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Legal Policy Second Alarm Media — Website Legal Policies # Privacy Policy **Effective date:** [Month Day, Year] **Last updated:** [Month Day, Year] Second Alarm Media ("Second Alarm Media," "we," "us," or "our") is an Ontario, Canada sole proprietorship that provides lead-generation and marketing services to business clients. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit [WEBSITE URL], submit an inquiry or lead form, communicate with us, or otherwise interact with our services. ## 1. Accountability and contact information Second Alarm Media is responsible for personal information under its control. Our Privacy Officer handles questions, access or correction requests, withdrawals of consent, and privacy complaints. **Privacy Officer** Second Alarm Media [BUSINESS/Mailing ADDRESS] [CITY], Ontario [POSTAL CODE], Canada Email: [PRIVACY EMAIL] Telephone: [PHONE NUMBER, IF OFFERED] ## 2. Personal information we collect Depending on how you interact with us, we may collect: - **Lead and inquiry information:** name, email address, telephone number, postal code or service location, preferred contact method, requested service, timing, budget range, project details, qualification answers, and information you choose to provide. - **Business-client information:** name, title, company name, business contact details, campaign preferences, account information, communications, agreements, invoices, payment status, and lead feedback. - **Website and device information:** IP address, browser and device type, operating system, referring page, pages viewed, dates and times, approximate location derived from IP address, cookie identifiers, advertising identifiers, and interactions with our website and advertisements. - **Communications and records:** emails, calls, text messages, form submissions, support requests, consent records, and notes about our interactions. We will give any notice or obtain any consent required by law before recording calls. - **Payment information:** billing address and transaction details. Payment-card information may be collected directly by our payment processor rather than stored by us. - **Information from other sources:** information supplied by our business clients, referral partners, advertising platforms, lead vendors, data providers, public sources, and service providers, where permitted by law. We require the party supplying personal information to have authority to collect it and disclose it to us for the stated purpose. Please do not provide sensitive personal information unless a form specifically asks for it and explains why it is needed. ## 3. How we collect information We collect information: - directly from you through websites, landing pages, advertisements, forms, calls, emails, text messages, and other communications; - automatically through cookies and similar technologies; - from business clients and service providers acting for us; - from referral partners, publishers, advertising platforms, and lead suppliers; and - from public or other lawful sources. When a form is operated for a particular advertiser or service provider, the form notice should identify that business or clearly describe the category and number of businesses that may receive the information. The notice shown at the point of collection forms part of this Privacy Policy. ## 4. Why we use personal information We may use personal information to: - receive, review, verify, qualify, route, and deliver inquiries or leads; - match an individual with one or more businesses that offer the requested product or service; - permit the selected business or businesses to contact the individual about the request; - operate, personalize, secure, troubleshoot, and improve our website, forms, advertising, campaigns, and services; - detect duplicate, inaccurate, fraudulent, or invalid submissions; - communicate about requests, accounts, campaigns, transactions, service updates, and support; - measure campaign performance, attribution, lead quality, and conversion; - manage client relationships, contracts, billing, collections, records, and disputes; - send marketing communications where we have the consent or other authority required by law; - comply with law, enforce agreements, establish or defend legal claims, and prevent harm or misuse; and - create aggregated or de-identified information that does not identify an individual. We will not use personal information for a new purpose unless that purpose is permitted by law or we obtain any consent required by law. ## 5. Consent and lead sharing We seek meaningful consent in a form appropriate to the sensitivity of the information and the reasonable expectations of the individual, except where law permits collection, use, or disclosure without consent. If you submit a request for a product or service, we may disclose the information identified in the form notice to the business or businesses described in that notice so they can assess and respond to your request. Those businesses are independent organizations and are responsible for their own privacy practices after receiving the information. Review their privacy policies and ask them questions before providing additional information. A general link to this Privacy Policy does not replace a clear disclosure at the point where lead information is collected. Our lead forms should state, before submission, what information will be shared, why it will be shared, who will receive it (by name or a sufficiently specific description), and that the recipient may contact the individual. Where information comes from a business client, vendor, referral partner, or other third party, we rely on that party's representation that it has given all required notices and obtained all required consents or other lawful authority. We may also perform reasonable consent and source checks. You may withdraw consent, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawal will not affect processing already lawfully completed and may prevent us from providing a requested service. ## 6. When we disclose personal information We may disclose personal information: - to business clients and service providers that match the request, as described at the point of collection; - to vendors that host websites or data, operate customer-relationship systems, send communications, process payments, provide analytics or advertising services, prevent fraud, or otherwise process information for us; - to professional advisers, insurers, auditors, and collection agencies where reasonably necessary; - in connection with a proposed or completed financing, sale, transfer, reorganization, or other transaction involving all or part of our business, subject to appropriate protections; - to law-enforcement, regulators, courts, government authorities, or other parties when required or permitted by law; and - where necessary to protect rights, safety, property, or the integrity of our services. We do not disclose personal information to an unrelated business for its own marketing unless the individual was clearly told about that disclosure and we have the consent or other legal authority required. ## 7. Service providers and processing outside Canada Our service providers may process or store personal information in Canada, the United States, or other countries. Information processed outside Canada may be subject to the laws of that jurisdiction and may be accessible to its courts, law-enforcement, or national-security authorities. We use contractual or