Last updated: March 23, 2026

Thurodale Inc. (“Thurodale”, “we”, “our” or “us”) is committed to protecting personal information and handling it in a responsible, transparent and secure manner.

This Privacy Notice describes how Thurodale collects, uses, discloses, retains and safeguards personal information in connection with:

• this website;
• communications with us;
• our governance, corporate services and consulting activities; and
• the administration and operation of our business.

By providing personal information to Thurodale, including through this website or in connection with an enquiry or engagement, you acknowledge that your personal information will be handled in accordance with this Privacy Notice, subject to applicable law.

In this Privacy Notice, “personal information” means information about an identifiable individual, subject to any exclusions or exceptions provided by applicable law.

Depending on the applicable legal context, business contact information used solely for the purpose of communicating with an individual in relation to that individual’s employment, business or profession may not be treated in the same manner as personal information.

The nature of the personal information we collect depends on the circumstances, the services involved and the manner in which an individual interacts with us.

Personal information we may collect includes:

• name, title, position and business affiliation;
• email address, telephone number and other contact details;
• information contained in enquiries, correspondence, instructions and requests;
• billing, invoicing and payment-related information;
• information required for onboarding, engagement administration and service delivery;
• governance, administrative and record-keeping information relating to corporate structures, entities, registers, records and related materials;
• information necessary to maintain contact lists, registers or internal records on behalf of clients;
• technical information, device information, website usage information and related analytics data collected through cookies and similar technologies; and
• any other personal information voluntarily provided to us or provided to us in connection with an engagement.

We seek to limit collection to information that is reasonably necessary and proportionate in light of the purposes for which it is collected.

Where required by law, Thurodale obtains consent to collect, use and disclose personal information.

Consent may be express or implied, depending on the nature and sensitivity of the information, the purpose for which it is collected, and the reasonable expectations of the individual.

By voluntarily providing personal information to us, including through this website or in connection with an enquiry or engagement, you consent to our handling of that information for the purposes described in this Privacy Notice, subject to applicable law.

You may withdraw your consent, subject to legal, contractual and operational restrictions and reasonable notice. Withdrawal of consent may affect our ability to respond to a request, administer an engagement or continue providing services.

If you provide us with personal information relating to another individual, you represent that you have the authority to do so or that such disclosure is otherwise permitted by law.

In certain engagements, Thurodale acts as a service provider processing personal information on behalf of a client.

In those circumstances: 

• the client determines the purposes for which the personal information is processed;
• Thurodale processes personal information in accordance with the client’s instructions, the applicable engagement terms and applicable law; and
• the client remains responsible for ensuring that an appropriate legal basis exists for the collection, use and disclosure of the personal information in question.

Where we act on behalf of clients, our role may include maintaining records, registers, governance materials, contact information or other administrative information relating to entities, structures or individuals.

Thurodale may disclose personal information where appropriate and consistent with applicable law: 

• to service providers who support our operations, including technology, hosting, communications, document management, data storage and administrative service providers;
• to professional advisors;
• to financial institutions and payment service providers;
• to regulators, governmental authorities, courts, tribunals or law enforcement where disclosure is required or permitted by law;
• to clients and their authorized representatives where relevant to an engagement; and
• to other parties where disclosure is reasonably necessary to establish, administer or perform services. 

Thurodale may use third-party service providers to host, store, process or otherwise handle personal information on our behalf.

As a result, personal information may be stored or processed outside Ontario or outside Canada and may be subject to the laws of those jurisdictions.

Where we use service providers, we expect them to maintain safeguards appropriate to the sensitivity of the information and the services being provided.

Thurodale retains personal information only for as long as reasonably necessary for the purposes for which it was collected, and thereafter for such longer period as may be required or permitted by applicable law, regulation, contractual obligation, limitation period, record-retention requirement or legitimate business need.

When personal information is no longer required, we may delete, destroy, anonymize or otherwise dispose of it in accordance with our retention practices and applicable law.

Thurodale maintains administrative, technical and organizational safeguards designed to protect personal information against loss, theft and unauthorized access, use, disclosure, modification or destruction.

The safeguards used depend on the sensitivity of the information and the nature of the activities involved.

While we take reasonable steps to protect personal information, no method of transmission over the internet and no method of storage is completely secure. Accordingly, we cannot guarantee absolute security.

Thurodale seeks to keep personal information as accurate, complete and current as reasonably necessary for the purposes for which it is to be used.

Where appropriate, we may rely on individuals and clients to inform us of changes to relevant personal information.

Subject to applicable law, an individual may request access to personal information held by Thurodale about that individual and may request correction of inaccurate or incomplete personal information.

Requests for access or correction should be made in writing to the contact identified below. Thurodale may require sufficient information to verify the identity of the requestor before responding.

Where permitted by law, Thurodale may send insights, updates, event notices or other communications by email or other electronic means.

Where consent is required, we will seek it. Where an unsubscribe mechanism is required, we will provide one.

You may unsubscribe from marketing or update communications at any time by using the unsubscribe mechanism in the communication or by contacting us.

This website may contain links to third-party websites, platforms or services. Thurodale is not responsible for the privacy practices, content or terms of any third party.

Your use of third-party sites or services is at your own risk and subject to the terms and policies of those third parties.

Thurodale may amend or update this Privacy Notice from time to time. The most current version will be posted on this website and will take effect when posted, unless otherwise indicated.

Questions, concerns and requests relating to this Privacy Notice or Thurodale’s handling of personal information may be directed to: privacy@thurodale.com