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Gruber Partners (DBA Direct Objective Consulting) - Terms of Use and Privacy Policy

Terms of Use and Privacy Policy

    1. Disclaimer:

The contents of Gruber Partners, Inc. (“Gruber Partners”)’s website are provided for informational and educational purposes only.

2. Definitions:

For the purposes of this Terms of Use and Privacy Policy, the following definitions apply:

i) “Privacy Policy” refers to this document and any updated versions posted to this website at a future date. The Terms of Use and Privacy Policy governs the collection and use of information as detailed in the document. The terms “Policy” and “Privacy Policy” may be used interchangeably throughout the document. 

ii) “Identifiable Individual” refers to an individual or business which may be distinguished, identified, or contacted through the use of information provided to Gruber Partners either directly or through the website applications as detailed in the Privacy Policy. 

iii) “Personal Information” refers to data collected by Gruber Partners through all means, including digital, oral, written, or otherwise. This information includes, but is not limited to:

a) Identity Information such as title, authentication details, and electronic data gathered by website applications as detailed in the Privacy Policy; 

b) Contact Information such as name, business name, email address, physical address, telephone number; and

c) Preference Information such as the types of services you use, demographic information, language settings, location, and communication preferences. 

iv) “Customer” refers to a person or business either actively or formerly engaged with Gruber Partners, as detailed in the Privacy Policy. 

v) “Potential Client” refers to a person or business who has expressed interest, either express or implied, in the services offered by Gruber Partners, either through the use of this website or other means. 

vi) “Third Party” refers to any person or business that is not part of Gruber Partners. 

vii) “User” refers to a person or business engaging with the website as a visitor of the website. 


3. Privacy Policy:

Protecting your privacy and the confidentiality of your Personal Information is very important to us and fundamental to the way we do business at Gruber Partners.

This Privacy Policy confirms our commitment to our clients and website visitors that we may collect and use Personal Information responsibly, safely, and only for the purposes and in the manner set out in this Policy. Gruber Partners is committed to protecting your Personal Information and maintaining high standards of confidentiality through the implementation of appropriate administrative, technical, and operational safeguards and security measures. We strive to be open and transparent with you as to our Personal Information practices.

We encourage you to read this Privacy Policy so that you can understand how we collect, use, and protect your Personal Information and how you can manage your information in a way that best suits you. By providing your Personal Information to us, you are consenting to the collection and use of your information as set out in this Privacy Policy and as otherwise permitted or required by law.

We may update this Privacy Policy from time to time without prior notice and will post the revised Policy on our website. Policy changes will apply to the information collected from the date of posting to the website, as well as to existing information in our records.

How We Collect Your Personal Information

Gruber Partners collects Personal Information to provide our services to our Customers and Potential Clients.

As a Customer and User of our services, most of your Personal Information is provided to us directly by you.

Depending on the service you use, we may also collect information about you from third parties. For example, to fulfill a complete profile, we may use various data services to allow us to learn more about yourself or your organization so that we can better serve you and personalize our services to you.

The Personal Information we collect is gathered in a number of ways throughout your relationship and dealings with us as a Customer. We offer various methods for communication with us, including by mail, email, phone, fax, and through our website. Personal information collected through each of these methods will be protected through our administrative, technical, and operational safeguards and security which we have implemented and described in this Policy.

We also collect information on, and track the behavior of visitors to our website. For further information on this collection, please see the “Collection of Information Through Gruber Partners’ website” section below.


We will obtain your consent to collect, use, and/or disclose personal information except where we are authorized or required by law to do so without consent.

Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be provided orally, in writing, electronically, through action (such as when you click submit on any of the forms on our website), or otherwise. Implied consent may be obtained through your use of our services or when you approach us to obtain information, inquire about, or apply for services from Gruber Partners. By providing Personal Information to us, you agree that we may collect, and use such Personal Information as set out in this Privacy Policy and as otherwise permitted or required by law.

