1. Who we are

Counterwide is the registered trade name of Counterwide Partners LLC, a Florida limited liability company with its principal place of business at 1450 Ocean Boulevard, Atlantic Beach, FL 32233 (“Counterwide,” “we,” “us,” “our”).

We are an independent reseller of commerce software and payment services. We sell, configure and install Shopify’s retail commerce platform for independent retailers across Canada and the United States, and we recruit independent sales representatives to do that work in their regions. We are not Shopify, and we are not affiliated with Shopify except as an authorized partner.

Counterwide is the party responsible for the personal information described in this policy. Under Canadian law we are the organization that collects it; under United States state privacy laws we are the business or controller that determines why and how it is processed.

2. What this policy covers

This policy applies to counterwide.com and to the personal information we collect through it, by email, by phone, and in the course of evaluating a merchant enquiry or a representative application.

It does not cover:

• Shopify’s platform. Once a merchant is on Shopify, Shopify’s own privacy policy governs the data in their store, including their customers’ data. We do not control it.

• A merchant’s own customers. We have no relationship with the shoppers who buy from our merchants, and we do not receive their personal information.

• Card and payment data. Payment processing is performed by Shopify and its payment partners. We do not collect, transmit or store cardholder data, full payment card numbers, or bank account credentials.

• Other companies’ websites, including any we link to.

3. The personal information we collect

3.1 Information you give us

If you are a shop owner or business enquiring about Shopify (our “Talk to a rep” form, or by email or phone): your name, business name, email address, phone number, city, province or state, number of locations, the point of sale system you use today, whether you sell online, when you prefer to be contacted, and anything else you choose to tell us.

If you apply to become a Counterwide representative: your name, email address, phone number, city, province or state, years of business-to-business sales experience, the categories of product you have sold, whether you are subject to a non-compete or non-solicitation obligation, your availability, and the free-text description of your sales experience that you submit. If we move forward with you, we will separately collect the information needed to engage and pay an independent contractor — which may include your legal name, mailing address, business number or tax identification number, and banking details for payment. That information is collected under a separate contracting process, not through this website.

If you contact us for any other reason: whatever you include in your message.

3.2 Information collected automatically

When you visit the site we and our service providers may collect your IP address, browser and device type, operating system, referring page, the pages you view, the links you click, and the dates and times of your visits. We collect this through cookies and similar technologies. See section 8.

3.3 Information from other sources

We may receive information about you from:

• Our representatives, who may pass on notes from a conversation with you.

• Publicly available sources, such as a business website, a business directory or a professional networking profile, used to confirm that an enquiry or application is genuine.

• Referrals, where an existing merchant or representative gives us your contact details. If that happens and you would rather we did not hold them, tell us and we will delete them.

• Shopify, in connection with merchants we have introduced or boarded, limited to what Shopify shares with us as a partner.

3.4 What we do not collect

We do not knowingly collect information from children (see section 12), and we do not ask you for sensitive categories of personal information — such as government identification numbers (outside the contracting process described above), health information, biometric data, precise geolocation, racial or ethnic origin, religious beliefs, or sexual orientation — through this website. Please do not include that kind of information in a free-text field.

4. Why we use it

We do not sell your personal information. We do not share it for cross-context behavioural advertising, and we do not use it for automated decision-making that produces legal or similarly significant effects.

What we use it for

• Responding to you — Contacting you about your enquiry, arranging a time to talk, answering questions.

• Assessing fit — Working out whether Shopify suits your business, or whether your background suits a representative role.

• Routing — Connecting a merchant enquiry to the representative who covers that region.

• Delivering our service — Configuring, migrating and installing the platform for merchants who go ahead.

• Contracting and payment — Engaging representatives, and calculating and paying commissions.

• Communicating — Sending you information you have asked for or consented to receive.

• Improving the site — Understanding how the site is used and what people are looking for.

• Security and integrity — Detecting fraud, abuse, and misuse of the site or our forms.

• Legal and compliance — Meeting our tax, contractual, record-keeping and other legal obligations.

5. Our basis for using it

In Canada, we rely on your consent. You give us express consent when you submit a form or ask us to contact you. In some circumstances we rely on implied consent, or on the business contact information exemption for information such as your name, title, business address and business phone number used to communicate with you in a business capacity. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice — see section 11.

In the United States, we process personal information to provide and improve our services, to communicate with you, and for the other purposes described in section 4, consistent with applicable state privacy laws.

This site is directed to businesses and individuals in Canada and the United States. It is not directed to the European Economic Area or the United Kingdom, and we do not intentionally market to residents there.

6. Who we share it with

Service providers. We use third parties to run our business, and they receive only what they need: website hosting and form handling [FRAMER / HOST], email and productivity [PROVIDER], customer relationship management [CRM], email delivery [EMAIL PROVIDER], analytics [ANALYTICS PROVIDER], and accounting and payment processing for contractor payments [PROVIDER]. They are required to protect the information and to use it only for the services they provide to us.

Our representatives. Counterwide representatives are independent contractors running their own businesses, not employees or agents of Counterwide beyond what their written agreement provides. If you are a merchant, we will share your enquiry with the representative for your region so that they can contact you. Their agreement requires them to use your information only to serve you, to protect it, to keep it in our approved systems, and to return or delete it when their engagement ends. If you believe a representative has misused your information, tell us at [privacy@counterwide.com] and we will investigate.

