ORION Cybernetics — Privacy & Security Policy

Effective Date: January 2026 Organization: Kevin Orr Associates Canada Inc., operating as ORION Cybernetics

ORION Cybernetics is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us. This Privacy & Security Policy explains how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial and federal legislation.

1. Introduction

We are dedicated to providing exceptional service while respecting your privacy. When interactions with ORION Cybernetics involve the collection of personal information, we handle that information in a manner a reasonable person would consider appropriate.

This Policy outlines:

Why we collect personal information
What personal information we collect
How we use and disclose personal information
How consent works
How we safeguard information
Your rights to access and correct your information

2. Website Visitor Statistics & Cookies

Use of Google Analytics

ORION Cybernetics uses Google Analytics to understand how visitors use our website. Google Analytics uses cookies to collect aggregated, non‑identifiable information such as:

Page visits
Time spent on pages
Navigation paths
Browser and device types

This information cannot be traced to an individual and is used solely to improve website performance and user experience.

What Are Cookies?

This website uses essential cookies required for core site functionality. No third-party analytics or advertising cookies are used. Cookies are small text files stored on your device to help websites recognize returning visitors and improve functionality. Cookies used on our site:

Do not harm your system
Do not identify you personally
Do not enable marketing to individuals

You may configure your browser to accept, reject, or notify you about cookies. Rejecting cookies may limit certain website features.

3. Legislative Framework

ORION Cybernetics complies with:

PIPEDA
The Privacy Act
Applicable provincial privacy laws
The Canadian Standards Association (CSA) Model Code

We follow the Ten Fair Information Principles, including accountability, consent, limiting collection, safeguards, accuracy, openness, and individual access.

4. What Is Personal Information?

Personal information is information about an identifiable individual, excluding business contact information. Examples include:

Name, address, phone numbers, email
Employment history
Date of birth
Credit or payment information (if applicable)

We may obtain this information from:

You directly
Credit or financial institutions
Government agencies (e.g., Contract Security Program)

5. When and Why We Collect Personal Information

Employment or Contract Engagements

We collect personal information to:

Assess suitability for employment or contract roles
Verify qualifications and work history

Government of Canada Security Clearances

For personnel requiring security clearances, we collect information required by the Contract Security Program, including:

Date of birth
Employment history
Family background
Other information required by federal standards

6. How We Use and Disclose Personal Information

We use personal information to:

Evaluate employment or contract applications
Initiate Government of Canada security clearance processes
Analyze risk
Meet legal or regulatory requirements

We will:

Use information only for identified purposes
Retain information only as long as necessary
Keep information accurate and up to date
Protect information with appropriate safeguards
Provide access to your information upon request

ORION Cybernetics never sells personal information to any organization.

7. Consent

Implied Consent

Implied consent applies when the purpose of collection is obvious from the context.

Express Consent

Express written or verbal consent is required for sensitive personal information, such as information used for security clearances.

Exceptions to Consent

Consent is not required when information is:

Disclosed to legal counsel
Used to collect debts
Required for investigations involving fraud or illegal activity
Required by law

Withholding or Withdrawing Consent

You may withdraw consent, subject to legal or contractual limitations. Withdrawal may affect our ability to provide services or process applications.

8. Access to Your Personal Information

You may request access to personal information held by ORION Cybernetics. Requests must be in writing. We will respond within 30 days.

Access may be denied if:

It would interfere with a law enforcement investigation
It is protected by solicitor‑client privilege
It contains confidential commercial information
It references other individuals
It was created during dispute resolution

Reasonable fees may apply for copies or retrieval.

9. Safeguards and Security

We protect personal information using:

Secure storage systems
Access controls
Encryption where appropriate
Contractual protections for third‑party service providers

Despite these measures, no system is entirely immune to cyber threats. We continuously review and enhance our security practices.

10. Third‑Party Tools and Services

Our website may use third‑party tools such as:

Google Analytics
Embedded media
Cloud‑based forms or hosting

These services operate under their own privacy policies. ORION Cybernetics is not responsible for third‑party data practices.

11. AI‑Assisted Content Notice

Some website content may be generated or assisted by artificial intelligence tools. Such content is provided for informational purposes only and should be independently verified where accuracy is critical.

12. Accessibility

ORION Cybernetics is committed to accessibility in accordance with the Accessibility for Ontarians with Disabilities Act (AODA). Users may contact us to report accessibility barriers.

13. Updates to This Policy

We may update this Privacy & Security Policy to reflect legislative changes or improvements to our practices. The most current version will always be available on our website.

14. Contact Information

For questions, concerns, or access requests, contact:

Privacy Compliance Officer ORION Cybernetics Email: privacy@orioncybernetics.com Phone: +1 (613) 590-1400

If concerns remain unresolved, you may contact:

Office of the Privacy Commissioner of Canada 112 Kent Street Place de Ville, Tower B, 3rd Floor Ottawa, ON K1A 1H3