This policy applies to all MAD Design brands, including EcoSmart Fire, Blinde Design, Heatscope and e-NRG.

At MAD Design USA (“MAD USA”, “we”, “us”), privacy means being fair, clear and transparent about how personal information is used. This Privacy Policy explains what personal information we collect when we sell products and services to customers in Canada through our websites, online stores, trade portals and customer-support channels (“Sites”), how we use it, who we share it with, how long we keep it, and the choices and rights you have under Canadian privacy law.

By using our Sites from Canada or purchasing from us while in Canada, you agree to the terms of this Privacy Policy and any applicable Terms & Conditions. If you do not agree, please do not use our Sites.

1. Who we are and how Canadian law applies

MAD Design USA is responsible for personal information collected when we sell and deliver products and services to customers in Canada via our Sites and support channels.

When we handle personal information about individuals in Canada in the course of commercial activities, we are subject to Canadian privacy laws, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA), and any substantially similar provincial private-sector privacy laws that may apply.

We are accountable for the personal information we control, including when it is processed by our service providers or transferred to other MAD Design Group companies.

2. What information we collect

We collect personal information that you provide directly, information generated by your use of our Sites, and information received from our service providers and group companies.

“Personal information” means information about an identifiable individual, including factual or subjective information such as contact details, purchase history and preferences.

2.1 Information you provide to us

Depending on how you interact with us, we may collect:

• Identity information such as your name and account username.
• Contact information such as your email address, phone number, billing address and shipping address.
• Company information such as your company name, company type and job role, particularly where you interact with us as a retailer, designer, architect or other business customer.
• Purchase and account information such as cart contents, order details, delivery details, returns, warranty records and purchase history.
• Communication information such as emails, support tickets, chat transcripts, callbacks and feedback notes.
• Preference information such as your marketing preferences, default shipping address and other settings in your account.

Payment card information is handled by our payment providers. We do not store full card numbers or security codes in our own systems.

2.2 Information we collect automatically

When you use our Sites, we may automatically collect certain information, including:

• Device and usage information such as your IP address, browser type and version, device type, operating system, pages viewed, referral URL, timestamps, session duration and similar technical details.
• Cookie and tracking information collected through cookies, pixels and similar technologies about how you browse and use our Sites.
• Clickstream data such as the sequence of pages you visit and how you navigate between them.

2.3 Aggregated and de-identified information

We may create aggregated or de-identified information from your personal information and usage data for analytics, reporting, research and improvement purposes. This information does not identify you personally.

3. How we use your information and legal basis under Canadian law

Under Canadian law, we collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances, and we generally rely on your knowledge and consent, except where otherwise permitted or required by law.

We use personal information to:

• Sell and deliver products and services to you, including processing orders, taking payment via our payment providers, managing shipping, handling returns, administering warranties and providing customer support.
• Manage accounts and business relationships, including providing account access, managing trade accounts and maintaining ongoing business relationships.
• Communicate with you, including responding to inquiries, sending service messages such as order confirmations and delivery updates, and contacting you about your account or transactions.
• Send marketing communications about products, services, promotions and events, where permitted by law and in line with your preferences. You can withdraw your consent to marketing at any time.
• Improve our Sites and services, including understanding how visitors use our Sites, improving site performance and user experience, and developing new products and services.
• Protect our business and prevent fraud, including detecting and investigating suspicious activity, misuse, fraud, security incidents and violations of our terms.
• Comply with legal and regulatory obligations, including tax, accounting, product-safety and consumer-protection requirements, and responding to lawful requests from authorities.

We may also use information for any other purpose that we describe at the time of collection or to which you consent.

We identify the purposes for collecting personal information at or before the time of collection and limit collection to what is necessary for those purposes.

4. Cookies and similar technologies

We use cookies and similar technologies to:

• make our Sites work properly;
• remember your preferences;
• help you stay signed in;
• understand how our Sites are used; and
• support analytics and marketing.

Where required by law, we obtain your consent to the use of non-essential cookies and similar technologies. You can control cookies through your browser settings and, where available, through our cookie banner or preference tools. If you disable cookies, some features of our Sites may not work as intended.

For more information, please see our Cookie Policy, where available.

5. AI-assisted chat and support

We use chat and support tools, including Intercom and AI assistants such as Fin, to help answer common questions and support customers more efficiently.

When you use our chat tool, you may be interacting with an AI assistant. The AI assistant may summarise your messages, suggest answers and help direct your enquiry to the right team. You can ask to speak to a human at any time.

Where a proposed outcome could materially affect you, such as a refund, cancellation or warranty decision, a human team member reviews and confirms the outcome before it is communicated or applied.

Intercom workspace data, including contacts and conversations, is retained while the workspace remains active unless deleted by us through the platform's tools. The AI assistant's internal memory may retain recent messages and summaries for a limited period, after which that memory is automatically cleared.

We do not use AI to make solely automated decisions that produce legal or similarly significant effects on you without meaningful human involvement.

6. Analytics and advertising

We use third-party analytics and advertising services such as Google Analytics, Google Ads and Meta (for example, Facebook, Instagram and related tools) to understand how our Sites are used and to deliver and measure advertising. These services may collect information about your use of our Sites over time and across different websites and apps.