other measures designed to require service providers to protect information and use it only for authorized purposes. Contact our Privacy Officer for information about our service providers or our policies concerning processing outside Canada. ## 8. Cookies, analytics, and advertising We and our service providers may use cookies, pixels, tags, local storage, and similar technologies to operate the website, remember preferences, measure traffic and campaign performance, prevent fraud, and deliver or measure advertising. You can adjust browser settings to block or delete cookies. You may also use the opt-out tools offered by applicable advertising and analytics providers. Blocking some technologies may affect website functionality. Where required, we will obtain consent before using non-essential cookies or similar technologies. **Website-specific services to list before publication:** [e.g., Google Analytics, Meta Pixel, Google Ads, call-tracking provider, CRM, scheduling tool, chat widget, payment processor]. ## 9. Marketing communications We send commercial electronic messages only where permitted by Canada's anti-spam law or other applicable law. Our messages will identify the sender and include a working unsubscribe method where required. You may unsubscribe using the link or instructions in a message or by contacting [MARKETING/PRIVACY EMAIL]. We may still send non-promotional messages necessary to respond to a request, administer an account, or complete a transaction. ## 10. Retention We retain personal information only as long as reasonably necessary for the purposes described in this Policy, to satisfy legal, tax, accounting, fraud-prevention, and contractual requirements, and to resolve disputes. Our retention periods depend on the type and sensitivity of information and the reason it is held. Unless a longer period is required or justified, our target retention periods are: - lead and consent records: [INSERT PERIOD, e.g., 24 months after the last activity]; - client contracts, invoices, and transaction records: [INSERT PERIOD, commonly at least six years where required for tax/business records]; - routine website analytics: [INSERT PERIOD]; and - privacy and security-incident records: as required by law. When information is no longer required, we securely delete, destroy, or de-identify it. ## 11. Safeguards and security incidents We use administrative, technical, and physical safeguards appropriate to the sensitivity and amount of information, including access controls, vendor controls, staff practices, and secure disposal. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We assess suspected privacy breaches and, where required by law, notify affected individuals and report the breach to the appropriate regulator. We maintain breach records as required by applicable law. ## 12. Access, correction, and privacy complaints You may request access to personal information we hold about you, ask how it has been used or disclosed, and request correction of inaccurate or incomplete information. We may need to verify your identity. Access may be limited by exceptions under applicable law, and we will explain any refusal as required. To make a request or complaint, contact our Privacy Officer using the details in section 1. We will investigate and respond within the time required by law. If you are not satisfied, you may contact the Office of the Privacy Commissioner of Canada at [www.priv.gc.ca](https://www.priv.gc.ca/). ## 13. Children Our website and services are intended for adults and businesses, not children under 18. We do not knowingly collect personal information from children for lead-generation purposes. Contact us if you believe a child has provided information to us. ## 14. Third-party websites Our website may link to third-party websites or services. We do not control and are not responsible for their content, security, or privacy practices. Review the applicable third party's policies. ## 15. Changes to this Privacy Policy We may update this Policy from time to time. We will post the revised version with a new "Last updated" date and provide any additional notice or seek consent where required by law. Material changes apply prospectively unless otherwise permitted by law. --- # Terms and Conditions **Effective date:** [Month Day, Year] These Terms and Conditions ("Terms") are an agreement between Second Alarm Media, an Ontario sole proprietorship ("Second Alarm Media," "we," "us," or "our"), and the person or entity accessing [WEBSITE URL] or purchasing our services ("you" or "Client"). By using the website, submitting an order, signing an order form, or purchasing services, you agree to these Terms. **Business use only.** Our paid marketing and lead services are offered only to persons acting for business purposes, not for personal, family, or household purposes. If you accept for an organization, you represent that you have authority to bind it. ## 1. Contract documents and priority The agreement consists of these Terms and any signed proposal, insertion order, campaign order, statement of work, or other order document that incorporates them (each, an "Order"). If there is a conflict, the Order controls for that campaign, followed by these Terms. The Privacy Policy governs our handling of personal information. ## 2. Website use You may use the website only for lawful purposes. You must not: - interfere with the website's security, operation, or networks; - attempt unauthorized access, introduce malware, scrape or harvest data without permission, or evade access controls; - impersonate another person or submit false, misleading, or unauthorized information; - infringe intellectual-property, privacy, publicity, or other rights; or - use the website or information obtained from it for unlawful, deceptive, discriminatory, abusive, or unsolicited marketing. We may restrict or suspend access to protect the website, users, or our rights. ## 3. Services and campaign criteria We provide marketing, advertising, lead-generation, lead-qualification, and lead-delivery services described in an Order. Each Order should specify the campaign, territory, channels, budget or retainer, price per lead, volume target or cap, delivery method, start date, and the objective criteria a submission must meet to be a "Qualified Lead." A lead is a Qualified Lead only if it materially meets the criteria in the applicable Order at the time of delivery. Unless the Order expressly states otherwise, a Qualified Lead is not a promise that the person will answer, book an appointment, qualify for financing, purchase, remain interested, or generate revenue. Volume estimates, projections, conversion rates, and timelines are estimates, not guarantees. We may reasonably adjust campaign tactics, channels, creative, or targeting while remaining within the Order. ## 4. Client responsibilities The Client will: - provide complete, accurate, current information, campaign criteria, approvals, and materials on time; - ensure its products, services, claims, licences, offers, landing pages, and follow-up practices comply with law and industry rules; - use lead information only to respond to the request and for purposes disclosed when the information was collected; - contact leads promptly, professionally, and only through lawful methods; - honour opt-outs, do-not-call requests, consent withdrawals, and privacy rights; - maintain appropriate privacy, security, and record-management practices; - not sell, transfer, enrich, or disclose lead information to another party