Your data, plainly explained

Privacy Policy

RF Holdings Inc., operating as "Gardril" · Calgary, Alberta, Canada
Last updated: July 9, 2026 · Effective date: July 9, 2026

1. Introduction

1.1 About this notice

This Privacy Notice explains how we collect, use, disclose, and safeguard your personal information when you visit our websites (gardril.com and gardril.ca), create an account, take a course, verify your identity, earn a certificate, or receive a verifiable digital credential. The plain-language summary above is a quick guide only; the numbered sections that follow are the full notice and govern in the event of any conflict.

1.2 Who we are and how to reach us

RF Holdings Inc., operating under the trade name "Gardril" ("Gardril", "we", "us", "our"), is incorporated in Alberta, Canada, with its principal place of business in Calgary, Alberta. RF Holdings Inc. is the organization responsible for your personal information under Canadian privacy law and applicable U.S. state privacy laws, and the "enterprise" in charge of it under Quebec's Law 25 (the Act respecting the protection of personal information in the private sector).

1.3 Who this notice applies to

This notice applies to learners who use Gardril directly. Where a business, training organization, or safety association provides Gardril to its people under a separate agreement, that organization may act as the controller of the records it manages, and its own privacy terms and data-residency choices (see Section 6) may also apply. If you reached Gardril through your employer or another organization, contact them for their handling of your information.

2. Legal basis for processing

We process your personal information only when we have a valid basis under applicable privacy law. Which basis applies depends on what we are doing.

2.1 Performance of our contract with you

• Creating and running your account and delivering your courses
• Verifying that you earned your certificate and issuing it
• Processing your payment and meeting related tax and accounting duties

2.2 Our legitimate interests

• Protecting the integrity of a Gardril certificate through fraud and bot prevention — the core of what makes it trustworthy
• Securing the platform and preventing unauthorized access
• Maintaining, operating, and improving the service

2.3 Legal obligations

• Keeping payment records for the period tax and accounting law requires
• Retaining training records where a regulated sector requires it (see Section 7)
• Notifying you and the appropriate regulators of a reportable breach

2.4 Your consent

• Identity verification — specifically the biometric step, which runs under Asgard's separate explicit consent
• Issuing your certificate as a verifiable, publicly shareable digital credential
• Non-essential cookies

Consent is explicit, informed, and freely given. You may withdraw it at any time by emailing privacy@gardril.com, subject to records the law requires us to keep. Withdrawing consent never invalidates a certificate you have already earned.

2.5 Sensitive information

Biometric information is treated as sensitive information under laws such as Quebec's Law 25 and Illinois's BIPA. Gardril does not collect, see, or store any biometric data. The biometric identity check is performed entirely by Asgard Authenticate under its own explicit, informed consent, and Gardril receives only a pass/fail result. Your headshot photo is stored and displayed as an ordinary photograph; Gardril derives no biometric template from it and never uses it for biometric identification (see Section 3.4).

2.6 Automated identity decisions

Identity verification returns a pass or fail result, and a failed check can prevent certification. This step is not left entirely to software: you may ask us to have a person review a failed verification, and you can contest the outcome by emailing privacy@gardril.com. Where a decision is based exclusively on automated processing, Quebec's Law 25 gives you the right to be informed of it and to submit your observations.

3. Personal information we collect

We collect only what we need to run your account and issue a certificate that proves you earned it.

3.1 Information you provide

3.2 Information created when you use the platform

Using the platform also generates records about you: your course progress and completions, your certificate, the pass/fail result of identity verification (never the biometric data itself), a log of the consents you give, and — if you choose to receive a verifiable credential (Section 5.2) — a unique credential identifier.

3.3 Technical information

We collect routine technical data such as your IP address and timestamps, used to operate and secure the service. We process this under our legitimate interests (see Section 2.2).

3.4 About your headshot photo

Gardril derives no biometric template from your headshot and runs no facial recognition on it, so we store and display it as an ordinary photograph — it is never used for biometric identification by Gardril or Credential Vault. It appears on your certificate and, where issued, in your verifiable credential purely as a visual check that the credential is yours, like the photo on a driver's licence. The separate biometric identity match is done by Asgard, whose biometric data never reaches Gardril. The photo's job is this visual check, so an employer can see the credential belongs to you. Because it performs that function, the photo is part of the certificate itself and cannot be removed while keeping the credential.

3.5 What we do not collect

Gardril never collects or stores your biometric data or your full payment card number.

