CGD Vibes is more than a platform, it’s a movement.
Empowering creators, dreamers, and doers to rise with purpose, grow with community, and build something that truly reflects their vibe.
© 2026 CGD Vibes™. All rights reserved.
Last Updated: [December 15, 2025]
CGD Vibes – Create, Grow, Dream
TABLE OF CONTENTS
1. INTRODUCTION & SCOPE
1.1 Our Commitment to Privacy
At CGD Vibes, we protect your privacy and handle your personal information responsibly, transparently, and in compliance with:
This Privacy Policy explains what personal information we collect, how we use and share it, your rights, and how to exercise them.
1.2 Who This Policy Applies To
This policy applies to all CGD Vibes users:
1.3 Acceptance
By accessing CGD Vibes, you acknowledge and agree to this Privacy Policy and our Terms of Service. If you disagree, you may not use our platform.
1.4 Language Rights (Quebec Residents)
English version is authoritative except for Quebec consumers.
French version available upon request: email [email protected] (provided within 30 days).
For Quebec consumers, French version governs where required by law (Bill 101).
2. WHO WE ARE & CONTACT INFORMATION
Company: CGD Vibes is operated by N.W. Marketing Inc. (Quebec, Canada).
Address: 204 rue du Saint-Sacrement, Espace 300, Montréal, Quebec, Canada, H2Y 1W8
Email: [email protected] | Privacy Officer: [email protected]
3. DATA CONTROLLER & PROCESSOR ROLES
3.1 CGD Vibes as Data Controller
CGD Vibes controls:
3.2 Sellers = Independent Controllers
Sellers operate independent businesses and control:
CGD Vibes is NOT responsible for sellers' independent data practices.
3.3 Data Boundaries
Platform Data (CGD Vibes controls):
Seller Access (limited to orders):
Seller Independent Data:
4. INFORMATION WE COLLECT
4.1 You Provide Directly
All Users:
Sellers Additional:
Buyers:
All Users:
4.2 Collected Automatically
Technical:
Usage:
Logs:
4.3 Cookies & Tracking
We use cookies, pixels, beacons for:
See Section 14 for cookie details.
4.4 From Third Parties
4.5 Sensitive Information (Limited)
Tax IDs (Sellers Only):
Government ID (Sellers Only):
We Do NOT Collect:
5. HOW WE USE YOUR INFORMATION
5.1 Platform Operations
5.2 Payments & Financial (As Merchant of Record)
5.3 Improvement & Analytics
5.4 Communications
Transactional (cannot opt out):
Marketing (can opt out):
5.5 Security & Fraud Prevention
5.6 Legal Compliance
5.7 Business Operations
6. LEGAL BASES FOR PROCESSING (GDPR/UK GDPR)
Where GDPR applies, we process data only with valid legal basis:
Contract Performance:
Legal Obligation:
Legitimate Interests:
You can object to legitimate interest processing (Section 15.4).
Consent:
You can withdraw consent anytime (doesn't affect prior processing).
Vital Interests:
7. AUTOMATED DECISION-MAKING & PROFILING
7.1 Overview
We use automated systems for efficiency and security. You have rights regarding automated processing.
7.2 Automated Systems
Fraud Detection:
Payment Verification:
Account Security:
Content Moderation (Flagging Only):
Personalization:
7.3 NO Solely Automated Significant Decisions
Important: We do NOT make solely automated decisions with legal/significant effects without human involvement.
All significant decisions have human review:
7.4 Your Rights
Right to Human Review:
How to Request: Email [email protected]:
Response: Within 7 business days.
7.5 Marketing Profiling
We analyze platform activity for:
You can:
8. HOW WE SHARE YOUR INFORMATION
8.1 General Principles
CGD Vibes does NOT sell your personal information.
We share only when necessary for operations, legal compliance, or with your consent, and only with parties contractually required to protect your data.
8.2 Sellers (Limited Info)
When you purchase from a seller:
Shared with Seller:
Purpose: Order fulfillment, support, delivery.
Seller Obligations: Protect your info per applicable law, use only for fulfillment, comply with privacy obligations.
CGD Vibes NOT responsible for sellers' external use or violations.
8.3 Service Providers (Subprocessors)
We engage third parties bound by confidentiality who process data on our behalf:
Platform & Hosting:
Payments:
Communications:
Analytics:
Marketing:
8.4 Affiliates
When you use an affiliate link:
8.5 Business Transfers
If CGD Vibes is involved in merger, acquisition, sale, bankruptcy:
8.6 Legal Requirements
We may disclose when necessary to:
Legal Process:
Protect Rights:
With Your Consent: When you explicitly consent or direct us.