unless the collection notice, applicable law, and the Order permit it; - not use lead information for eligibility decisions, background checks, or other sensitive purposes unless expressly authorized and legally compliant; and - promptly tell us about complaints, regulator inquiries, suspected unauthorized use, security incidents, or inaccurate campaign claims. The Client is independently responsible for its communications and relationship with each lead after delivery. ## 5. Client materials and approvals The Client retains ownership of materials it supplies. The Client grants us a non-exclusive, worldwide, royalty-free licence during the agreement to use, reproduce, adapt, display, and distribute those materials as necessary to perform the services. The Client represents that it has all rights and permissions needed for the materials and instructions it provides and that they are accurate and lawful. Client approval of creative, offers, targeting, forms, or scripts confirms their accuracy and authorization. We may reject or remove content that we reasonably believe is unlawful, misleading, infringing, unsafe, or inconsistent with platform rules. ## 6. Fees, invoices, taxes, and advertising costs The Client will pay the retainer, per-lead charges, setup fees, advertising spend, platform costs, and other fees stated in the Order. Unless the Order states otherwise: - retainers and setup fees are billed in advance and are non-refundable once the applicable service period or setup work begins; - lead charges are invoiced [WEEKLY/MONTHLY/ON DELIVERY]; - invoices are due within [7/15/30] calendar days; - fees are in Canadian dollars and exclude applicable taxes; - the Client authorizes recurring charges to an approved payment method for amounts due; and - overdue amounts accrue interest at the lesser of [1.5% per month (18% annually)] and the maximum lawful rate, plus reasonable collection costs. We may pause campaigns or lead delivery while an invoice is overdue. A pause does not waive amounts already earned or committed third-party costs. Advertising spend and third-party costs are non-refundable once incurred or committed. ## 7. Lead review and credits The Client must review each lead promptly. To request a credit, the Client must provide written notice within **five (5) business days** after delivery, identify the lead, state the specific campaign criterion not met, and provide reasonable supporting information. Unless an Order states otherwise, a lead may qualify for a credit only if, at delivery, it: - contained materially false or unusable contact information; - was a duplicate delivered by us to the same Client for the same campaign within the previous [90] days; - was outside the agreed geography; - requested a materially different service; or - failed another express, objective Qualified Lead criterion in the Order. A lead is not invalid merely because the person does not answer, changes their mind, does not purchase, does not meet an unstated preference, was also contacted by another business where the Order permits non-exclusive leads, or produces no revenue. We will reasonably investigate timely requests. Approved credits are applied to a future invoice or replacement lead and are not cash refunds unless the Order states otherwise. Failure to dispute within the review period constitutes acceptance, except in the case of our fraud or wilful misconduct. Lead credits are the Client's exclusive remedy for an individual lead that fails the agreed criteria. ## 8. Exclusive and non-exclusive leads Leads are non-exclusive unless an Order expressly labels them exclusive. "Exclusive" means we will not intentionally sell or deliver that same lead to another client for the same campaign category during the exclusivity period stated in the Order. It does not mean that the person has not independently contacted another provider or appeared through another source. ## 9. Term, renewal, suspension, and termination These Terms apply while you use the website. A service engagement begins and continues for the term stated in the Order. If no term is stated, it continues month to month until either party gives at least **30 days' written notice**. Either party may terminate an Order for a material breach not cured within 10 days after written notice. We may suspend or terminate immediately for unlawful or deceptive activity, misuse of lead data, a security risk, platform-policy violations, non-payment, or conduct likely to harm a person, our reputation, or our legal compliance. On termination, the Client must pay fees earned, leads delivered, advertising spend, non-cancellable commitments, and taxes through the effective termination date. Prepaid amounts are non-refundable except for services we do not provide after a termination caused solely by our uncured material breach. Sections that by their nature should survive will survive, including payment, intellectual property, confidentiality, privacy, disclaimers, indemnity, liability limits, and dispute terms. ## 10. Confidentiality Each party may receive non-public business, technical, pricing, campaign, or customer information of the other ("Confidential Information"). The receiving party will use it only for the agreement and protect it with reasonable care. It may disclose Confidential Information to personnel and service providers who need it and are bound by confidentiality duties. Confidential Information excludes information that the receiving party can show was lawfully known without restriction, becomes public without breach, is received lawfully from another source, or is independently developed. Required legal disclosures are permitted after advance notice where lawful and practical. ## 11. Privacy and data protection Each party will comply with privacy, anti-spam, telemarketing, consumer-protection, and other laws applicable to its activities. Each party acts as an independent organization responsible for personal information under its control, except to the extent an Order expressly states that one party processes information only on the other's instructions. The Client will use lead information only within the scope of the consent and collection notice associated with that lead. On request, the Client will reasonably assist us in addressing consent questions, privacy requests, complaints, and security incidents. If either party becomes aware of unauthorized access to or use of shared personal information, it will notify the other without unreasonable delay and cooperate on legally required action. ## 12. Intellectual property We and our licensors retain ownership of the website, software, methods, templates, know-how, campaign structures, reports, and materials we create or owned before the engagement ("Second Alarm Materials"). After full payment, the Client may use final campaign deliverables created specifically for it for its internal business and marketing purposes, subject to third-party licence terms and any different terms in the Order. No ownership in Second Alarm Materials transfers unless an Order expressly says so. Feedback may be used by us without restriction or compensation, provided we do not publicly identify the Client without permission. ## 13. Third-party platforms and services Campaigns may depend on advertising networks, telecommunications carriers, hosting providers, analytics tools, payment processors, and other third parties. Their terms, policies, pricing, algorithms, availability, and decisions are outside our control. We are not responsible for a third party's