Subsidiary Brands and Operating Divisions. This Policy applies universally across The Maynard Group and governs all brands, trade names, and operating subsidiaries under The Maynard Group umbrella, specifically including:

2. Definitions

2.1 Interpretation and Defined Terms. For the purposes of this Privacy Policy, the following capitalized or quoted terms shall have the meanings set forth below:

3. What Personal Information We Collect

3.1 Limiting Collection Principle. The Maynard Group limits the collection of Personal Information to that which is reasonably necessary for the purposes identified in this Policy, using fair and lawful means. Depending on how you interact with our Website and Services, we collect the following categories of information:

3.2 Information You Provide Directly. We collect Personal Information that you knowingly and voluntarily provide when interacting with us, including:

• Contact and Identity Information: Your full name, telephone number, email address, and mailing or physical service address submitted via Website contact forms, online quote requests, consultation booking forms, or general inquiry forms.
• Project Information and Visual Media: Project details, scope descriptions, room dimensions, structural or accessibility requirements, and photographs or site images that you voluntarily submit to assist us in evaluating your inquiry or preparing an estimate.
• Direct Communications: Records and copies of correspondence, call notes, and communications sent to or received from us via email, telephone (506-962-8542), or written correspondence.

3.3 Information Collected Automatically. When you visit, browse, or interact with the Website (www.maynardgroup.ca), certain technical and usage data is collected automatically via cookies, server logs, and standard web analytics tools:

• Technical and Log Information: Your Internet Protocol (IP) address, browser type and version, operating system, referring URL, specific Website pages visited, duration of page views, and the exact time and date of your visit.
• Device Information: Unique device identifiers, screen resolution, and general device category (e.g., desktop, tablet, or mobile device) used to access the Website.

3.4 Information Collected from Third Parties. We may occasionally receive your contact and project inquiry information through referrals from trusted partner contractors, trade specialists, architectural consultants, or material suppliers, strictly where you have provided your consent to such third party to share your details with us.

3.5 Exclusion of Sensitive Personal Information. We do NOT collect sensitive personal information—such as banking or financial account credentials, credit card numbers, Social Insurance Numbers (SIN), or medical and clinical health records—through the Website. Prospective and current clients should never submit sensitive financial or government identification numbers through online Website contact forms.

4. How We Use Your Personal Information

4.1 Permitted Business and Operational Purposes. The Maynard Group uses the Personal Information we collect strictly for the purposes for which it was collected, or for purposes consistent therewith, including:

• Responding to Inquiries and Estimates: To review, process, and respond to your inquiries, preliminary quote requests, site assessment bookings, or consultation requests across any of our subsidiary brands.
• Service Delivery and Contract Performance: To schedule, coordinate, manage, and deliver construction, renovation, accessibility, Murphy Wall Bed®, or tile installation Services under a formally executed written service agreement.
• Project Administration and Billing: To communicate project updates, construction schedules, material selections, site safety notices, timelines, change orders, invoicing, and warranty documentation.
• CASL-Compliant Marketing Communications: To send commercial electronic messages, newsletters, seasonal promotions, or company updates solely where express or valid implied consent has been obtained in compliance with Canada's Anti-Spam Legislation (CASL).
• Website Optimization and Analytics: To monitor, analyze, and improve Website functionality, navigation, technical performance, and overall user experience.
• Regulatory and Legal Compliance: To comply with applicable federal, provincial, and municipal legal obligations, building code recordkeeping, tax reporting, and statutory audit requirements.
• Protection of Legal Rights: To establish, exercise, enforce, or defend the legal rights, property, safety, and contractual interests of The Maynard Group, our personnel, our clients, and the public.

4.2 No Automated Decision-Making or Profiling. We do NOT use your Personal Information for automated decision-making, algorithmic credit scoring, or automated behavioural profiling.