9. THIRD-PARTY SERVICES & SUBPROCESSORS
9.1 Key Subprocessors
[Detailed table with Service Provider, Purpose, Data Processed, Location for each category]
Platform Infrastructure:
Payment Processing:
Communications:
Analytics:
Marketing:
9.2 Data Processing Agreements
All subprocessors bound by:
9.3 Subprocessor Changes
Notification:
To Receive Notifications: Email [email protected]: Subject "Subprocessor Notification Request"
9.4 Objecting to Subprocessors (GDPR)
If you object to new subprocessor:
Limitation: If subprocessor essential and no alternative exists, may be unable to accommodate; you may terminate account.
10. INTERNATIONAL DATA TRANSFERS
10.1 Data Storage Locations
Primary storage:
10.2 Cross-Border Transfers
When transferring from EEA/UK/Switzerland to countries without adequate protection (US, Canada), we implement appropriate safeguards.
10.3 Transfer Safeguards
Standard Contractual Clauses (SCCs):
Adequacy Decisions:
Additional Safeguards:
10.4 EzyCourse GDPR Compliance
EzyCourse operates GDPR-compliant infrastructure:
10.5 Your Rights
Right to Information: Request info about:
Right to Object: In certain circumstances, may object to international transfers. If transfer necessary for services, may be unable to accommodate; you may terminate account.
How to Request: Email [email protected]: Subject "International Data Transfer Inquiry"
10.6 Copies of Safeguards
Request copies of SCCs, UK Addendum, etc. by emailing [email protected]. Provided within 30 days (confidential commercial info redacted).
11. DATA RETENTION
11.1 General Principle
We retain personal information only as long as necessary for collection purposes, legal obligations, dispute resolution, and legitimate interests.
11.2 Retention Periods
[Comprehensive retention table by data category]
Account & Profile:
Transaction & Financial:
Communications:
Security & Compliance:
Analytics & Usage:
11.3 Extended Retention
May retain beyond standard periods for:
Notification: Where permissible, we notify affected users.
11.4 Data Minimization
We regularly:
11.5 Post-Deletion
After retention expires:
Anonymized data:
11.6 Backups
Backup Retention:
If You Delete:
11.7 User-Initiated Deletion
You Control Your Data:
Data Download Before Deletion:
What Happens When You Delete:
12. DATA SECURITY
12.1 Our Commitment
CGD Vibes implements reasonable administrative, technical, and organizational measures to protect your information from unauthorized access, disclosure, alteration, destruction.
12.2 Technical Measures
Encryption:
Authentication & Access:
Network Security:
Payment Security:
12.3 Organizational Measures
CGD Vibes implements reasonable organizational practices to protect your data:
Access Controls:
Vendor Management:
Incident Response:
12.4 Limitations & User Responsibility
No System is 100% Secure: Despite measures, no system guarantees absolute security. Internet transmission and electronic storage have inherent risks.
Your Responsibilities:
CGD Vibes Not Liable For:
Subject to applicable law and Terms of Service Section 15.
12.5 Third-Party Security
Payment Processors: Stripe, PayPal maintain:
Platform Provider: EzyCourse maintains:
13. DATA BREACH NOTIFICATION
13.1 Our Commitment
In the event of a data breach affecting your personal information, CGD Vibes commits to prompt and transparent notification.
13.2 Discovery & Initial Response (0-72 Hours)
Upon discovering a breach, we will immediately:
13.3 User Notification (Within 72 Hours)
We will notify affected users within 72 hours via email, including:
✓ Clear description of what happened
✓ Types of data affected (see categories below)
✓ When the breach occurred and when we discovered it
✓ Steps we're taking to secure the platform
✓ Recommended actions you should take
✓ Contact information: [email protected]
✓ Your privacy rights under applicable laws
13.4 Data We Control (Breach Risk Categories)
CGD Vibes directly controls and could be affected by a breach:
Account & Profile Data:
Transaction History:
Platform Activity:
User Content:
Data NOT at Risk (Managed by Stripe):
If Stripe experiences a breach of payment data, Stripe will handle notification directly as required by PCI-DSS and applicable law.
