Privacy Policy

1. Preamble: A Statement of Principle

Unbroken Rising Holdings Inc. and its affiliated entities (collectively, "RISING ATELIER™," "we," "us," or "our") are the architects of luxury streetwear, crafting not merely apparel but an experience. Integral to this experience is our unwavering commitment to the stewardship of your personal information. This Privacy Policy (the "Policy") articulates the principles and practices governing the collection, use, and disclosure of your Personal Data when you engage with our digital atelier: our website(s), mobile application(s), and related services (the "Services").

We approach data privacy with the same precision and respect for craft that defines our collections. Your trust is our most valued asset, and we are dedicated to maintaining the confidentiality, security, and integrity of the information you entrust to us. This Policy is designed to provide the transparency you deserve and the control you require.

2. Jurisdictional Nexus and Legal Foundations

RISING ATELIER™ operates from our headquarters in Montreal, Quebec, Canada. Our processing of Personal Data is conducted in accordance with applicable Canadian federal and provincial legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and An Act respecting the protection of personal information in the private sector (Quebec Law 25).

The provision of your Personal Data is voluntary. However, its collection is fundamental to the performance of our contractual obligations to you, the provision and enhancement of our Services, the protection of our legitimate interests, and compliance with our legal and regulatory duties. Without it, we may be unable to provide the full spectrum of our Services or optimize your experience.

3. The Data We Curate

3.1. Personal Data

"Personal Data" refers to any information that relates to an identifiable individual. We collect the following categories:

• Identity and Contact Data: Your name, mailing address, email address, telephone number, and similar details provided during account registration, a purchase, or an inquiry.
• Transactional Data: Details related to your purchases. We utilize reputable third-party payment processors. We do not retain full payment card information, but may receive and store a tokenized reference or limited, non-sensitive details to process transactions and service your account.
• Profile and Correspondence Data: Information you voluntarily provide when you contact our client services, complete a survey, subscribe to our communications, or interact with us through any channel.
• Technical and Usage Data: Your IP address, approximate geographic location (city/country), browser type, device information, and details regarding your interaction with our Services (pages viewed, time spent, referral source).
• Social Data: If you choose to authenticate your account through a third-party platform (e.g., Google), we may receive certain profile information as permitted by that platform and your privacy settings.
• Enterprise Representative Data: If you engage with our Services on behalf of a corporate entity, we collect relevant business contact information necessary to manage that relationship.

3.2. Non-Personal & Aggregate Data

We collect anonymized, aggregated data derived from user activity for analytical purposes, such as statistical trends in site usage. This data does not reveal your identity and is not subject to the protections afforded to Personal Data.

4. Digital Craftsmanship: Tracking Technologies

Our Services employ cookies, pixel tags, and similar tracking technologies ("Tracking Technologies") to enhance functionality, analyze trends, and personalize your journey. These tools help us understand how you interact with our digital atelier, allowing us to refine its design and content.

Privacy by Default: Our Services are configured to privacy by default — tracking technologies that identify, locate, or profile you are disabled unless you expressly opt-in. Essential cookies necessary for Service functionality remain active. Non-essential cookies, including those used for analytics and marketing, require your explicit consent before activation.

Please note that disabling certain Tracking Technologies may impact the functionality and performance of our Services.

5. The Purpose of Processing: How We Utilize Your Data

We act as careful custodians of your Personal Data, using it solely for defined purposes:

• To execute and administer your account, process transactions, and deliver our Services.
• To communicate regarding your account, orders, and our Services, including essential updates.
• To personalize and continually refine your experience within our Services.
• For direct marketing, where you have provided your separate, explicit consent or where permitted by law. Marketing consent is requested distinctly from account creation and can be withdrawn at any time by using the "unsubscribe" link in any email or contacting our Privacy Officer directly.
• To ensure the security of our Services, protect against fraud, and enforce our Terms of Service.
• To comply with valid legal requests, court orders, or regulatory requirements.

Automated Decision-Making: We do not make decisions based exclusively on automated processing, including profiling. If this practice changes, we will notify you and provide information on the logic involved and your right to contest.

Privacy Impact Assessments: We conduct Privacy Impact Assessments (PIAs) when implementing new information systems, transferring data outside Quebec, or engaging in high-risk processing. Documentation is available upon request to the Privacy Officer.

6. Disclosures of Personal Data

We share your Personal Data only under strict circumstances:

• Service Providers: With trusted partners (e.g., hosting, analytics, payment processing, logistics) who act under our instruction and are bound by contractual obligations to protect your data.
• Legal Compliance and Protection: Where required by law, or to protect the rights, property, or safety of RISING ATELIER™, our clients, or the public.
• Corporate Transactions: In connection with a merger, acquisition, financing, or sale of assets, under conditions of confidentiality.
• With Your Consent: For any other purpose disclosed to you at the point of collection, with your explicit consent.

7. International Transfers

As a global brand, some service providers or affiliates may be located outside Canada, including in the United States. When we transfer your Personal Data across borders, we ensure appropriate safeguards are in place, such as contractual clauses, to provide a level of protection comparable to Canadian and Quebec law.

Specifically, your data may be transferred to:

• Shopify Inc. (Canada/USA) for e-commerce platform services
• Google LLC (USA) for analytics services
• Payment processors operating under PCI-DSS standards

These transfers are protected by contractual clauses ensuring protection comparable to Quebec law. A Privacy Impact Assessment has been conducted for these transfers.

8. Security of Your Data

We implement robust administrative, technical, and physical measures designed to safeguard your Personal Data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption, access controls, and secure server infrastructure.

While we strive to protect your information, no digital transmission or storage system is entirely impregnable. You play a vital role in security by maintaining the confidentiality of your account credentials.

9. Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Our retention schedules consider the nature, sensitivity, and purpose of the data.

10. Your Legal Rights (Canada & Quebec)

As a resident of Canada and Quebec, you possess rights regarding your Personal Data:

• Right of Access: To request confirmation of processing and a copy of your Personal Data.
• Right of Rectification: To correct inaccurate or incomplete data.
• Right to Erasure: To request deletion of your data, subject to legal limitations.
• Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format and, where technically feasible, have it transmitted directly to another data controller.
• Right to Object/Restrict Processing: To object to certain processing activities or request a temporary restriction.
• Right to Withdraw Consent: Where processing is based on consent, to withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.

These rights are not absolute and may be subject to our legitimate interests or legal requirements. To exercise any right, please contact our Privacy Officer using the details in Section 14. We will respond within 30 days in accordance with applicable law.

11. Breach Notification

In the event of a breach of Personal Data that creates a risk of serious injury, we will:

• Notify you promptly via email or prominent notice on our Services
• Report the breach to the Commission d'accès à l'information du Québec
• Take immediate remedial action to contain and mitigate the breach

12. Policy Regarding Minors

Our Services are not intended for individuals under the age of 14. We do not knowingly solicit or collect Personal Data from minors. If we become aware that such data has been inadvertently provided, we will take prompt steps to delete it. Parents or guardians who believe their child has submitted Personal Data should contact us immediately.

13. Revisions to This Policy

This Policy may be updated periodically to reflect changes in our practices, Services, or legal obligations. The "Last Updated" date at the top of this page will be revised accordingly. Material changes will be communicated through our Services or via direct notification. Your continued use of our Services following any update constitutes your acknowledgment of the revised Policy.

15. Language

This Privacy Policy is provided in English. A French version is available upon request to privacy@risingatelier.com. In case of discrepancy between the English and French versions, the English version shall prevail unless otherwise required by applicable law.