5. Legal Basis for Collection

5.1 Lawful Grounds Under Canadian Privacy Law. Our collection, use, and disclosure of your Personal Information is grounded in the following recognized legal bases:

• Consent: Meaningful express or implied consent obtained from you at or before the point of collection (for example, when you voluntarily complete and submit a contact form or quote request on www.maynardgroup.ca, or provide your details by telephone), in accordance with Principle 3 (Consent) of PIPEDA.
• Contractual Necessity: Processing that is necessary to take pre-contractual steps at your request (such as conducting an on-site consultation) or to perform our obligations under a signed construction, renovation, or installation agreement with you.
• Legitimate Business Interests: Processing necessary for the reasonable operation, administration, and improvement of our business, maintaining Website security, preventing fraud or unauthorized access, and enforcing our Website Terms and Conditions, provided such interests do not override your fundamental privacy rights.
• Legal Obligation: Processing and retention required to comply with applicable Canadian federal or New Brunswick provincial legislation, court orders, regulatory directives, or taxation requirements.

6. Cookies & Website Tracking

6.1 Use of Cookies and Tracking Technologies. The Website (www.maynardgroup.ca) may use "cookies" (small text files placed on your computer or mobile device by your web browser) and similar tracking technologies (such as pixel tags or server log analytics) for the following specific purposes:

• Essential Website Function: Enabling core Website navigation, page rendering, security features, and reliable form submission.
• Analytics and Traffic Analysis: Collecting aggregated, non-identifying statistical data regarding Website visitor volume, traffic sources, and page engagement (using industry-standard tools such as Google Analytics or similar analytics platforms) so we can improve Website structure and content.
• Remembering User Preferences: Storing basic display or session preferences to provide a smoother browsing experience during repeat visits.

6.2 Managing and Disabling Cookies. Most web browsers automatically accept cookies by default, but you may modify your browser settings at any time to decline, block, or delete cookies. Please note, however, that disabling essential cookies may affect Website functionality and limit your ability to use certain interactive features on www.maynardgroup.ca.

6.3 No Behavioural Advertising or Cross-Site Tracking. The Maynard Group does not use cookies for third-party behavioural advertising targeting, retargeting networks, or intrusive cross-site tracking beyond standard, aggregated Website analytics.

7. Disclosure of Personal Information

7.1 Strict Prohibition on Sale of Personal Information. We do NOT sell, rent, lease, or trade your Personal Information to any third parties under any circumstances.

7.2 Permitted Disclosures to Authorized Recipients. We may share or disclose your Personal Information only in the limited circumstances set out below, and strictly to the extent required for the stated purpose:

• Service Providers and Subcontractors: Trusted third-party trade subcontractors, specialized installers, material suppliers, IT hosting providers, and administrative service providers who assist us in delivering our Services or operating our Website. All such parties are provided only with the information necessary to perform their designated functions and are bound by contractual confidentiality and data protection obligations.
• Professional Advisors: Our external legal counsel, chartered professional accountants, auditors, and commercial insurers where reasonably necessary for legal compliance, financial auditing, risk management, or the establishment and defence of legal claims.
• Government or Regulatory Bodies: Law enforcement agencies, municipal building inspectors, taxation authorities, courts of competent jurisdiction, or regulatory bodies where disclosure is required by applicable Canadian or New Brunswick law, subpoena, warrant, or court order.
• Successor Entities in Business Transactions: A prospective or actual purchaser, successor entity, or assignee in the event of a bona fide corporate merger, acquisition, amalgamation, reorganization, or sale of all or substantially all of the assets of The Maynard Group or any of its subsidiary brands, subject to statutory confidentiality restrictions.

7.3 Principle of Minimal Disclosure. In every instance, any disclosure of Personal Information is strictly limited to the minimum amount of information necessary to accomplish the specific, legitimate purpose identified in this Policy.

8. Marketing Communications & CASL Compliance

8.1 Compliance with Canada's Anti-Spam Legislation (CASL). The Maynard Group complies fully with Canada's Anti-Spam Legislation (CASL, S.C. 2010, c. 23). We will only send Commercial Electronic Messages ("CEMs")—such as company newsletters, seasonal renovation promotions, or promotional announcements—where we have obtained your prior express consent, or where valid implied consent exists under CASL (such as an existing business relationship arising from a completed project or a formal inquiry submitted within the statutory timeframe).