suspension, rejection, outage, policy change, data loss, or performance, but we will use commercially reasonable efforts to manage services within our control. ## 14. Disclaimers To the maximum extent permitted by law, the website, leads, and services are provided "as is" and "as available." We disclaim implied warranties and conditions of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted or error-free operation. We do not guarantee lead volume, exclusivity unless expressly purchased, contactability, conversion, revenue, profitability, platform approval, ranking, or any particular business outcome. Nothing on the website is legal, financial, or other professional advice. ## 15. Limitation of liability To the maximum extent permitted by law, neither party will be liable for indirect, incidental, special, exemplary, punitive, or consequential damages, or for lost profits, revenue, business, goodwill, anticipated savings, or data, arising from the agreement, even if advised of the possibility. To the maximum extent permitted by law, Second Alarm Media's total aggregate liability arising from an Order or these Terms will not exceed the fees paid or payable to Second Alarm Media under the affected Order during the three (3) months immediately before the event giving rise to the claim. The exclusions and cap do not apply where liability cannot lawfully be excluded or limited. [LAWYER REVIEW: consider negotiated carve-outs for confidentiality, privacy/security, infringement, fraud, wilful misconduct, payment obligations, and indemnity.] ## 16. Indemnity The Client will defend, indemnify, and hold harmless Second Alarm Media and its owner, personnel, and contractors from third-party claims, losses, damages, penalties, and reasonable legal costs arising from: (a) Client materials, products, services, claims, or instructions; (b) the Client's contact with or use of information about a lead; (c) breach of sections 4, 5, 10, or 11; or (d) the Client's violation of law or third-party rights. We will promptly notify the Client of a covered claim and provide reasonable cooperation at the Client's expense. The Client may control the defence but may not settle in a way that admits our fault, imposes obligations on us, or fails to fully release us without our written consent. ## 17. Governing law and disputes These Terms and each Order are governed by the laws of Ontario and the federal laws of Canada applicable there, without regard to conflict-of-law rules. The parties irrevocably submit to the exclusive jurisdiction of the courts located in [CITY/REGION], Ontario. Before starting a court proceeding, a party will give written notice describing the dispute, and authorized representatives will attempt in good faith to resolve it for at least 15 days. Either party may seek urgent injunctive relief where appropriate. ## 18. Changes to these Terms We may update the website-use provisions by posting revised Terms with a new effective date. Changes to an active Order will not apply retroactively and will take effect only as permitted by the Order or with the Client's agreement. Continued website use after posted changes means acceptance of the revised website-use provisions. ## 19. General terms Neither party may assign an Order without the other's consent, except that we may assign it in connection with a sale or reorganization of our business. We may use subcontractors but remain responsible for our obligations. The parties are independent contractors. These Terms do not create a partnership, joint venture, fiduciary, franchise, employment, or agency relationship. Neither party may bind the other. Notices concerning an Order must be in writing and sent to the contact listed in the Order. Notices to Second Alarm Media must also be sent to [LEGAL NOTICE EMAIL]. Email notice is effective when received, excluding automated delivery failures. If a provision is unenforceable, it will be limited to the minimum extent necessary and the remainder will continue. A waiver must be in writing and applies only to the specific instance. Headings are for convenience. "Including" means "including without limitation." These Terms and each Order are the entire agreement about their subject matter and replace prior discussions or communications. ## 20. Contact Second Alarm Media [BUSINESS/Mailing ADDRESS] [CITY], Ontario [POSTAL CODE], Canada Email: [GENERAL/LEGAL EMAIL] Website: [WEBSITE URL] --- # Lead-Form Consent Notice Place this notice immediately beside the form's submit button. Do not pre-check an optional marketing box. Tailor the recipient description to the actual campaign; name the recipient where practical. ## Option A — One identified service provider > By clicking **[SUBMIT BUTTON TEXT]**, you agree that Second Alarm Media may collect and use the information you provide to assess your request and share it with **[CLIENT LEGAL/BUSINESS NAME]**, which may contact you by telephone, email, or text about **[REQUESTED SERVICE]**. Consent is not a condition of purchase. Message and data rates may apply. You may withdraw consent at any time. See our [Privacy Policy] and [CLIENT NAME's Privacy Policy]. ## Option B — A small number of matched providers > By clicking **[SUBMIT BUTTON TEXT]**, you agree that Second Alarm Media may collect and use the information you provide to assess your request and share it with up to **[NUMBER] [TYPE OF SERVICE] providers serving [LOCATION]**, which may contact you by telephone, email, or text about your request. Consent is not a condition of purchase. Message and data rates may apply. You may withdraw consent at any time. See our [Privacy Policy] and the identity of participating providers [LINK OR DISCLOSURE METHOD]. ## Separate optional marketing checkbox > ☐ I agree to receive promotional emails and/or text messages from Second Alarm Media about [DESCRIBE CONTENT]. I can unsubscribe at any time. Contact: [MAILING ADDRESS], [EMAIL], [WEBSITE]. Keep evidence of the exact notice, date and time, page URL, source, information submitted, recipient(s), and affirmative action associated with each lead. --- # Publication Checklist 1. Replace every **[square-bracketed item]** and remove all drafting notes. 2. Put the Privacy Policy and Terms on separate, permanently accessible website pages and link them in the footer and each relevant form. 3. Add the tailored lead-form notice next to every submit button; identify or narrowly describe recipients and the maximum number of businesses receiving the lead. 4. Inventory every cookie, pixel, analytics tool, call tracker, CRM, form provider, payment provider, and advertising platform, then make section 8 accurate. 5. Set and follow real retention periods. Maintain security-incident records and an access/correction request process. 6. Use a signed Order for every client stating price, retainer, ad spend, lead criteria, territory, exclusivity, caps, billing timing, dispute window, term, and cancellation rights. 7. Obtain source and consent warranties from lead vendors; periodically audit sample consent records. Do not rely on a contractual warranty where the collection notice is visibly inadequate. 8. Ensure client agreements restrict use, resale, disclosure, retention, and security of lead data. 9. Configure commercial messages with sender identification, contact information, and a functioning unsubscribe process, and maintain consent/suppression records. 