13.5 Immediate Protective Actions
If a breach occurs, we will automatically:
✓ Force password resets for all affected accounts
✓ Enable two-factor authentication (2FA) if not already active
✓ Increase monitoring for suspicious activity (90 days)
✓ Notify law enforcement if criminal activity suspected
✓ Notify regulators as required by law (PIPEDA, GDPR, state laws)
13.6 Recommended User Actions
We will advise affected users to:
✓ Change your password immediately (we'll force reset)
✓ Enable two-factor authentication
✓ Review your account for any unauthorized changes
✓ Be alert for phishing emails using your information
✓ Monitor your CGD Vibes account activity
If payment data potentially affected (via Stripe breach):
✓ Monitor bank/card statements for unauthorized transactions
✓ Consider placing fraud alerts with credit bureaus
✓ Contact your bank if you see suspicious activity
13.7 Ongoing Communication
13.8 Breach Support
Contact for Questions:
No Penalties: Users affected by a breach will NOT face penalties for:
13.9 Regulatory Compliance
We will notify authorities as required:
13.10 What We DON'T Offer
As a small platform, we do NOT provide:
However, if Stripe experiences a breach affecting payment data they manage on our behalf, Stripe may offer these services as required by their PCI-DSS obligations and insurance.
13.11 Prevention & Continuous Improvement
After any incident, we will:
14. COOKIES & TRACKING TECHNOLOGIES
14.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They help remember preferences, keep you logged in, and understand site usage.
CGD Vibes uses cookies and similar tracking technologies (web beacons, pixels, local storage).
14.2 Types of Cookies
For a complete, up-to-date list of all cookies and trackers in operation on the Platform, see our Cookie Policy.
14.3 Cookie Consent
Cookie Banner: When you first visit CGD Vibes, you'll see a cookie consent banner allowing you to:
Your Choices Saved: Preferences remembered for 12 months. Change anytime via cookie settings link in website footer.
Required by Law: Where required (EU, UK, certain US states), we won't set non-essential cookies until you provide consent.
14.4 Managing Cookies via Browser
Browser Settings: Control/delete cookies through browser settings. Note: Blocking essential cookies may prevent using certain features (login, purchases, etc.).
How to Manage:
Third-Party Opt-Out Tools:
14.5 Other Tracking Technologies
Web Beacons / Pixels: Small, invisible images in emails/web pages tracking:
Local Storage: HTML5 local storage for:
Server-Side Tracking: Some analytics performed server-side (via Stripe) without browser cookies:
14.6 Do Not Track (DNT)
Current Status: CGD Vibes does not currently respond to "Do Not Track" (DNT) browser signals (no industry-wide standard).
Your Privacy Not Affected: Even without DNT response, you can:
14.7 Cookie Policy Updates
May update cookie use from time to time. Material changes communicated through:
15. YOUR PRIVACY RIGHTS
Your rights vary by location and applicable laws.
15.1 Rights for All Users
Access: Request confirmation of processing + copy of your personal information
Correction: Request correction of inaccurate/incomplete information
Deletion: Request deletion (subject to legal exceptions)
Withdraw Consent: Withdraw consent anytime (doesn't affect prior processing)
Complain: File complaint with appropriate data protection authority
15.2 Quebec Residents (Law 25)
Additional Rights:
Access & Correction:
Data Portability:
Deletion:
Withdraw Consent:
Object to Use Beyond Consent:
Know & Be Informed:
Complain: File complaint with Commission d'accès à l'information du Québec (CAI):
French Language Rights:
15.3 Canadian Residents (PIPEDA) Rights:
Access & Correction:
Withdraw Consent:
Complain: File complaint with Office of the Privacy Commissioner of Canada (OPC):
15.4 EEA & UK Residents (GDPR/UK GDPR)
Comprehensive Rights:
Access (Article 15):
Rectification (Article 16):
Erasure / "Right to be Forgotten" (Article 17):
Restriction (Article 18):
Data Portability (Article 20):
Object (Article 21):
Automated Decision-Making (Article 22):
Lodge Complaint: File with your local data protection authority:
15.5 California Residents (CCPA/CPRA) Rights:
Know:
Delete:
Correct:
Opt-Out of Sale/Sharing:
Limit Use of Sensitive Information:
Non-Discrimination:
Authorized Agents:
Verification: For security, we'll verify your identity before processing requests:
Response Timing:
For More: See Section 18 for detailed California disclosures.
15.6 Other U.S. State Residents
States with Privacy Laws (as of 2026): Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), others
General Rights:
Specific state laws may provide additional rights. Contact [email protected] for state-specific information.
15.7 How to Exercise Rights
Methods:
Email: [email protected]
Subject: "[Your Right] Request" (e.g., "Access Request," "Deletion Request")
Include:
Account Settings (for some requests):
Mail:
N.W. Marketing Inc.