4. How we use your personal information

• Run your account and deliver courses — necessary to provide the service you signed up for.
• Verify your identity and issue your certificate — with your consent; the biometric step itself runs under Asgard's separate explicit consent.
• Issue your credential in a verifiable, portable form — with your consent, so you can prove your achievement to an employer or regulator and keep it in a wallet.
• Process payments — necessary to complete your purchase, with related tax and accounting obligations.
• Protect certificate integrity — fraud and bot prevention is the core of what makes a Gardril certificate trustworthy.

5. Disclosure and sharing of personal information

5.1 Service providers

We rely on a small number of trusted service providers to deliver specialized parts of the service. Each one processes your information only for that purpose, under its own published terms and under contractual data-protection obligations.

Gardril is the issuer of your credential and decides what it contains; Credential Vault stores and delivers it on Gardril's instructions and does not add to or change what it holds. If we add or change a service provider in a way that materially affects how your information is handled, we will post notice here and, where required, notify you or your organization.

5.2 Your verifiable credential and public verification

When you earn a Gardril certificate, it can also be issued as a verifiable digital credential through Credential Vault. This is built on two open, international standards — the W3C Verifiable Credentials data model and Open Badges 3.0 — so your credential is cryptographically signed, tamper-evident, and can be confirmed as authentic by anyone you share it with, without them having to contact Gardril. Because this makes your information shareable in a new way, we ask for your explicit, opt-in consent before enabling it.

The public verification page. Each verifiable credential has a verification page and QR code. When opened, it shows your name, your photo, the credential (course, issue date, and the criteria you met), Gardril as the issuer, and whether the credential is currently valid or has been revoked. Your photo appears here on purpose — it is how a viewer confirms the credential is yours — which also means anyone you share it with can see it. It does not show your email address or any payment or biometric data. The page is designed to be reachable by anyone who has the link; that is the whole point of a credential an employer can trust. You control who you share the link or QR code with, and where the standard supports it you can choose to disclose only parts of a credential.

Wallets and portability. Because your credential follows open standards, you can download it into a digital wallet — a W3C-compatible wallet, or Apple or Google Wallet where supported — and keep or present it independently of Gardril. Once a copy is in your wallet, or you have shared it with someone, that copy is under your control, not ours.

Revoking is not the same as deleting. If a credential ever needs to be invalidated — an error, or a certification that later lapses — it is revoked: its status is updated so it no longer verifies as valid, and anyone who checks it will see that it has been revoked. A status record is kept for this purpose; the original signed credential is never secretly altered. What revocation and deletion mean for you is set out in Section 7.

What stays private. Your email address, your payment information, and your biometric verification data are never shown on the public verification page or embedded in your credential. Credential Vault performs no facial recognition or biometric matching of any kind — your photo is stored and shown as a static image only.

5.3 Legal and regulatory authorities

We may disclose your personal information where we are required to by law, or where we have a good-faith belief it is necessary to comply with a legal obligation or lawful request, enforce our terms, or protect the rights, property, or safety of Gardril, our learners, or the public.

5.4 Corporate transactions

If Gardril is involved in a merger, acquisition, reorganization, or sale of assets, your personal information may transfer to the successor entity. We will notify you of any such change and of any choices you may have. A transfer as part of such a corporate transaction is not a "sale" of your personal information under laws such as California's CCPA/CPRA.

5.5 What we never do

We never sell your personal information. We never share it for third-party marketing without your consent. We never publish your email address, payment details, or biometric data.

6. International data transfers and data residency

7. Data retention

Training records and certificates are kept while your account is active and for as long as you choose to keep the credential — potentially for life, because a certificate is only useful if it lasts. You can request deletion at any time.

Verification results and consent logs are kept with the related training record as proof that verification and consent occurred.

Your verifiable credential. As the organization that issues your credential, Gardril sets the retention rule Credential Vault applies, so it matches this policy: your credential is kept while you want it, and revoked and removed on request. If you ask us to remove it, we revoke it (so it no longer verifies as valid), unpublish the hosted verification page, and instruct Credential Vault to delete its hosted copy and the personal data it holds for that credential. We cannot, however, retrieve or delete a copy you have already downloaded into a wallet or shared with someone else — that copy stays under your control.

Payment confirmations are retained as tax and accounting law requires, typically 6 years in Canada.

Account and technical data is deleted within 90 days of account closure, except records we must keep by law.