In certain circumstances, Personal Information can be collected, used, or shared without knowledge and consent. For example, we may collect, and/or use Personal Information without your knowledge or consent where:

    • the Personal Information is publicly available from a prescribed source, such as a telephone directory, etc.;
    • we have your implied consent.

You may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to Gruber Partners. Please see the “Your Privacy Choices” section below for further information on withdrawing consent.

Information We Collect

Personal information is any information about an “identifiable individual” that can be used to distinguish, identify or contact a specific individual. The Personal Information that we collect will depend on which of the services you request or use and how you use them. The Personal Information that we collect falls into the following categories:

Identity Information that allows us to identify and authenticate you;

Contact Information that allows us to communicate with you;

Behavioural Information about how you use our website or services;

Relationship and Preference Information that helps us to understand more about you, including what types of services or offers you may like (e.g., language and communication preferences, location, demographics, and interests).

We limit the Personal Information we collect to only what is required to carry out the purposes set out in the “Use of Information” section below. Any additional information about you that we would like to collect to assist us in understanding your profile, needs, and in providing you with services, will be clearly indicated as “optional”.

Use of Information

As a Client, the main reason why we collect and use Personal Information is to maintain relationships with, and provide services to our Customers. To facilitate that objective, we collect and use your Personal Information for the following purposes:

    1. To establish and maintain communications with you, and disseminate to you information of interest;
    2. To help us to better understand your needs and what services may be of interest to you, including through surveys and review and analysis of your relationship with us, including your visits to this website;
    3. To compile statistical data and carry out research;
    4. To offer and market services that we believe will be of interest to you;
    5. To detect and prevent fraud, identity theft, and other illegal acts;
    6. To perform our everyday business operations; and
    7. To comply with applicable laws.

By providing your Personal Information to us, you are consenting to the collection and use of your information as set out in this Privacy Policy and as otherwise permitted or required by law.

Information Sharing

Gruber Partners does not sell, trade, or rent lists or Personal Information of Customers to third parties for their own use, unless you provide consent.

However, we may release your Personal Information to parties outside of Gruber Partners under certain circumstances, without your consent, as set out below:


    • Suppliers and Corporate Partners

      In order to facilitate the provision of services to you, we may require the assistance of Third Party suppliers and corporate partners and need to share your Personal Information with them from time to time. This would include, for example,  Third Party suppliers that we engage to facilitate completion of a mandate. Only the information that is required for that purpose will be disclosed. Such suppliers and corporate partners must follow our strict confidentiality standards to protect that information and are required to use it only for the purposes for which they have been engaged. These suppliers and corporate partners may be located in Canada or in other jurisdictions or countries which may provide for different data protection rules and may be subject to demands or requests for information from legal or government authorities in those locations.

    • Responding to Legal, Compliance, or Regulatory Obligations

      Sometimes it may be necessary for Gruber Partners to disclose Personal Information of our Customers to meet legal, compliance, or regulatory obligations. This would include, for example, a request by a government official for information. In such cases, we will release only the information that is required, and only after confirming that the appropriate legal authority to require such information is in place.

    • Prevention of Illegal Acts

      Information may also be disclosed by us to third parties outside of Gruber Partners where we are of the view that it is necessary to do so in order to detect and prevent fraud, identity theft, and other illegal acts. Such disclosure would be limited to what is required and subject to the Third Party both having the appropriate legal authority and providing a commitment to confidentiality and restricted use.


By providing your Personal Information to us, you are consenting to the collection and use of your information as set out in this Privacy Policy and as otherwise permitted or required by law.

Protecting Your Information

At Gruber Partners, we take the protection of your Personal Information seriously. We are committed to protecting your Personal Information and maintaining high standards of confidentiality through the implementation of appropriate administrative, technical, and operational safeguards and security measures so as to prevent any unauthorized access, disclosure, copying, use, or modification of your personal information.