10. Obtain Ontario legal review before publication and before running campaigns in regulated or sensitive sectors.Legal Policy Second Alarm Media — Website Legal Policies # Privacy Policy **Effective date:** [Month Day, Year] **Last updated:** [Month Day, Year] Second Alarm Media ("Second Alarm Media," "we," "us," or "our") is an Ontario, Canada sole proprietorship that provides lead-generation and marketing services to business clients. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit [WEBSITE URL], submit an inquiry or lead form, communicate with us, or otherwise interact with our services. ## 1. Accountability and contact information Second Alarm Media is responsible for personal information under its control. Our Privacy Officer handles questions, access or correction requests, withdrawals of consent, and privacy complaints. **Privacy Officer** Second Alarm Media [BUSINESS/Mailing ADDRESS] [CITY], Ontario [POSTAL CODE], Canada Email: [PRIVACY EMAIL] Telephone: [PHONE NUMBER, IF OFFERED] ## 2. Personal information we collect Depending on how you interact with us, we may collect: - **Lead and inquiry information:** name, email address, telephone number, postal code or service location, preferred contact method, requested service, timing, budget range, project details, qualification answers, and information you choose to provide. - **Business-client information:** name, title, company name, business contact details, campaign preferences, account information, communications, agreements, invoices, payment status, and lead feedback. - **Website and device information:** IP address, browser and device type, operating system, referring page, pages viewed, dates and times, approximate location derived from IP address, cookie identifiers, advertising identifiers, and interactions with our website and advertisements. - **Communications and records:** emails, calls, text messages, form submissions, support requests, consent records, and notes about our interactions. We will give any notice or obtain any consent required by law before recording calls. - **Payment information:** billing address and transaction details. Payment-card information may be collected directly by our payment processor rather than stored by us. - **Information from other sources:** information supplied by our business clients, referral partners, advertising platforms, lead vendors, data providers, public sources, and service providers, where permitted by law. We require the party supplying personal information to have authority to collect it and disclose it to us for the stated purpose. Please do not provide sensitive personal information unless a form specifically asks for it and explains why it is needed. ## 3. How we collect information We collect information: - directly from you through websites, landing pages, advertisements, forms, calls, emails, text messages, and other communications; - automatically through cookies and similar technologies; - from business clients and service providers acting for us; - from referral partners, publishers, advertising platforms, and lead suppliers; and - from public or other lawful sources. When a form is operated for a particular advertiser or service provider, the form notice should identify that business or clearly describe the category and number of businesses that may receive the information. The notice shown at the point of collection forms part of this Privacy Policy. ## 4. Why we use personal information We may use personal information to: - receive, review, verify, qualify, route, and deliver inquiries or leads; - match an individual with one or more businesses that offer the requested product or service; - permit the selected business or businesses to contact the individual about the request; - operate, personalize, secure, troubleshoot, and improve our website, forms, advertising, campaigns, and services; - detect duplicate, inaccurate, fraudulent, or invalid submissions; - communicate about requests, accounts, campaigns, transactions, service updates, and support; - measure campaign performance, attribution, lead quality, and conversion; - manage client relationships, contracts, billing, collections, records, and disputes; - send marketing communications where we have the consent or other authority required by law; - comply with law, enforce agreements, establish or defend legal claims, and prevent harm or misuse; and - create aggregated or de-identified information that does not identify an individual. We will not use personal information for a new purpose unless that purpose is permitted by law or we obtain any consent required by law. ## 5. Consent and lead sharing We seek meaningful consent in a form appropriate to the sensitivity of the information and the reasonable expectations of the individual, except where law permits collection, use, or disclosure without consent. If you submit a request for a product or service, we may disclose the information identified in the form notice to the business or businesses described in that notice so they can assess and respond to your request. Those businesses are independent organizations and are responsible for their own privacy practices after receiving the information. Review their privacy policies and ask them questions before providing additional information. A general link to this Privacy Policy does not replace a clear disclosure at the point where lead information is collected. Our lead forms should state, before submission, what information will be shared, why it will be shared, who will receive it (by name or a sufficiently specific description), and that the recipient may contact the individual. Where information comes from a business client, vendor, referral partner, or other third party, we rely on that party's representation that it has given all required notices and obtained all required consents or other lawful authority. We may also perform reasonable consent and source checks. You may withdraw consent, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawal will not affect processing already lawfully completed and may prevent us from providing a requested service. ## 6. When we disclose personal information We may disclose personal information: - to business clients and service providers that match the request, as described at the point of collection; - to vendors that host websites or data, operate customer-relationship systems, send communications, process payments, provide analytics or advertising services, prevent fraud, or otherwise process information for us; - to professional advisers, insurers, auditors, and collection agencies where reasonably necessary; - in connection with a proposed or completed financing, sale, transfer, reorganization, or other transaction involving all or part of our business, subject to appropriate protections; - to law-enforcement, regulators, courts, government authorities, or other parties when required or permitted by law; and - where necessary to protect rights, safety, property, or the integrity of our services. We do not disclose personal information to an unrelated business for its own marketing unless the individual was clearly told about that disclosure and we have the consent or other legal authority required. ## 7. Service providers and processing outside Canada Our service providers may process or store personal information in Canada, the United States, or other countries. Information processed outside Canada may be subject to the laws of that jurisdiction and may be accessible to its courts, law-enforcement, or national-security authorities. We use contractual or other measures designed to require service providers to protect information and