In some regulated sectors (mining, oil and gas, occupational health and safety), the law may require training records to be kept for a set period even after a deletion request — for example, for a regulatory workplace-fatality investigation. Where that applies, we will tell you before processing your request. For biometric data held by Asgard, we will direct your deletion request to Asgard, whose own retention and destruction practices are set out in its terms.

8. Your rights

Depending on where you live, you hold some or all of the following — and we honour the strongest set available to you:

• Access — a copy of the data we hold about you.
• Correction — fix inaccurate or incomplete data.
• Deletion — including your certificate; we comply except where the law requires retention. For a verifiable credential, deletion means we revoke and unpublish it (see Section 7); copies you have already saved to a wallet or shared stay under your control.
• Turn off public verification — you can ask us to unpublish or revoke your credential's verification page at any time while keeping the certificate itself.
• Portability — receive your data in a portable format; a verifiable credential is portable by design.
• Withdraw consent — at any time.
• Object or restrict — to certain processing.

To exercise any right, email privacy@gardril.com. We respond within 30 days (and within any shorter period a law that applies to you requires), after reasonable steps to verify your identity. Exercising your rights will never be held against you.

You may also complain to a regulator: the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, the Information and Privacy Commissioner of Alberta or British Columbia, or your state Attorney General in the United States.

9. Data security and breach notification

We protect your data with encryption in transit and at rest, access controls, hashed passwords, audit logging of consent, and contractual security obligations on our partners. Gardril itself holds no biometric data. For verifiable credentials, the cryptographic signing keys that make a credential trustworthy are protected with managed key-management infrastructure, and trust relies on tamper-evident signatures and a revocation status record rather than on exposing any of your personal data.

If a breach occurs that puts you at risk, we will notify you and the appropriate regulators without unreasonable delay, as PIPEDA, Quebec's Law 25, and applicable U.S. state laws require. We maintain a register of confidentiality incidents.

10. Age requirement

Gardril accounts are available only to learners aged 18 and older. We do not knowingly collect information from anyone under 18, and if we learn we have, we delete it promptly.

11. Cookies

We use only the cookies and local storage necessary to keep you signed in and operate the platform. Non-essential cookies are off by default and used only if you opt in.

12. Laws this policy honours

This policy is written for learners in Canada and the United States. In Canada, that means PIPEDA, the Alberta and British Columbia PIPAs, and Quebec's Law 25, which sets strict rules for sensitive information such as biometrics. In the United States, it means the FTC Act's requirement that we honour the promises on this page, state consumer-privacy laws such as California's CCPA/CPRA, state biometric-privacy laws such as Illinois's BIPA — under which the biometric step is performed by Asgard with your explicit consent — and every state's breach-notification law. Where any law gives you a stronger right, the stronger protection applies.

Where making your credential verifiable involves communicating your information outside Quebec — for example, to Credential Vault, whose operator and infrastructure are in Alberta and other Canadian regions — we carry out the assessment Quebec's Law 25 requires, and we remain accountable under PIPEDA for information we entrust to our service providers. Making your credential verifiable is never a "sale" of your data under laws such as California's CCPA/CPRA.

This policy and the consent materials are made available in French for Quebec learners — Lire la politique en français.

13. Changes to this policy

If we make material changes — especially to how identity verification works — we will notify you, and where the change is material to biometric handling we will ask for your fresh consent rather than relying on notice alone. Issuing your certificate as a publicly verifiable, wallet-portable credential is a change in how your information can be shared, so we ask for your fresh, explicit, opt-in consent before enabling it. The version and effective date always appear at the top of this page.

14. Contact

Privacy Officer, RF Holdings Inc. (operating as Gardril)
privacy@gardril.com

Definitions

Personal information — any information about an identifiable individual, such as your name, email address, or photo.

Processing — anything we do with personal information, including collecting, storing, using, sharing, or deleting it.

Controller / enterprise — the organization that decides why and how personal information is handled. For your Gardril account, that is RF Holdings Inc.

Service provider / processor — a company that handles personal information on our instructions and only for the purpose we set (for example, Asgard, Stripe, and Credential Vault).

Sensitive information — categories the law protects more strictly, including biometric data. Gardril holds none.

Biometric data — measurements of your body or face used to identify you. This is handled solely by Asgard; Gardril receives only a pass/fail result.

Verifiable digital credential — a cryptographically signed, tamper-evident version of your certificate, built on the W3C Verifiable Credentials and Open Badges 3.0 standards, that anyone you share it with can confirm as authentic.

Consent — your freely given, specific, and informed agreement to a particular use of your information, which you can withdraw at any time.