Privacy Policy

This Privacy Notice for Newrosebud (“we,” “us,” or “our”) describes how and why we access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you visit our Site, submit one of our forms to request information about debt relief or related financial services, or engage with us in marketing or communications.

If you do not agree with our policies and practices, please do not use our Services or submit your information. If you have questions, contact us at info@newrosebud.com.

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Summary of Key Points

What personal information do we process? The information you provide when you submit our forms — including your name, contact details, and information about your financial situation (such as your approximate debt level) — plus information collected automatically when you visit our sites.

Do we process sensitive personal information? Yes. Information about your debts and financial circumstances is sensitive in nature. We collect it only to match you with appropriate providers, and we handle it with a correspondingly high standard of care.

How do we process your information? To respond to your request, connect you with providers, contact you (including by phone, email, and SMS where you have consented), for security and fraud prevention, and to comply with law.

With whom do we share your information? We share and/or sell your personal information to third-party debt-relief and financial-service providers (“Buyers”) who may contact you about their services. See Section 4.

What are your rights? Under Canadian privacy law you may access, correct, and request deletion of your information, and withdraw your consent at any time. See Sections 9 and 14.

1. What Information Do We Collect?

Personal information you disclose to us

We collect the personal information you voluntarily provide when you submit a form or otherwise contact us. Depending on the form, this may include:

• Name
• Phone number
• Email address
• Postal code / province
• Information about your financial situation, such as your approximate total debt, type of debt, employment status, or similar details you choose to provide so we can match you with an appropriate provider

Sensitive information. Information about your debts and financial circumstances is sensitive. We collect it only for the matching purpose described in this notice, we limit access to it, and we apply heightened safeguards. We do not collect information about racial or ethnic origin, health, sexual orientation, or religious beliefs.

Information automatically collected

When you visit our sites we automatically collect technical information such as your IP address, browser and device characteristics, operating system, referring URLs, general location (derived from IP), and information about how you interact with our sites. This is collected through cookies and similar technologies and is used for security, analytics, and measuring the performance of our advertising.

2. How Do We Process Your Information?

We process your personal information to:

• Connect you with third-party debt-relief and financial-service providers who can offer the services you are seeking (our core purpose);
• Contact you about your request, including by phone, email, and SMS where you have provided consent;
• Respond to your inquiries and provide support;
• Operate, secure, and improve our sites and prevent fraud;
• Measure and improve the effectiveness of our advertising; and
• Comply with applicable law.

We process your information only when we have a valid legal reason to do so.

3. What Legal Bases Do We Rely On? (Canada)

We process your personal information on the basis of your consent, which may be express (for example, when you check a box or submit a form after being told your information will be shared with providers and that they may contact you) or implied where permitted by law. You can withdraw your consent at any time (see Section 9).

In limited circumstances, Canadian law permits processing without consent — for example, for fraud detection and prevention, to comply with a subpoena or court order, or where otherwise authorized under the Personal Information Protection and Electronic Documents Act (PIPEDA) or applicable provincial law.

4. When and With Whom Do We Share Your Personal Information?

• Buyers are independent third parties. Once your information is shared with a Buyer, that Buyer’s own privacy practices govern its handling of your information, and we encourage you to review their privacy policies.
• By submitting your information to us, you consent to this sharing/sale and to being contacted by the Buyer(s) by phone, email, and/or SMS.
• You can withdraw this consent at any time by contacting us (see Section 14). Withdrawal applies going forward and does not affect sharing that already occurred.

We may also share your information with service providers (hosting, CRM, call-tracking, lead-distribution, and analytics vendors) who process information on our behalf under contract; advertising and analytics partners, as described in Section 6; and in a business transfer, in connection with a merger, financing, or sale of all or part of our business.

5. Marketing Communications and Your Consent (CASL)

When you submit your information, you are providing express consent under Canada’s Anti-Spam Legislation (CASL) to receive commercial electronic messages (email and SMS) and phone calls from us and from the Buyer(s) to whom we provide your information, for the purpose of offering and providing the services you requested.

You may unsubscribe or withdraw this consent at any time — by replying STOP to an SMS, using the unsubscribe link in an email, or contacting us at info@newrosebud.com. Withdrawing consent will stop future messages from us; to stop messages from a Buyer, you may also need to contact that Buyer directly.

6. Do We Use Cookies and Other Tracking Technologies?

We use cookies and similar technologies (including web beacons and advertising pixels, such as the Meta pixel and Google Analytics) to operate and secure our sites, measure advertising performance, and understand how visitors use our sites. Some of these technologies are provided by third parties (such as Meta and Google) who may use the information they collect in accordance with their own privacy policies.

You can opt out of Google Analytics at tools.google.com/dlpage/gaoptout. Most browsers let you refuse or delete cookies, though some site features may not work as a result.

7. How Long Do We Keep Your Information?

We keep your personal information only as long as necessary for the purposes set out in this notice, including the legitimate need to document the consent you provided and the sharing of your information with Buyers, unless a longer retention period is required or permitted by law (such as tax or other legal requirements). When no longer needed, we delete or anonymize it, or securely isolate it until deletion is possible.

8. How Do We Keep Your Information Safe?

We maintain reasonable technical and organizational safeguards designed to protect your personal information. However, no method of internet transmission or storage is completely secure, and we cannot guarantee absolute security. You provide information to us at your own risk and should only use our Services in a secure environment.

9. What Are Your Privacy Rights?

Under PIPEDA and applicable provincial law, you have the right to:

• Request access to the personal information we hold about you;
• Request correction of inaccurate information;
• Request deletion of your information (subject to legal retention requirements);
• Withdraw your consent at any time — including consent to be contacted and consent to have your information shared or sold to Buyers; and
• Make a complaint to the Office of the Privacy Commissioner of Canada (priv.gc.ca) if you believe we have not handled your information appropriately.

To exercise any of these rights, contact us using the details in Section 14. Withdrawing consent does not affect the lawfulness of processing or sharing that occurred before withdrawal.

10. Do We Collect Information From Minors?

Our Services are intended only for individuals 18 years of age or older. We do not knowingly collect information from anyone under 18. If we learn we have collected such information, we will delete it promptly. If you believe we have information from a person under 18, contact us at info@newrosebud.com.

11. Controls for Do-Not-Track Features

Most browsers offer a Do-Not-Track (“DNT”) setting. Because no uniform standard for DNT has been adopted, we do not currently respond to DNT signals. If a standard is adopted, we will update this notice accordingly.

12. Do Residents of Other Regions Have Specific Rights?

Quebec. If you are a Quebec resident, you have additional rights under Quebec’s Act respecting the protection of personal information in the private sector (Law 25), including rights of access, correction, de-indexing, and the right to be informed when your information is used to render a decision based on automated processing. Contact us to exercise these rights.

Australia and New Zealand. Where we collect information from residents of Australia or New Zealand, we do so in accordance with Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. You may request access or correction, and may complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

13. Do We Make Updates to This Notice?

Yes. We will update this notice as needed and revise the “Last updated” date above. Material changes will be posted prominently. Please review this notice periodically.

14. How Can You Contact Us / Review, Update, or Delete Your Data?

To ask questions, exercise your rights, or request access to, correction of, or deletion of your personal information — or to withdraw consent — contact:

This document is a template prepared to reflect Canadian privacy-law expectations (PIPEDA, Quebec Law 25, and CASL) for a lead-generation business that shares/sells consumer information to third-party buyers. It is not legal advice. Because this operation collects sensitive financial information from consumers and distributes it to third parties, have this notice — and your on-form consent language — reviewed by a Canadian privacy/advertising lawyer before publishing.