use it only for authorized purposes. Contact our Privacy Officer for information about our service providers or our policies concerning processing outside Canada. ## 8. Cookies, analytics, and advertising We and our service providers may use cookies, pixels, tags, local storage, and similar technologies to operate the website, remember preferences, measure traffic and campaign performance, prevent fraud, and deliver or measure advertising. You can adjust browser settings to block or delete cookies. You may also use the opt-out tools offered by applicable advertising and analytics providers. Blocking some technologies may affect website functionality. Where required, we will obtain consent before using non-essential cookies or similar technologies. **Website-specific services to list before publication:** [e.g., Google Analytics, Meta Pixel, Google Ads, call-tracking provider, CRM, scheduling tool, chat widget, payment processor]. ## 9. Marketing communications We send commercial electronic messages only where permitted by Canada's anti-spam law or other applicable law. Our messages will identify the sender and include a working unsubscribe method where required. You may unsubscribe using the link or instructions in a message or by contacting [MARKETING/PRIVACY EMAIL]. We may still send non-promotional messages necessary to respond to a request, administer an account, or complete a transaction. ## 10. Retention We retain personal information only as long as reasonably necessary for the purposes described in this Policy, to satisfy legal, tax, accounting, fraud-prevention, and contractual requirements, and to resolve disputes. Our retention periods depend on the type and sensitivity of information and the reason it is held. Unless a longer period is required or justified, our target retention periods are: - lead and consent records: [INSERT PERIOD, e.g., 24 months after the last activity]; - client contracts, invoices, and transaction records: [INSERT PERIOD, commonly at least six years where required for tax/business records]; - routine website analytics: [INSERT PERIOD]; and - privacy and security-incident records: as required by law. When information is no longer required, we securely delete, destroy, or de-identify it. ## 11. Safeguards and security incidents We use administrative, technical, and physical safeguards appropriate to the sensitivity and amount of information, including access controls, vendor controls, staff practices, and secure disposal. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We assess suspected privacy breaches and, where required by law, notify affected individuals and report the breach to the appropriate regulator. We maintain breach records as required by applicable law. ## 12. Access, correction, and privacy complaints You may request access to personal information we hold about you, ask how it has been used or disclosed, and request correction of inaccurate or incomplete information. We may need to verify your identity. Access may be limited by exceptions under applicable law, and we will explain any refusal as required. To make a request or complaint, contact our Privacy Officer using the details in section 1. We will investigate and respond within the time required by law. If you are not satisfied, you may contact the Office of the Privacy Commissioner of Canada at [www.priv.gc.ca](https://www.priv.gc.ca/). ## 13. Children Our website and services are intended for adults and businesses, not children under 18. We do not knowingly collect personal information from children for lead-generation purposes. Contact us if you believe a child has provided information to us. ## 14. Third-party websites Our website may link to third-party websites or services. We do not control and are not responsible for their content, security, or privacy practices. Review the applicable third party's policies. ## 15. Changes to this Privacy Policy We may update this Policy from time to time. We will post the revised version with a new "Last updated" date and provide any additional notice or seek consent where required by law. Material changes apply prospectively unless otherwise permitted by law. --- # Terms and Conditions **Effective date:** [Month Day, Year] These Terms and Conditions ("Terms") are an agreement between Second Alarm Media, an Ontario sole proprietorship ("Second Alarm Media," "we," "us," or "our"), and the person or entity accessing [WEBSITE URL] or purchasing our services ("you" or "Client"). By using the website, submitting an order, signing an order form, or purchasing services, you agree to these Terms. **Business use only.** Our paid marketing and lead services are offered only to persons acting for business purposes, not for personal, family, or household purposes. If you accept for an organization, you represent that you have authority to bind it. ## 1. Contract documents and priority The agreement consists of these Terms and any signed proposal, insertion order, campaign order, statement of work, or other order document that incorporates them (each, an "Order"). If there is a conflict, the Order controls for that campaign, followed by these Terms. The Privacy Policy governs our handling of personal information. ## 2. Website use You may use the website only for lawful purposes. You must not: - interfere with the website's security, operation, or networks; - attempt unauthorized access, introduce malware, scrape or harvest data without permission, or evade access controls; - impersonate another person or submit false, misleading, or unauthorized information; - infringe intellectual-property, privacy, publicity, or other rights; or - use the website or information obtained from it for unlawful, deceptive, discriminatory, abusive, or unsolicited marketing. We may restrict or suspend access to protect the website, users, or our rights. ## 3. Services and campaign criteria We provide marketing, advertising, lead-generation, lead-qualification, and lead-delivery services described in an Order. Each Order should specify the campaign, territory, channels, budget or retainer, price per lead, volume target or cap, delivery method, start date, and the objective criteria a submission must meet to be a "Qualified Lead." A lead is a Qualified Lead only if it materially meets the criteria in the applicable Order at the time of delivery. Unless the Order expressly states otherwise, a Qualified Lead is not a promise that the person will answer, book an appointment, qualify for financing, purchase, remain interested, or generate revenue. Volume estimates, projections, conversion rates, and timelines are estimates, not guarantees. We may reasonably adjust campaign tactics, channels, creative, or targeting while remaining within the Order. ## 4. Client responsibilities The Client will: - provide complete, accurate, current information, campaign criteria, approvals, and materials on time; - ensure its products, services, claims, licences, offers, landing pages, and follow-up practices comply with law and industry rules; - use lead information only to respond to the request and for purposes disclosed when the information was collected; - contact leads promptly, professionally, and only through lawful methods; - honour opt-outs, do-not-call requests, consent withdrawals, and privacy rights; - maintain appropriate privacy, security, and record-management practices; - not sell, transfer, enrich, or disclose lead information to another party unless the collection notice, applicable law, and the Order permit it; - not use