1. Who we are and what this policy covers
Klusa Holdings Inc. (“Klusa”, “we”, “us”) is an Ontario-based company that operates two divisions: Klusa Workforce (staffing and job placement) and Klusa Business Solutions (business technology setup and support).
This policy explains how we handle personal information about people who visit our website, contact us, request a quote, become our clients, or apply for work. Job applicants and the workers we employ should also read our applicant & worker privacy notice, which adds detail for them.
We follow the Personal Information Protection and Electronic Documents Act (PIPEDA) and its ten fair information principles, and Canada’s Anti-Spam Legislation (CASL) for electronic messages.
2. Accountability
We have designated a Privacy Officer who is responsible for our compliance with this policy. You can reach them at:
Privacy Officer, Klusa Holdings Inc.Klusa Holdings Inc.
Thunder Bay, Ontario, Canada
Email: [email protected]
3. Information we collect
Information you give us
- Quote requests and inquiries: your name, email, phone number, business name, community, and details about the staff or systems you need.
- Clients: billing contacts, agreements, purchase orders, invoices and communications, and the account details needed to set up or support your systems.
- Job applications: contact details, work history, skills, certifications, availability, résumé, and whether you are legally entitled to work in Canada. See the applicant notice for what we collect once you are hired.
Information collected automatically
- Analytics: pages visited, the site that referred you, and your country, browser and device type, collected by Cloudflare Web Analytics without cookies. See cookies & analytics.
- Account and sign-in records: if you have a Klusa account, your name, email, sign-in times and the IP address used. Passwords are stored only in a scrambled (hashed) form that we cannot read.
- Server and security logs: IP address, browser type, pages requested and the date and time, used to operate and protect the website.
- Cookies: essential cookies keep the website secure and keep you signed in, and your dark-mode choice is stored on your own device. See cookies & analytics.
Information from others
- References you authorize us to contact, background-check providers (only with your express consent), and clients who give feedback about work performed for them.
We do not knowingly collect information we don’t need, and we ask you not to send sensitive information (such as health information or your Social Insurance Number) through our website forms.
4. How we use information
We use personal information only for purposes a reasonable person would expect, including to:
- respond to your inquiries and prepare quotes;
- provide, manage and bill for our services;
- assess applicants and match them with suitable work;
- employ, pay and support the workers we place, and meet our obligations as their employer;
- provide customer and team accounts on our website;
- understand, in summary form, how the website is used so we can improve it;
- keep our website, systems and records secure and prevent fraud;
- meet legal, tax, employment-standards, workplace-safety and insurance requirements; and
- with your express consent, send you news and offers by email (you can unsubscribe at any time).
If we want to use your information for a new purpose, we will tell you and, where required, ask for your consent first.
5. Consent
When you submit a form or contact us, you consent to our use of your information for the purpose you contacted us about. We obtain express consent for marketing messages and for sensitive steps such as background checks.
You may withdraw consent at any time, subject to legal or contractual limits, by contacting our Privacy Officer. If you withdraw consent, we may be unable to provide some services or consider you for work.
Every marketing email we send identifies us and includes a working unsubscribe link, as CASL requires. We process unsubscribe requests within ten business days.
7. Where information is stored
We store information in Canada where practical. Some of our service providers may store or process information in other countries, including the United States, where it may be accessible to authorities under those countries’ laws. Our website is hosted on a virtual server provided by ServaRICA and delivered through Cloudflare’s global network. Our email is provided by Zoho. Website form submissions, including any résumé, are stored on that server and emailed to our Zoho mailbox. Website analytics are processed by Cloudflare.
8. How long we keep information
We keep personal information only as long as needed for the purposes above or as the law requires, and then securely delete or anonymize it. As a guide:
- Inquiries that do not lead to work: up to 24 months after our last contact.
- Client records and invoices: at least six years, as tax law requires.
- Applications from people we do not hire: up to 24 months, unless you ask us to delete them sooner.
- Payroll and employment records: for the periods required by the Employment Standards Act, 2000, the Income Tax Act and workplace-insurance rules.
9. How we protect information
We use safeguards appropriate to the sensitivity of the information, including encrypted connections (HTTPS), access limited to people who need it, strong passwords and multi-factor sign-in, and secure disposal. No method of transmission or storage is perfectly secure, but we work to protect your information and review our safeguards regularly.
If a breach of security safeguards creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as PIPEDA requires, and keep a record of the breach.
10. Your rights
You may ask to see the personal information we hold about you, ask how it has been used and shared, and ask us to correct it. Send your request to our Privacy Officer. We will respond within 30 days, or tell you if we need more time as the law allows. We may need to verify your identity first. In limited cases the law allows or requires us to refuse access, and we will explain why.
11. Young people
Our services are intended for businesses and for job seekers of legal working age in Ontario. We do not knowingly collect personal information from children.
12. Changes to this policy
We may update this policy as our services or the law change. We will post the updated version here with a new effective date and, for significant changes, take reasonable steps to let you know.
13. Questions and complaints
Please contact our Privacy Officer first. We will investigate and respond to every complaint.
Privacy Officer, Klusa Holdings Inc.Klusa Holdings Inc.
Thunder Bay, Ontario, Canada
Email: [email protected]
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.