8.2 Right to Withdraw Marketing Consent (Opt-Out). You have the absolute right to withdraw your consent to receive marketing or promotional communications at any time, free of charge, by:

• Clicking the "Unsubscribe" link included at the bottom of any marketing email sent by The Maynard Group or any of its subsidiary brands; or
• Contacting our Privacy Officer directly using the contact details provided in Section 17 of this Policy.

8.3 Preservation of Transactional and Operational Communications. Please note that withdrawing your consent from marketing communications will be processed promptly (and in any event within ten (10) business days as required by CASL), but does not affect necessary transactional, operational, safety, or warranty communications directly related to an active quote request, ongoing construction project, or executed service agreement.

9. Data Retention

9.1 General Retention Principle. In accordance with Principle 5 (Limiting Use, Disclosure, and Retention) of PIPEDA, Personal Information is retained only for as long as reasonably necessary to fulfil the purposes for which it was collected, or as required to comply with statutory, regulatory, tax, and legal obligations.

9.2 Client Project Records (Minimum 7-Year Retention). Client project information—including client contact details, signed construction or service agreements, change orders, invoices, payment records, warranty certificates, and project completion records—is retained for a minimum of seven (7) years following project completion for structural warranty administration, statutory limitation periods, legal compliance, and Canada Revenue Agency (CRA) tax recordkeeping purposes, in accordance with New Brunswick and federal Canadian law.

9.3 Non-Client Website Inquiries (Maximum 2-Year Retention). Website inquiry information and preliminary quote request details submitted by prospective clients who do not proceed to a formal project engagement are retained for up to two (2) years from the date of last communication, unless the inquiry subsequently results in a contracted project engagement.

9.4 Secure Destruction and Anonymization. Upon the expiration of the applicable retention period, Personal Information is permanently and securely destroyed, erased from electronic systems, shredded (where held in physical form), or irreversibly anonymized so that it can no longer be associated with an identifiable individual.

10. Security of Personal Information

10.1 Administrative, Technical, and Physical Safeguards. In accordance with Principle 7 (Safeguards) of PIPEDA, The Maynard Group implements reasonable and appropriate administrative, technical, and physical safeguards designed to protect Personal Information in our custody against loss, theft, and unauthorized access, use, disclosure, copying, modification, alteration, or destruction. These safeguards include restricted role-based access controls, secure electronic storage, password protection, encrypted Website transmission (HTTPS/TLS), and physical security at our business premises.

10.2 Inherent Limitations of Electronic Transmission. Please be advised that no method of data transmission over the Internet or method of electronic storage is 100% secure or impenetrable. While we strive diligently to use commercially acceptable means to protect your Personal Information, we cannot guarantee or warrant the absolute security of any information you transmit to us over the Internet.

10.3 Mandatory Breach Notification Under PIPEDA. The Maynard Group maintains records of all security incidents in accordance with federal law. In the event of a breach of security safeguards involving Personal Information under our control where it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm ("RROSH") to an individual, we will promptly notify affected individuals and report the breach to the Office of the Privacy Commissioner of Canada as required under Division 1.1 of PIPEDA.

11. Your Rights Under PIPEDA

11.1 Statutory Privacy Rights. Under Canada's Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5), you have the following statutory rights with respect to the Personal Information that The Maynard Group holds about you:

• Right of Access: You have the right to request confirmation of whether we hold Personal Information about you, to receive access to that Personal Information, and to receive an account of how it has been used and to whom it has been disclosed.
• Right of Correction (Rectification): You have the right to challenge the accuracy and completeness of your Personal Information and to request that any demonstrated inaccuracies or omissions be promptly amended or corrected.
• Right to Withdraw Consent: You have the right to withdraw your consent to the continued collection, use, or disclosure of your Personal Information at any time, subject to applicable legal or contractual restrictions and reasonable notice.
• Right to File a Complaint: You have the right to address a challenge concerning our compliance with PIPEDA to our Privacy Officer and, if unsatisfied, to file a formal complaint with the Office of the Privacy Commissioner of Canada.