Shopify. For merchants who proceed, we share the information required to set up the merchant’s account and services. Merchants contract directly with Shopify and are billed directly by Shopify, so from that point the account relationship — and the data in the merchant’s store — belongs to Shopify. Shopify’s handling of that information is governed by Shopify’s own privacy policy.

Professional advisors, such as our accountants and lawyers, where necessary.

Legal and protective disclosures. We may disclose personal information where required by law, subpoena, court order or other lawful request; to establish, exercise or defend legal claims; or to protect the rights, property or safety of Counterwide, our merchants, our representatives or the public.

Business transfer. If Counterwide is involved in a merger, acquisition, financing, reorganization or sale of assets, personal information may be transferred as part of that transaction. We will require the recipient to honour this policy or to give you notice of any material change.

7. Calls, texts and email

If you give us your phone number, you agree that Counterwide or a Counterwide representative may contact you at that number about your enquiry or application, including by text message where you have indicated that we may. Message and data rates may apply. You can stop text messages by replying STOP, and you can ask us to stop calling at any time. We maintain an internal do-not-call list and honour applicable telemarketing and do-not-call rules.

Marketing email. We will send you commercial email only where you have consented or where applicable law otherwise permits — including, in Canada, the requirements of the anti-spam legislation. Every marketing email contains an unsubscribe link and our mailing address. Unsubscribing stops marketing email; it does not stop messages about an enquiry or application you have already made.

8. Cookies and analytics

We use cookies and similar technologies to keep the site working, remember your preferences, and understand how the site is used. The categories we use are:

• Strictly necessary — required for the site and its forms to function. These cannot be turned off.

• Analytics — how visitors find and move through the site, in aggregate. [ANALYTICS PROVIDER]

• [Advertising — only if you later run paid campaigns. Delete this line if you do not.]

You can block or delete cookies through your browser settings, though parts of the site may stop working properly. Some browsers send a Global Privacy Control or Do Not Track signal; we honour the Global Privacy Control where applicable law requires it.

9. How long we keep it

Retention categories

• Merchant enquiries that do not proceed — [12–24 MONTHS] from last contact.

• Merchant records where we delivered services — Term of the relationship plus [X YEARS].

• Representative applications not taken forward — [12–24 MONTHS] from decision.

• Representative contracting, tax and commission records — As required by tax and contract law, generally [7 YEARS].

• Website analytics — [PERIOD].

We keep personal information only as long as we need it for the purposes in section 4, or as long as the law requires.

When we no longer need it, we delete it or make it anonymous.

10. How we protect it

We use administrative, technical and physical safeguards appropriate to the sensitivity of the information, including access controls limited to people who need it, encryption in transit, contractual obligations on our service providers and representatives, and a requirement that representatives not store merchant information outside our approved systems.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards occurs that creates a real risk of significant harm, we will notify affected individuals and the applicable regulators as the law requires.

11. Your rights and choices

If you are in Canada

You have the right to:

• Access the personal information we hold about you and be told how it has been used and to whom it has been disclosed.

• Correct information that is inaccurate or incomplete.

• Withdraw consent to our collection, use or disclosure, subject to legal and contractual restrictions and reasonable notice. If you withdraw consent we may no longer be able to provide the service you asked for.

• Complain to us, and — if you are not satisfied with our response — to the Office of the Privacy Commissioner of Canada or to your provincial privacy regulator, including in Quebec, British Columbia and Alberta.

If you are in the United States

Depending on your state of residence, you may have the right to:

• Know and access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties we disclose to.

• Correct inaccurate personal information.

• Delete personal information we have collected from you, subject to legal exceptions.

• Obtain a portable copy of the information you provided to us.

• Opt out of the sale or sharing of personal information and of targeted advertising. We do not sell or share personal information for these purposes, so there is nothing to opt out of — but the right is yours if that ever changes.

• Be free from discrimination for exercising any of these rights. We will not deny you services, charge you a different price, or give you a lesser level of service.

How to exercise any of these rights

Email [privacy@counterwide.com] with your request and enough information for us to find your record. We will confirm receipt and respond within the time the applicable law requires — generally 30 days in Canada and 45 days in most US states, with an extension where the law permits and we tell you.

We will take reasonable steps to verify your identity before acting on a request, and we may decline a request where the law allows — for example, where granting it would reveal someone else’s personal information or compromise a legal claim. If we decline, we will tell you why. An authorized agent may make a request on your behalf with proof of authority. If you disagree with our decision, you may ask us to reconsider it by writing to [privacy@counterwide.com], and you may complain to your regulator.

12. Children

The site is intended for businesses and for adults seeking a contractor role. It is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.

13. Where your information goes

Counterwide is based in the United States, and our service providers may store or process information in the United States, Canada or elsewhere. If you are in Canada, your personal information will be transferred to and processed in the United States, where it may be accessible to US courts, law enforcement and national security authorities under the laws of that country. We use contractual and other measures to require comparable protection wherever it is processed.

14. Other websites

The site links to third-party sites, including Shopify’s. We do not control them and we are not responsible for their privacy practices. Read their policies.

15. Changes to this policy

We may update this policy. The “last updated” date at the top will change, and if the change is material we will give you prominent notice on the site or by email before it takes effect. Continued use of the site after a change means you accept the updated policy.

16. Contact us

Counterwide Partners LLC 1450 Ocean Boulevard, Atlantic Beach, FL 32233, United States Privacy enquiries: [privacy@counterwide.com]

[If a Privacy Officer is designated, name the role here — Canadian privacy law expects an accountable individual to be identified.]