Attn: Privacy Officer
c/o CGD Vibes
204 rue du Saint-Sacrement, Espace 300
Montréal, Québec, Canada
H2Y 1W8
Response Timeline:
Verification:
For security, we'll verify your identity before processing requests involving access, correction, or deletion:
No Fee for First Request:
15.8 Appeals (U.S. State Residents)
If we deny your request and you reside in a US state with appeal rights (CA, VA, CO, CT, UT, etc.):
How to Appeal: Email [email protected] within 30 days of denial:
Appeal Review:
16. CHILDREN'S PRIVACY
16.1 Age Restrictions
CGD Vibes is not intended for children under 13 (or under 16 in EEA/UK where applicable).
Minimum Age:
16.2 No Knowingly Collecting from Children Under 13
CGD Vibes does not knowingly collect personal information from children under 13.
If We Discover a Child Under 13 Registered:
16.3 Age Verification (Current Practices)
Current Method:
Limitations:
Parental Notification:
If you believe your child under 13 created an account or provided information to CGD Vibes, contact [email protected] immediately. We'll delete account and information promptly.
16.4 Parental Consent for 13-17 (Not Currently Implemented)
Current Status: CGD Vibes does not currently have mechanism for obtaining/verifying parental consent for users 13-17.
Requirement for 13-17: Per Terms of Service, users 13-17 must have parental/guardian consent. However:
Future Implementation: Evaluating parental consent verification for compliance with:
16.5 Parental Rights & Controls
Parents and Legal Guardians Can:
How Parents Exercise Rights: Email [email protected]:
Verification: For security, we'll verify parental identity before providing access or deleting child's information:
16.6 Third-Party Services & Children
Third-Party Content: Platform may contain links to third-party websites/products/services not controlled by CGD Vibes.
Parental Responsibility:
No Targeted Advertising to Children:
CGD Vibes does not engage in targeted advertising directed at children or users known to be under 18.
16.7 Reporting Underage Accounts
If You Suspect Underage User: If you believe a user is under 13 (or under minimum age in your jurisdiction), report to [email protected]:
We'll investigate promptly and take appropriate action (account termination, data deletion).
16.8 Commitment to Children's Safety
CGD Vibes is committed to protecting children's privacy and safety online. We:
Report Child Safety
Concerns: Email [email protected] immediately for urgent child safety issues.
17. MARKETING COMMUNICATIONS & YOUR CHOICES
17.1 Types of Communications
Transactional (Cannot Opt Out): Essential emails:
You cannot opt out (necessary for services and legal compliance).
Marketing (Can Opt Out): Promotional emails:
You can opt out anytime (see 17.2).
17.2 How to Opt Out
Unsubscribe Link: Every marketing email contains "Unsubscribe" link at bottom. Click to:
Account Settings: Log in → Account → Settings → Communication Preferences
Toggle specific categories on/off (promotional, newsletters, recommendations)
Email Request: Send to [email protected]:
Processing Time:
17.3 Seller Communications
From Sellers You've Purchased From: Sellers receive your email and may send:
Seller Independence: Sellers are independent parties with own email marketing practices:
CGD Vibes' Responsibility:
17.4 Retargeting & Personalized Advertising
What is Retargeting?
Shows you CGD Vibes ads on other websites/social media after you visit our site.
How It Works:
Your Choices:
Opt Out via Cookie Settings:
Opt Out with Ad Platforms:
Browser Privacy Settings:
Industry Opt-Out Tools:
17.5 Personalized Recommendations
On-Platform Personalization: CGD Vibes may personalize by:
Opting Out:
17.6 Affiliate Emails
If You Join as Affiliate: By joining affiliate program, you consent to receive:
Affiliate Marketing Opt-Out:
17.7 Anti-Spam Compliance
CGD Vibes complies with anti-spam laws worldwide:
Report Spam: If you receive unsolicited/inappropriate emails claiming to be from CGD Vibes, report to [email protected].
18. CALIFORNIA-SPECIFIC DISCLOSURES
Additional disclosures required under CCPA/CPRA.
18.1 Notice at Collection
Categories of Personal Information Collected:
Company: CGD Vibes is operated by N.W. Marketing Inc. (Quebec, Canada).
Address: 204 rue du Saint-Sacrement, Espace 300, Montréal, Quebec, Canada, H2Y 1W8
Email: [email protected] | Privacy Officer: [email protected]
18.2 Sources of Personal Information
18.3 Purposes
We collect/use for business and commercial purposes described in Section 5:
18.4 Categories Disclosed
In preceding 12 months, CGD Vibes disclosed for business purposes:
We do NOT disclose protected classification, biometric, precise geolocation, or sensory data to third parties.