11.2 Procedure, 30-Day Response Standard, and Identity Verification. To exercise any of these rights, please submit a written request to our Privacy Officer using the contact information set forth in Section 17. We will acknowledge and respond to your written request within thirty (30) days of receipt, in accordance with Section 8(3) of PIPEDA. To protect your privacy and prevent unauthorized disclosure, we may require reasonable identity verification before processing any access, correction, or deletion request.

12. Children's Privacy

12.1 Age Restriction (18 Years and Older). The Website (www.maynardgroup.ca) and our Services are intended for adult homeowners, property managers, and commercial clients and are not directed to individuals under the age of eighteen (18). We do not knowingly solicit or collect Personal Information from minors under the age of 18.

12.2 Prompt Deletion of Minor Information. If we become aware that Personal Information of a minor under the age of 18 has been inadvertently collected through the Website without verified parental or legal guardian consent, we will take immediate steps to purge and delete such information from our records promptly.

13. Third-Party Websites

13.1 External Links Excluded from This Policy. The Website may contain hyperlinks or references to third-party websites, manufacturer portals (such as product specification pages), social media platforms, or industry directories that are not owned, operated, or controlled by The Maynard Group. This Privacy Policy applies solely to www.maynardgroup.ca and does not apply to any third-party websites.

13.2 No Liability for Third-Party Privacy Practices. We strongly encourage you to read and review the privacy policies and terms of use of every third-party website you visit after leaving our Website. The Maynard Group has no control over, and assumes no responsibility or liability whatsoever for, the content, security safeguards, cookies, or privacy practices of any third-party websites.

14. Cross-Border Data Transfers

14.1 Processing Outside New Brunswick or Canada. While The Maynard Group operates exclusively within the Province of New Brunswick, Canada, certain third-party technology service providers we engage (such as cloud website hosting providers, email servers, CRM software, or web analytics providers) may process, route, or store Personal Information on secure servers located outside of New Brunswick or outside of Canada (including in the United States).

14.2 Contractual Safeguards and Foreign Jurisdiction Access. Where Personal Information is transferred or stored outside of Canada, we ensure through contractual data protection clauses and vendor due diligence that appropriate technical and legal protections are in place to provide a comparable level of privacy protection consistent with PIPEDA requirements. While located in a foreign jurisdiction, such information may be subject to the laws of that jurisdiction and accessible to foreign courts, law enforcement, or national security authorities in accordance with local laws.

15. Changes to This Privacy Policy

15.1 Right to Amend and Update. The Maynard Group reserves the right, in its sole discretion, to amend, modify, or update this Privacy Policy at any time to reflect changes in our business operations, subsidiary brands, technological practices, or applicable Canadian privacy legislation. Any changes will be posted prominently on the Website along with a revised "Last Updated" date at the top and header of this Policy.

15.2 Acceptance Through Continued Use and Material Change Notice. We encourage you to review this Privacy Policy periodically to stay informed of how we protect your Personal Information. Your continued access to or use of the Website or our Services after any changes are posted constitutes your acknowledgement and acceptance of the updated Policy. For material changes that significantly alter how we handle previously collected Personal Information, we may also notify existing clients directly by email where we hold current contact information.

16. Accountability

16.1 Designation of Privacy Officer. The Maynard Group has designated a Privacy Officer who bears overarching responsibility for overseeing the Company's compliance with this Privacy Policy, PIPEDA, CASL, and applicable New Brunswick privacy legislation across all operating divisions and subsidiary brands.

16.2 Internal Training and Subcontractor Compliance. All employees, project managers, administrative personnel, and authorized subcontractors of The Maynard Group who have access to Personal Information in the course of their duties are informed of their strict confidentiality obligations and are required to adhere to the standards set forth in this Policy.

17. Contact Us / Privacy Officer

17.1 Contacting Our Privacy Officer. For any questions about this Privacy Policy, or to submit a formal request to access or correct your Personal Information, file a privacy inquiry or complaint, or withdraw your consent, please contact our designated Privacy Officer at:

17.2 Regulatory Escalation to the Office of the Privacy Commissioner of Canada. We are committed to resolving all privacy concerns fairly, transparently, and promptly. However, if you are not satisfied with our response to a privacy complaint or inquiry, you have the statutory right to escalate the matter to the federal privacy regulator at: