Effective date: 1 April 2026 Last updated: 1 April 2026
1. About this policy
This Privacy & Cookies Policy explains how the Proactive Digital Solutions group (“Proactive Digital Solutions“, “we“, “us“, “our“) collects, uses, holds, shares and otherwise handles personal information when you interact with us, including when you visit proactivedigital.solutions and any of our other websites, products and services (together, the “Services“).
“Proactive Digital Solutions” is the trading name under which the following companies in the Proactive Group Holdings Inc. group operate:
| Region | Legal entity | Trading as |
|---|---|---|
| Canada / United States | Proactive Group Holdings Inc. (Adnet Communications is a trading name of Proactive Group Holdings Inc.) | Proactive Digital Solutions |
| United Kingdom / EU | Brighter IR Ltd | Proactive Digital Solutions |
| Australia / New Zealand | IRM Pty Ltd | Proactive Digital Solutions |
The entity that is the data controller / responsible organisation for your personal information will normally be the one in your region, or the one with which you (or your employer) have a contractual relationship. Contact details for each entity are at the end of this policy.
2. What we mean by “personal information”
“Personal information” (also referred to in some jurisdictions as “personal data”) means information about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether or not it is recorded in a material form.
3. The personal information we collect
The personal information we collect depends on how you interact with us. It may include:
- Identity and contact data: name, job title, employer, business address, email address, telephone number.
- Account and service data: log-in credentials, account preferences, records of products or services ordered, supplied or enquired about, and communications between you and us.
- Marketing data: your preferences in receiving marketing from us and your communication preferences.
- Technical and usage data: IP address, device and browser type, operating system, referring URLs, pages viewed, time spent, and similar information collected through cookies and analytics tools (see Section 11 below).
- Investor- and IR-related data: information you submit through investor relations features on websites we build or operate for our clients (for example, alert sign-up forms, investor centre registrations, or shareholder Q&A submissions).
- Limited payment data: for paying customers, basic billing information. We do not ourselves store full credit card numbers; payment card information is processed by our payment service providers.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date.
We collect personal information directly from you wherever practicable. We may also collect it from third parties (for example, your employer, public sources, our group companies, our service providers, or analytics and lead-identification providers).
4. How and why we use your personal information
We use personal information for a range of purposes, including:
- to provide, administer and improve the Services and any contract you (or your employer) have with us;
- to respond to enquiries, provide customer support and resolve complaints;
- to send you service communications, including notices about changes to the Services;
- with your consent or where otherwise permitted by law, to send you marketing communications about our products and services and those of other companies in our group;
- to operate, secure and improve our websites and to understand how visitors use them;
- to comply with our legal, regulatory and risk-management obligations, including assisting law enforcement, regulators and the courts where required;
- to detect, prevent and investigate fraud, abuse and security incidents;
- for internal management reporting, research, and aggregated/de-identified analysis; and
- where you have given consent, for any additional purposes described at the time of collection.
4.1 Legal bases (UK / EU users)
Where the UK GDPR or EU GDPR applies, we rely on one or more of the following legal bases:
- Contract: processing necessary to perform a contract with you, or to take steps at your request before entering into one.
- Legitimate interests: processing necessary for our legitimate business interests (for example, providing and improving the Services, B2B marketing to professional contacts, securing our systems), where those interests are not overridden by your rights.
- Legal obligation: processing necessary to comply with applicable law.
- Consent: where we have asked for and you have given consent — for example, for certain cookies and certain marketing communications. You can withdraw consent at any time without affecting the lawfulness of prior processing.
4.2 Australian users
If you are in Australia, we collect, use and disclose personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We will only collect personal information that is reasonably necessary for, or directly related to, one or more of our functions or activities.
4.3 Canadian users
If you are in Canada, we handle personal information in accordance with the *Personal Information Protection and Electronic Documents Act* (PIPEDA) and applicable provincial laws (including Quebec’s *Act respecting the protection of personal information in the private sector* (Law 25), and the BC and Alberta *Personal Information Protection Acts*). We rely on consent (express or implied) as required, and on other legal bases permitted by those laws.
4.4 US users
If you are a US resident, we process personal information in accordance with applicable US federal and state privacy laws, including (where applicable) the California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA“) and comparable laws in other states (such as Virginia, Colorado, Connecticut, Utah and Texas). Specific rights for US residents are described in Section 9 below.