lead information for eligibility decisions, background checks, or other sensitive purposes unless expressly authorized and legally compliant; and - promptly tell us about complaints, regulator inquiries, suspected unauthorized use, security incidents, or inaccurate campaign claims. The Client is independently responsible for its communications and relationship with each lead after delivery. ## 5. Client materials and approvals The Client retains ownership of materials it supplies. The Client grants us a non-exclusive, worldwide, royalty-free licence during the agreement to use, reproduce, adapt, display, and distribute those materials as necessary to perform the services. The Client represents that it has all rights and permissions needed for the materials and instructions it provides and that they are accurate and lawful. Client approval of creative, offers, targeting, forms, or scripts confirms their accuracy and authorization. We may reject or remove content that we reasonably believe is unlawful, misleading, infringing, unsafe, or inconsistent with platform rules. ## 6. Fees, invoices, taxes, and advertising costs The Client will pay the retainer, per-lead charges, setup fees, advertising spend, platform costs, and other fees stated in the Order. Unless the Order states otherwise: - retainers and setup fees are billed in advance and are non-refundable once the applicable service period or setup work begins; - lead charges are invoiced [WEEKLY/MONTHLY/ON DELIVERY]; - invoices are due within [7/15/30] calendar days; - fees are in Canadian dollars and exclude applicable taxes; - the Client authorizes recurring charges to an approved payment method for amounts due; and - overdue amounts accrue interest at the lesser of [1.5% per month (18% annually)] and the maximum lawful rate, plus reasonable collection costs. We may pause campaigns or lead delivery while an invoice is overdue. A pause does not waive amounts already earned or committed third-party costs. Advertising spend and third-party costs are non-refundable once incurred or committed. ## 7. Lead review and credits The Client must review each lead promptly. To request a credit, the Client must provide written notice within **five (5) business days** after delivery, identify the lead, state the specific campaign criterion not met, and provide reasonable supporting information. Unless an Order states otherwise, a lead may qualify for a credit only if, at delivery, it: - contained materially false or unusable contact information; - was a duplicate delivered by us to the same Client for the same campaign within the previous [90] days; - was outside the agreed geography; - requested a materially different service; or - failed another express, objective Qualified Lead criterion in the Order. A lead is not invalid merely because the person does not answer, changes their mind, does not purchase, does not meet an unstated preference, was also contacted by another business where the Order permits non-exclusive leads, or produces no revenue. We will reasonably investigate timely requests. Approved credits are applied to a future invoice or replacement lead and are not cash refunds unless the Order states otherwise. Failure to dispute within the review period constitutes acceptance, except in the case of our fraud or wilful misconduct. Lead credits are the Client's exclusive remedy for an individual lead that fails the agreed criteria. ## 8. Exclusive and non-exclusive leads Leads are non-exclusive unless an Order expressly labels them exclusive. "Exclusive" means we will not intentionally sell or deliver that same lead to another client for the same campaign category during the exclusivity period stated in the Order. It does not mean that the person has not independently contacted another provider or appeared through another source. ## 9. Term, renewal, suspension, and termination These Terms apply while you use the website. A service engagement begins and continues for the term stated in the Order. If no term is stated, it continues month to month until either party gives at least **30 days' written notice**. Either party may terminate an Order for a material breach not cured within 10 days after written notice. We may suspend or terminate immediately for unlawful or deceptive activity, misuse of lead data, a security risk, platform-policy violations, non-payment, or conduct likely to harm a person, our reputation, or our legal compliance. On termination, the Client must pay fees earned, leads delivered, advertising spend, non-cancellable commitments, and taxes through the effective termination date. Prepaid amounts are non-refundable except for services we do not provide after a termination caused solely by our uncured material breach. Sections that by their nature should survive will survive, including payment, intellectual property, confidentiality, privacy, disclaimers, indemnity, liability limits, and dispute terms. ## 10. Confidentiality Each party may receive non-public business, technical, pricing, campaign, or customer information of the other ("Confidential Information"). The receiving party will use it only for the agreement and protect it with reasonable care. It may disclose Confidential Information to personnel and service providers who need it and are bound by confidentiality duties. Confidential Information excludes information that the receiving party can show was lawfully known without restriction, becomes public without breach, is received lawfully from another source, or is independently developed. Required legal disclosures are permitted after advance notice where lawful and practical. ## 11. Privacy and data protection Each party will comply with privacy, anti-spam, telemarketing, consumer-protection, and other laws applicable to its activities. Each party acts as an independent organization responsible for personal information under its control, except to the extent an Order expressly states that one party processes information only on the other's instructions. The Client will use lead information only within the scope of the consent and collection notice associated with that lead. On request, the Client will reasonably assist us in addressing consent questions, privacy requests, complaints, and security incidents. If either party becomes aware of unauthorized access to or use of shared personal information, it will notify the other without unreasonable delay and cooperate on legally required action. ## 12. Intellectual property We and our licensors retain ownership of the website, software, methods, templates, know-how, campaign structures, reports, and materials we create or owned before the engagement ("Second Alarm Materials"). After full payment, the Client may use final campaign deliverables created specifically for it for its internal business and marketing purposes, subject to third-party licence terms and any different terms in the Order. No ownership in Second Alarm Materials transfers unless an Order expressly says so. Feedback may be used by us without restriction or compensation, provided we do not publicly identify the Client without permission. ## 13. Third-party platforms and services Campaigns may depend on advertising networks, telecommunications carriers, hosting providers, analytics tools, payment processors, and other third parties. Their terms, policies, pricing, algorithms, availability, and decisions are outside our control. We are not responsible for a third party's suspension, rejection, outage, policy change, data loss, or performance, but