18.5 Sale or Sharing
CGD Vibes Does NOT Sell Personal Information: CGD Vibes has NOT sold personal information in preceding 12 months or at any time, and we do NOT sell personal information.
CGD Vibes Does NOT Share for Cross-Context Behavioral Advertising: CGD Vibes has NOT shared personal information for cross-context behavioral advertising (CPRA definition).
Why No "Do Not Sell My Personal Information" Link? Because we don't sell or share as defined under CCPA/CPRA, we're not required to provide "Do Not Sell or Share" opt-out link.
Cookies & Advertising: While we use cookies for advertising (Facebook Pixel, Google Ads, TikTok Ads):
18.6 Retention
For retention periods by category, see Section 11 (Data Retention).
18.7 Sensitive Personal Information
Limited Use: CGD Vibes collects/uses sensitive info (SSN, financial accounts, tax IDs) only for permitted purposes under CPRA:
No Additional Opt-Out: Because we use sensitive info only for permitted purposes, you don't need to opt out or limit use.
18.8 California Minors
Users Under 18: California residents under 18 can request removal of content they posted publicly.
How to Request: Email [email protected]:
Limitations:
18.9 California "Shine the Light" Law
California Civil Code § 1798.83 permits CA residents to request info about disclosure to third parties for direct marketing.
CGD Vibes' Response: CGD Vibes does NOT disclose personal information to third parties for their direct marketing. No "Shine the Light" disclosures required.
18.10 Authorized Agents
CA residents may designate authorized agent to submit privacy requests.
Requirements:
How to Submit: Email [email protected]:
19. CHANGES TO THIS PRIVACY POLICY
19.1 Right to Update
CGD Vibes may update this Privacy Policy to reflect:
19.2 Material Changes
Material Changes Defined: Those significantly affecting:
Notification for Material Changes:
Your Options: Before material changes take effect:
19.3 Non-Material Changes
Non-Material Defined:
Notification:
19.4 Staying Informed
Review Regularly: We encourage periodic review to stay informed.
Change Log: Summary of recent changes available at top of Privacy Policy (when applicable).
Email Notifications: To receive email notifications of all updates (including non-material):
20. CONTACT US & COMPLAINTS
20.1 Privacy Questions & Requests
General Privacy Inquiries:
Email: [email protected]
Subject: "Privacy Inquiry" or "Data Protection Request"
Mailing Address:
N.W. Marketing Inc.
Attn: Privacy Officer
c/o CGD Vibes
204 rue du Saint-Sacrement, Espace 300
Montréal, Québec, Canada
H2Y 1W8
Response Time:
20.2 Data Protection Officer
Privacy Officer:
Email: [email protected]
Mailing: (same as above)
Responsible for:
20.3 Complaints & Dispute Resolution
Internal Complaints: If you believe your privacy rights violated or dissatisfied with how we handled your request:
20.4 Regulatory Authorities
If unsatisfied with our response, file complaint with appropriate authority:
Canada (Quebec):
Commission d'accès à l'information du Québec (CAI)
Canada (Other Provinces):
Office of the Privacy Commissioner of Canada (OPC)
European Economic Area:
Contact your local data protection authority:
United Kingdom:
Information Commissioner's Office (ICO)
United States (California):
California Attorney General - Privacy Enforcement
US (Other States):
Contact your state attorney general's office or consumer protection agency.
20.5 Security Concerns
For urgent security matters (suspected breaches, unauthorized access, vulnerabilities):
Email: [email protected]
Subject: "URGENT - Security Issue"
Monitored 24/7 for critical security incidents.
20.6 Child Safety Concerns
To report child safety issues (underage accounts, inappropriate content involving minors):
Email: [email protected]
Subject: "Child Safety Report"
Reviewed immediately, escalated to law enforcement when appropriate.
20.7 Language Assistance
French Language Support (Quebec Residents):
Pour de l'assistance en français, contactez [email protected] avec l'objet "Assistance en français".
We respond to French-language inquiries in French within same timeframes as English.
ACKNOWLEDGMENT & ACCEPTANCE
By creating an account, accessing the platform, making a purchase, or using CGD Vibes services, you acknowledge that you have read, understood, and agree to this Privacy Policy.
CGD Vibes
Operated by N.W. Marketing Inc.
204 rue du Saint-Sacrement, Espace 300
Montréal, Québec, Canada, H2Y 1W8
General Contact: [email protected]
Privacy Officer: [email protected]
Security: [email protected]
Child Safety: [email protected]