We do not sell your personal information. We may allow these providers to collect identifiers (such as cookie IDs, IP address and device identifiers), internet or other electronic network activity information (such as page views, clicks and browsing actions) and approximate location information from your browser or device via cookies, pixels and similar technologies.

You can limit how Google and Meta use information for personalised ads by using their own tools, such as Google's ad settings and Meta's ad preferences, and by using browser or platform settings to limit tracking.

If you disable or block cookies in your browser, or adjust your mobile-device settings to limit ad tracking, some features of our Sites may not work properly.

7. How we share information

We do not sell your personal information.

We may disclose personal information to:

• Other MAD Design Group companies, as needed for support, logistics, operations, analytics and customer service.
• Service providers, including third-party companies that provide services on our behalf such as hosting, payments, logistics, customer support, communications, analytics, advertising, consent management and security. These service providers are only allowed to use personal information to provide services to us and must protect it with appropriate safeguards.
• Business partners where we jointly offer products or services or run joint promotions, in line with applicable law and your choices.
• Law-enforcement agencies, regulators, courts or other parties where we believe it is necessary to comply with laws or legal processes, respond to lawful requests, protect our rights, property or safety or the rights, property or safety of others, or detect and prevent fraud or security issues.
• Actual or potential buyers (and their advisers) in connection with a merger, acquisition, restructuring, financing or sale of all or part of our business, subject to appropriate protections.

We may share aggregated or de-identified information that does not identify you with third parties for analytics, research, marketing and similar purposes.

When we transfer personal information to service providers or other MAD Design Group companies, we remain responsible for that information and require appropriate contractual and technical safeguards, consistent with Canadian accountability principles.

8. Cross-border transfers of Canadian personal information

As a US-based company, we may transfer, store and process your personal information in the United States and other countries where our service providers and group companies are located.

When your personal information is transferred outside of Canada, it may be subject to the laws of the foreign jurisdiction, including access by courts, law-enforcement and national-security authorities in those jurisdictions.

We take steps to ensure that the personal information we handle on behalf of individuals in Canada is adequately protected when transferred outside Canada, including through contracts with service providers that require appropriate safeguards and restrict the use of personal information to specified purposes.

If you have questions about our cross-border practices or would like more information about how we protect your personal information when it is transferred outside Canada, you can contact us using the details below.

9. How we protect information

We use appropriate physical, technical and administrative measures to help protect personal information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access, taking into account the sensitivity of the information.

However, no website, internet transmission or storage system can be guaranteed to be completely secure. You use our Sites and provide information at your own risk.

10. Children's privacy

Our Sites are intended for adults and are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete it.

If you are between 13 and the age of majority in your province or territory, you should use our Sites only with the permission of a parent or legal guardian.

11. Retention of personal information

We keep personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy and to comply with our legal, accounting and reporting obligations, unless a longer retention period is required or permitted by law.

In deciding how long to keep information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.

In general, we keep order, tax and warranty records for at least the period required by tax and consumer laws; customer-service records for the period we reasonably need to manage our relationship with you and handle complaints or disputes; and marketing information for as long as you remain subscribed to our marketing and for a reasonable period afterwards to manage your preferences and demonstrate compliance.

When personal information is no longer required, we securely destroy, delete or anonymise it, consistent with our legal obligations and retention policies.

12. Your rights and choices under Canadian law

Subject to certain exceptions and limits under Canadian law, you have the right to:

• Request access to your personal information, including an explanation of how we have used and disclosed it.
• Request corrections to your personal information if you believe it is inaccurate or incomplete.
• Withdraw your consent to our use of your personal information for certain purposes, such as marketing, where we rely on consent, subject to legal or contractual restrictions and reasonable notice.
• Ask questions or challenge our compliance with applicable Canadian privacy laws.

To exercise these rights or to request more information, you can contact us using the details in the “Contact us and complaints (Canada)” section below. We may need to verify your identity before responding to your request.

We will respond to your request within a reasonable time and in accordance with applicable law. In some cases, we may refuse a request where permitted or required by law, for example where disclosure could reveal personal information about someone else, where the information is subject to legal privilege or where we are restricted by law or court order. If we refuse a request, we will explain the reasons, subject to legal limitations.

You can opt out of marketing emails at any time by using the “unsubscribe” link in those emails or by contacting us.

13. Links to other websites

Our Sites may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those sites. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on our Sites and update the “Last updated” date at the top.

If we make material changes, we may also notify you by email or through other reasonable means. Your continued use of our Sites after the updated Privacy Policy is posted means that you accept the changes.

15. Contact us and complaints (Canada)

If you have any questions, concerns or requests regarding this Privacy Policy or our handling of personal information, please contact:

MAD Design USA

Attn: Privacy Officer

info@mad-usa.com

311 North Robertson Blvd, PMB 932

Beverly Hills, CA 90211

If you are not satisfied with our response or how we handle your personal information, you may have the right to contact the Office of the Privacy Commissioner of Canada or your provincial or territorial privacy commissioner. Information about how to do so is available on the Office of the Privacy Commissioner of Canada's website.