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Privacy Policy

May 2026

1. Introduction

2803708 Ontario Inc. (“we,” “us,” or “our”) operates KaratBroker, a compliance and transaction management platform for independent jewellers, cash-for-gold buyers, and pawnbrokers (karatbroker.ca). This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our platform and website.

We are committed to compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

2. Who This Policy Applies To

This policy applies to operators (jewellers and dealers) who subscribe to KaratBroker, end customers whose information is entered into KaratBroker by operators during in-store transactions, and visitors to karatbroker.ca.

KaratBroker is a business-to-business platform intended for use by adults operating licensed businesses. It is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors.

3. Information We Collect

From operators: Business name, address, and contact information; HST/CRA business registration numbers; billing information (processed by third-party payment processors); account credentials and usage data.

From end customers (entered by operators): Name and contact information (phone number, address); government-issued identification details, where required by law; transaction records including items purchased or pledged, amounts, and dates; signatures captured electronically during regulated transactions.

From website visitors: No personal information is currently collected passively on karatbroker.ca. If analytics or tracking tools are introduced in the future, this policy will be updated accordingly.

4. How We Use Personal Information

We use personal information to deliver and operate the KaratBroker platform; process and record regulated transactions on behalf of operators; generate compliance documentation required under the Ontario Second-Hand Dealers and Pawnbrokers Act (SHDPBA) and applicable municipal bylaws; send transactional SMS notifications to end customers on behalf of operators, including loan payment reminders, repair pickup notices, appraisal completion alerts, and special order arrivals; respond to support and account inquiries; and maintain platform security and prevent fraud.

We do not use personal information for advertising or sell it to third parties.

5. SMS Notifications

End customers may receive transactional SMS messages sent by their jeweller through KaratBroker's messaging system (KaratLine). These messages are strictly transactional — they relate to active transactions between the customer and the operator.

Opt-in: Customers provide their phone number in person at point of sale. By providing their number, customers consent to receive transaction-related SMS notifications from their jeweller via KaratBroker.

Opt-out: Customers may reply STOP to any message at any time to unsubscribe. No further messages will be sent following an opt-out request.

Message frequency varies based on transaction activity. Message and data rates may apply. Mobile numbers are never sold or shared with third parties for marketing purposes.

6. Disclosure of Personal Information

We disclose personal information only in the following circumstances:

  • Legal compliance: Transaction records may be disclosed to law enforcement as required under the SHDPBA, applicable municipal bylaws, or court order.
  • Service providers: Trusted third parties engaged to operate our platform, bound by confidentiality obligations, with infrastructure maintained in Canada.
  • Business transfers: In the event of a merger or acquisition, affected parties will be notified.

We do not sell, rent, or trade personal information.

7. Data Residency and Storage

All personal information processed through KaratBroker is stored on infrastructure located in Canada (ca-central-1, Canada Central). We do not transfer personal information outside of Canada in the ordinary course of operations.

8. Data Retention

Personal information is retained for as long as a tenant's account remains active on the KaratBroker platform. Transaction records required for regulatory compliance are retained for the minimum period required by applicable law. Upon account termination, personal information is retained for a reasonable period to satisfy legal obligations before secure deletion.

9. Security

We implement administrative, technical, and physical safeguards appropriate to the sensitivity of the personal information we hold, including encrypted data storage, isolated tenant databases, role-based access controls, and audit logging of all data mutations.

In the event of a data breach affecting your personal information, we will notify affected parties as required by law.

10. Your Rights

Under PIPEDA, you have the right to:

  • Request access to personal information we hold about you
  • Request correction of inaccurate information
  • Withdraw consent where processing is based on consent (subject to legal and contractual limitations)
  • Lodge a complaint with the Office of the Privacy Commissioner of Canada

To exercise your rights, contact us at hello@karatbroker.ca. We will respond within 30 days.

11. Cookies and Tracking

karatbroker.ca does not currently use cookies or third-party tracking tools. If this changes, this policy will be updated and visitors will be notified prior to any tracking being activated.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of KaratBroker following notice of changes constitutes acceptance of the updated policy.

13. Contact

Privacy inquiries may be directed to:

2803708 Ontario Inc.
hello@karatbroker.ca
karatbroker.ca
Welland, Ontario, Canada