5. Sharing your personal information
We treat your personal information as confidential. We will not share it with third parties except:
- with other companies in the Proactive Group Holdings Inc. group (including the entities listed in Section 1) for the purposes described in this policy;
- with our service providers and processors (for example, hosting and cloud providers, analytics and lead-identification providers, email and CRM platforms, payment processors, and professional advisers), who are required to keep your information confidential and to use it only on our instructions and for the purposes for which they are engaged;
- with our clients, where you have submitted information through an investor relations website or tool we operate on their behalf — in which case the client is the entity for whom the personal information is collected and you should also consult that client’s own privacy policy;
- with regulators, courts, law enforcement and other authorities where required or permitted by law, or to establish, exercise or defend legal claims;
- with any successor or acquirer in connection with a merger, acquisition, financing, restructuring or sale of all or part of our business; and
- with your consent, or otherwise as described at the time of collection.
We do not sell personal information for money. To the extent that “selling” or “sharing” is broadly defined under certain US state laws (for example, the CCPA’s definition of “sharing” for cross-context behavioural advertising), we describe how to opt out in Section 9.
6. International transfers
We operate internationally, and your personal information may be transferred to, stored or processed in countries other than the one in which you are located, including Canada, the United States, the United Kingdom, the European Economic Area, Australia and the Philippines, and other jurisdictions in which we or our service providers operate.
Where personal information is transferred out of the UK, the EEA, Australia or Canada, we put appropriate safeguards in place. These may include:
- transferring to countries that the UK or EU has determined provide an adequate level of protection;
- using approved Standard Contractual Clauses (or the UK International Data Transfer Agreement / Addendum), supplemented where required;
- relying on other lawful transfer mechanisms permitted under applicable law; and
- in the case of Australian personal information, taking reasonable steps to ensure overseas recipients comply with the APPs.
You may contact us using the details in Section 13 for further information about our international transfer safeguards.
7. How long we keep your personal information
We will retain your personal information for as long as necessary to provide you with the Services, to operate our business, and to comply with our legal, regulatory, accounting and risk-management obligations. After that, we will either securely delete it or de-identify it.
Where we have asked for your consent to send you marketing, we will retain your contact details for that purpose until you tell us you no longer wish to receive marketing from us.
8. Security
We take reasonable technical and organisational measures designed to protect personal information from loss, misuse, interference, unauthorised access, modification or disclosure. No method of transmission or storage is completely secure, but we work to maintain appropriate safeguards proportionate to the sensitivity of the information involved.
9. Your rights and choices
The rights you have in respect of your personal information depend on where you live and which laws apply.
9.1 Rights available to all users
Subject to applicable law, you may ask us to:
- confirm whether we hold personal information about you, and provide a copy of it;
- correct personal information that is inaccurate or out of date;
- delete personal information that we no longer need to retain;
- restrict or object to certain types of processing;
- withdraw any consent you have given (without affecting prior processing); and
- stop using your information for marketing.
Where applicable law gives you a right of data portability, you may also ask us to provide your personal information in a structured, commonly used and machine-readable format, or (where technically feasible) transmit it directly to another controller.
9.2 Specific rights for US residents
If you are a US resident covered by the CCPA or a comparable US state privacy law, you may also have the right to:
- know what categories of personal information we have collected, the sources, the purposes for which we collect or share it, and the categories of recipients;
- request deletion or correction of personal information, subject to certain exceptions;
- opt out of any “sale” or “sharing” (as defined under the CCPA) of personal information, and of targeted advertising;
- limit our use of “sensitive personal information” to specified purposes; and
- not be discriminated against for exercising any of these rights.
We do not knowingly sell personal information for monetary consideration. To exercise an opt-out from “sharing” for cross-context behavioural advertising, you can adjust your cookie preferences via the cookie banner on our site or contact us using the details in Section 13. We will honour Global Privacy Control (“GPC”) signals where required by applicable law.
You may designate an authorised agent to make a request on your behalf. We will take reasonable steps to verify your identity (and your agent’s authority) before responding.
9.3 Specific notes for UK / EU residents
You have the right to lodge a complaint with the UK Information Commissioner’s Office (the “ICO“) or your local data protection authority. We would, however, appreciate the chance to address your concerns first — please contact us using the details in Section 13.