We have security standards and safeguards to protect our systems and your information against unauthorized access and use. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. Safeguards will vary depending on the sensitivity, format, location, and storage of the personal information. Said safeguards may include limiting access to Personal Information to representatives of Gruber Partners on a need-to-know basis, storing Personal Information on computers, servers, files, or sites with encryption protection and password entry, and utilizing locked filing cabinets with restricted physical access to the file storage location for physical documents containing personal information.

To ensure the integrity and privacy of the Personal Information you pass to us via the Internet when you make an online transaction, Gruber Partners has implemented safeguard and security measures that are compliant with  industry-standards. All information collected within a secure page is encrypted while being transmitted to Gruber Partners’ secure server. The server is protected by a firewall that is regularly updated when new patches and fixes are released.

Our suppliers, as part of their contracts with Gruber Partners, commit to maintain the confidentiality of your information and not use it for any unauthorized purpose.

For all disclosures, we disclose only the information that is legally required.

All employees of Gruber Partners are familiar with the procedures that must be taken to safeguard Customer information. Protecting the confidentiality of your Personal Information is more than a procedure – it is part of our job.

Gruber Partners regularly audits our procedures and security measures to ensure they are being properly administered and that they remain effective and appropriate to the sensitivity of the information.

The length of time for which we keep your information will vary depending on the service and the type of information we have. We retain your information only as long as we reasonably need to for customer service, legal, or reasonable business purposes. That period may extend beyond the end of your relationship with us, but only for so long as it is necessary for us to be in a position to respond to an issue that may arise at a later date, or for legal or regulatory purposes.

When your Personal Information is no longer required for these purposes, we have procedures in place to destroy, delete, erase, or convert it to an anonymous form.

Keeping Your Information Accurate

Gruber Partners takes reasonable efforts to ensure that any Personal Information in its possession is accurate, current and complete as is necessary for the purposes for which the information is to be used, as set out in this Policy. We count on you to keep your Personal Information current and advise us of any changes to your Personal Information as and when they occur. Keeping your information accurate and up-to-date enables us to continue to offer you the highest quality service.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

Information contained in files that have been closed is not actively updated or maintained.

Accessing Your Information

As a Customer, you have the right to access all Personal Information we hold about you. 

Upon written request and authentication of identity, we will provide you with your Personal Information under our control, and information about the ways in which that information is being used.

We may charge a fee for providing information in response to an access request and will provide an estimate of any such fee upon receiving an access to information request. We may require a deposit for all or part of the fee.

We will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.

In some situations, we may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal Personal Information about another individual, the Personal Information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation, disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of Gruber Partners, or where we exercise our solicitor’s lien against materials in our files in respect of outstanding accounts. 

Where an access request is refused, we will notify you in writing, documenting the reasons for refusal and outline further steps available to you.

If you have questions about our Personal Information practices, please reach out to us using the information in the “Contact Us” section below.

Collection of Information Through Gruber Partners’ Website

By accessing and browsing our website, you agree that we may collect and use any information we collect about you through our website, as described in this Policy.

    • Cookies and Other Web Tracking Tools

      Gruber Partners uses various web tools including cookies, web beacons, embedded script, and tagging on our website, as well as various analytics and marketing services from third parties.

      The web tools may be used for a number of purposes, including but not limited to counting visitors to our website, to monitor how visitors navigate the website, to determine the date and time of your visit to our website, the documents that you downloaded, the searches you performed, to count how many emails that were sent were actually opened, or how many, and which, particular articles or links were actually viewed. Web tools will not be used to collect Personal Information that is not expressly provided by a visitor.

      These Web tools help us to better serve visitors by managing our website, diagnosing any technical problems, remembering information about your visits (e.g. login credentials, preferences), improving the content of our website, and communicating with you regarding products and services that may be of interest to you.

    • Social Media Tracking Pixels and Cookies

      We may also use social media cookies embedded on our website to communicate with our visitors who are registered users of certain social media platforms (e.g., LinkedIn, Facebook, Twitter, YouTube, etc.). We use Web data, including email addresses and other Personal Information expressly provided, to create custom audiences by retargeting advertising to visitors and similar social media users of these platforms in order to deliver more useful and relevant content. The use of social media by Gruber Partners adheres to the policies set forth by each social media platform.