we will use commercially reasonable efforts to manage services within our control. ## 14. Disclaimers To the maximum extent permitted by law, the website, leads, and services are provided "as is" and "as available." We disclaim implied warranties and conditions of merchantability, fitness for a particular purpose, non-infringement, and uninterrupted or error-free operation. We do not guarantee lead volume, exclusivity unless expressly purchased, contactability, conversion, revenue, profitability, platform approval, ranking, or any particular business outcome. Nothing on the website is legal, financial, or other professional advice. ## 15. Limitation of liability To the maximum extent permitted by law, neither party will be liable for indirect, incidental, special, exemplary, punitive, or consequential damages, or for lost profits, revenue, business, goodwill, anticipated savings, or data, arising from the agreement, even if advised of the possibility. To the maximum extent permitted by law, Second Alarm Media's total aggregate liability arising from an Order or these Terms will not exceed the fees paid or payable to Second Alarm Media under the affected Order during the three (3) months immediately before the event giving rise to the claim. The exclusions and cap do not apply where liability cannot lawfully be excluded or limited. [LAWYER REVIEW: consider negotiated carve-outs for confidentiality, privacy/security, infringement, fraud, wilful misconduct, payment obligations, and indemnity.] ## 16. Indemnity The Client will defend, indemnify, and hold harmless Second Alarm Media and its owner, personnel, and contractors from third-party claims, losses, damages, penalties, and reasonable legal costs arising from: (a) Client materials, products, services, claims, or instructions; (b) the Client's contact with or use of information about a lead; (c) breach of sections 4, 5, 10, or 11; or (d) the Client's violation of law or third-party rights. We will promptly notify the Client of a covered claim and provide reasonable cooperation at the Client's expense. The Client may control the defence but may not settle in a way that admits our fault, imposes obligations on us, or fails to fully release us without our written consent. ## 17. Governing law and disputes These Terms and each Order are governed by the laws of Ontario and the federal laws of Canada applicable there, without regard to conflict-of-law rules. The parties irrevocably submit to the exclusive jurisdiction of the courts located in [CITY/REGION], Ontario. Before starting a court proceeding, a party will give written notice describing the dispute, and authorized representatives will attempt in good faith to resolve it for at least 15 days. Either party may seek urgent injunctive relief where appropriate. ## 18. Changes to these Terms We may update the website-use provisions by posting revised Terms with a new effective date. Changes to an active Order will not apply retroactively and will take effect only as permitted by the Order or with the Client's agreement. Continued website use after posted changes means acceptance of the revised website-use provisions. ## 19. General terms Neither party may assign an Order without the other's consent, except that we may assign it in connection with a sale or reorganization of our business. We may use subcontractors but remain responsible for our obligations. The parties are independent contractors. These Terms do not create a partnership, joint venture, fiduciary, franchise, employment, or agency relationship. Neither party may bind the other. Notices concerning an Order must be in writing and sent to the contact listed in the Order. Notices to Second Alarm Media must also be sent to [LEGAL NOTICE EMAIL]. Email notice is effective when received, excluding automated delivery failures. If a provision is unenforceable, it will be limited to the minimum extent necessary and the remainder will continue. A waiver must be in writing and applies only to the specific instance. Headings are for convenience. "Including" means "including without limitation." These Terms and each Order are the entire agreement about their subject matter and replace prior discussions or communications. ## 20. Contact Second Alarm Media [BUSINESS/Mailing ADDRESS] [CITY], Ontario [POSTAL CODE], Canada Email: [GENERAL/LEGAL EMAIL] Website: [WEBSITE URL] --- # Lead-Form Consent Notice Place this notice immediately beside the form's submit button. Do not pre-check an optional marketing box. Tailor the recipient description to the actual campaign; name the recipient where practical. ## Option A — One identified service provider > By clicking **[SUBMIT BUTTON TEXT]**, you agree that Second Alarm Media may collect and use the information you provide to assess your request and share it with **[CLIENT LEGAL/BUSINESS NAME]**, which may contact you by telephone, email, or text about **[REQUESTED SERVICE]**. Consent is not a condition of purchase. Message and data rates may apply. You may withdraw consent at any time. See our [Privacy Policy] and [CLIENT NAME's Privacy Policy]. ## Option B — A small number of matched providers > By clicking **[SUBMIT BUTTON TEXT]**, you agree that Second Alarm Media may collect and use the information you provide to assess your request and share it with up to **[NUMBER] [TYPE OF SERVICE] providers serving [LOCATION]**, which may contact you by telephone, email, or text about your request. Consent is not a condition of purchase. Message and data rates may apply. You may withdraw consent at any time. See our [Privacy Policy] and the identity of participating providers [LINK OR DISCLOSURE METHOD]. ## Separate optional marketing checkbox > ☐ I agree to receive promotional emails and/or text messages from Second Alarm Media about [DESCRIBE CONTENT]. I can unsubscribe at any time. Contact: [MAILING ADDRESS], [EMAIL], [WEBSITE]. Keep evidence of the exact notice, date and time, page URL, source, information submitted, recipient(s), and affirmative action associated with each lead. --- # Publication Checklist 1. Replace every **[square-bracketed item]** and remove all drafting notes. 2. Put the Privacy Policy and Terms on separate, permanently accessible website pages and link them in the footer and each relevant form. 3. Add the tailored lead-form notice next to every submit button; identify or narrowly describe recipients and the maximum number of businesses receiving the lead. 4. Inventory every cookie, pixel, analytics tool, call tracker, CRM, form provider, payment provider, and advertising platform, then make section 8 accurate. 5. Set and follow real retention periods. Maintain security-incident records and an access/correction request process. 6. Use a signed Order for every client stating price, retainer, ad spend, lead criteria, territory, exclusivity, caps, billing timing, dispute window, term, and cancellation rights. 7. Obtain source and consent warranties from lead vendors; periodically audit sample consent records. Do not rely on a contractual warranty where the collection notice is visibly inadequate. 8. Ensure client agreements restrict use, resale, disclosure, retention, and security of lead data. 9. Configure commercial messages with sender identification, contact information, and a functioning unsubscribe process, and maintain consent/suppression records. 10. Obtain Ontario legal review before publication and before running campaigns in regulated or sensitive sectors.This is where you can write your privacy policy or terms and conditions.