9.4 Specific notes for Australian residents
You may complain about how we have handled your personal information by contacting us using the details in Section 13. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
In limited circumstances permitted by the Privacy Act, we may decline to give access to or correct your personal information. If we do, we will explain why in writing.
9.5 Specific notes for Canadian residents
If you have a concern about our handling of your personal information, you can contact us in the first instance. You also have the right to complain to the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) and, depending on where you live, to your provincial privacy regulator (for example, the Commission d’accès à l’information du Québec, or the Information and Privacy Commissioners of British Columbia or Alberta).
9.6 How to exercise your rights
To exercise any of these rights, please contact us using the details in Section 13. We will respond within the timeframes required by applicable law. We may need to verify your identity before acting on your request.
10. Marketing
We may send you marketing communications about our products and services and those of other companies in our group where permitted by applicable law. You can opt out at any time by:
- following the unsubscribe link in any marketing email;
- contacting us using the details in Section 13; or
- updating your preferences in our cookie banner where applicable.
In jurisdictions that require it (including the UK/EU for many electronic marketing communications, Canada under CASL, and Australia under the Spam Act), we will only send you electronic marketing communications where we have obtained the consent required, or where we are otherwise permitted to do so.
11. Cookies and similar technologies
11.1 What cookies are
Cookies are small text files that a website places on your device. They allow the site to recognise your device, remember your preferences, understand how the site is used, and (in some cases) deliver more relevant advertising. We use similar technologies (such as pixels, tags and local storage) for the same purposes — references to “cookies” in this policy include those technologies.
11.2 The categories of cookies we use
| Category | Purpose |
|---|---|
| Strictly necessary | Required for the site to function (for example, security, network management, recording your cookie choices). These cannot be turned off. |
| Performance / analytics | Help us understand how visitors use our site so we can improve it (for example, Google Analytics). Information is generally aggregated. |
| Functional | Remember choices you make (for example, language) to provide a more personalised experience. |
| Marketing / targeting | Used by us or our partners to measure the effectiveness of marketing campaigns and, in some cases, to deliver more relevant advertising. We also use lead-identification tools (such as Lead Forensics) to identify the businesses, not individuals, visiting our site. |
A current list of the specific cookies in use on proactivedigital.solutions is available via the cookie preferences link in the footer of the site. Because cookies on the new site will be re-audited at and after launch, the list will be kept up to date there rather than duplicated in this policy.
11.3 Managing your cookie preferences
When you first visit our site, you will be asked to accept or manage non-essential cookies via our cookie banner. You can change your preferences at any time using the “Cookie preferences” link in the footer.
You can also control cookies through your browser settings — most browsers let you block or delete cookies. Please note that disabling some cookies may affect site functionality. For more information about cookies generally, see allaboutcookies.org.
We will honour Global Privacy Control (GPC) and similar opt-out signals where required by applicable law.
12. Children
The Services are intended for business users and are not directed at children. We do not knowingly collect personal information from children under the age of 16 (or any higher age set by applicable local law). If you believe we have collected information from a child, please contact us so that we can delete it.
13. Contact us
You can contact us using any of the details below. Please direct your enquiry to the entity in your region where possible.
Canada / United States — Proactive Group Holdings Inc. Email: privacy@proactivedigital.solutions Post: 100 King Street West, Suite 7210, Toronto, ON M5X 1E1, Canada
United Kingdom / EU — Brighter IR Ltd Email: privacy@proactivedigital.solutions Post: 95 Southwark Street, London SE1 0HX, United Kingdom Telephone: +44 (0)207 264 3926
Australia / New Zealand — IRM Pty Ltd Email: privacy@proactivedigital.solutions Post: Level 11, 66 Clarence Street, Sydney, NSW 2000, Australia
For complaints to a regulator:
- UK: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF — 0303 123 1113 — ico.org.uk
- Australia: Office of the Australian Information Commissioner — oaic.gov.au — 1300 363 992
- Canada: Office of the Privacy Commissioner of Canada — priv.gc.ca — 1-800-282-1376
- United States: Your applicable state Attorney General or privacy regulator (for example, the California Privacy Protection Agency at cppa.ca.gov)
14. Changes to this policy
We may update this policy from time to time. The “Last updated” date at the top of this page tells you when it was most recently revised. If we make material changes, we will take reasonable steps to bring them to your attention.