      All data matching takes place using secure one-way hash functions, such that no Personal Information of our visitors is provided to the social media platforms if the visitor is not already registered with the social media platform.

    • Digital Marketing

      From time to time, we may engage in digital marketing campaigns. These efforts may include using social media platforms to promote goods and services. You consent to us using your Personal Information to serve advertisements and other announcements. When we do so, we follow the protocols and procedures established by service providers such as the Google Display Network and other leading advertising exchange platforms. You consent to us working with digital media channels in this manner.

      We may also track your activity on other websites or social media platforms that you visit after leaving the Gruber Partners website for the purposes of delivering advertising campaigns that may be of interest to you.

    • Links to Other Websites

      Please note that our website may contain links to other sites and advertisements. Our Privacy Policy only applies to information collected by our website. We are not responsible for the privacy practices and policies of such Third Party sites or advertisements.

    • Withdrawing Your Consent to Cookies

      If you wish to withdraw your consent to cookies, you should review the help documentation for your web browser software to decline or selectively decline cookies by adjusting the setting on your browser. Declining cookies may adversely impact website performance.

Customers From Outside Canada

Gruber Partners is subject to and complies with Canada’s Federal Privacy legislation, known as the Personal Information and Protection of Electronic Documents Act (PIPEDA).

If you are located in the European Union (EU), you should know first of all that, as a result of the comprehensive privacy protections provided to data subjects under PIPEDA, personal data flow from the EU to Canada has been approved by the adequacy decision of the European Commission under its European Directive. While Gruber Partners is not directly subject to the General Data Protection Regulation (GDPR), most of the rights granted to you under the GDPR are substantially similar to those granted to data subjects under PIPEDA, including the right to request access to, correct, amend, delete, or limit the use of your personal data. Please refer to the “Accuracy of Your Information” and “Access to Your Information” sections above for further information.

If you have any questions about our Personal Information practices, please reach out to us using the information below in the “Contact Us” section.

Your Privacy Choices

You can withdraw your consent to various aspects of our collection, use, or sharing of your Personal Information at any time upon giving us reasonable notice, subject to legal, business, or contractual requirements.


    • Consent to Collection

      As indicated in the “Information We Collect” section above, we limit the collection of Personal Information to that which is necessary and required to provide you with our products and services and carry out the purposes set out in the “Use of Information” section above. As such, withdrawal of consent to collection of required Personal Information may result in our inability to provide services for which that information is necessary. If we ask for additional information, we will clearly indicate that it is optional for you to provide that information, and if you do provide it, you are free to withdraw your consent at any time, and such information will be deleted.

    • Consent to Use

      You may withdraw your consent to certain uses of your personal information. From time to time Gruber Partners may offer and market services that we believe will be of interest. This includes marketing through various communication methods, including mail, phone, email, and website digital marketing.

      Consent to receiving this information is optional and you can decide to withdraw it at any time by contacting us directly or through our website.

      Upon receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide services for which that information is necessary.

Contact Us

We will promptly respond to questions and concerns relating to our Personal Information practices and this Policy, and do our utmost to resolve your concerns. If you have any questions or concerns about this Privacy Policy, please contact us at:

Attn: Privacy Officer

Gruber Partners, Inc.

4035 Rue St-Ambroise Suite 209

Montreal, QC, H4C 2E1 Canada


4. Liability:

Gruber Partners shall not be liable to you and/or any Third Party for any damages of any kind arising out of or relating to the use of this website including, but not limited to, any lost profits, lost opportunities, special, incidental, indirect, consequential, or punitive damages. Gruber Partners assumes no responsibility to you or any Third Party for the consequences of any errors or omissions on this website.

This website links visitors to sites that are not maintained by Gruber Partners. Gruber Partners cannot and does not warrant the accuracy, completeness, timeliness, non-infringement, merchantability, and fitness for a particular purpose of the information available through these links and disclaims any opinions expressed on such websites.