Effective Date: 1 November 2025

1. Overview

This website is maintained by Toby Bartlett in connection with its professional and corporate affairs.

The firm operates globally, providing advisory, analytical, and creative consultancy services to institutional, governmental, and corporate clients.

This Privacy Policy describes the limited circumstances in which information may be collected or processed when individuals interact with this website.

2. Scope

This Policy applies solely to information obtained through public interaction with the website www.tobybartlett.ca (the “Site”).

It does not govern information collected through professional engagements, contractual relationships, or in-person security environments, all of which are subject to separate agreements and nondisclosure obligations.

3. Information Collected

3.1 Voluntary Submissions – Information you choose to provide by email or other communication channels listed on this Site (such as name, contact details, or message content).

3.2 Technical Data – Minimal system data automatically transmitted by your device or browser, including IP address, time of access, and user-agent metadata, required to maintain Site integrity and prevent misuse.

3.3 No Cookies or Trackers – The Site does not deploy analytics, marketing cookies, or third-party tracking scripts.

4. Use of Information

Information may be used only for:

– responding to inquiries;

– maintaining security, integrity, and lawful operation of the Site;

– complying with applicable legal or regulatory obligations of an international character.

No data are sold, leased, or otherwise transferred for commercial gain.

5. Data Retention and Security

Information is retained only for the period necessary to achieve the limited purposes set out above and is deleted or anonymised thereafter.

Appropriate technical and organisational safeguards consistent with the highest international standards are applied to protect against unauthorised access, alteration, or disclosure.

6. Cross-Border Processing

Data may be processed or stored in locations that maintain standards of protection consistent with recognised international benchmarks.

Such processing does not imply submission to any particular jurisdiction.

7. Third-Party Links

The Site may contain links to external websites (for example, LinkedIn).

Those destinations operate under their own privacy frameworks, for which Toby Bartlett accepts no responsibility or liability.

8. Enquiries

All privacy-related correspondence shall be directed exclusively to:

legal@tobybartlett.ca

No other contact channel is authorised for privacy or compliance matters.

9. Revisions

This Policy may be amended periodically.

The latest version will be published on this Site and will supersede all prior versions as of the Effective Date stated above.

10. Governing Principles

These Terms and this Policy shall be interpreted and applied in accordance with principles of international commercial practice and recognised standards of data protection, without submission to any specific national jurisdiction or conflict-of-laws regime.