Privacy Policy

Last modified: May 15, 2024

Echobox Memory Vault Ltd. and its affiliates or subsidiaries (“we“, “us“, “our“, and similar expressions) value your privacy and we want you to understand how we collect, use, share, and protect your personal information when you visit www.echobox.ca and any of its sub-domains (our “Website“), buy products through us, use our services, sign up for an account with us, use our Echobox software platform (the “Platform” and together with the foregoing, the “Services“), and otherwise interact with us. By using our Website or any of our Services, you are agreeing to the terms of this Privacy Policy.

1. What is personal information?
“Personal information” is generally any information about an identified or identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a natural person.

2. What personal information do we collect about you and how do we collect it?
There are several types of information we collect about you:

a. Information you give to us. We collect information that you give us directly. We typically identify the information we are collecting at the time we ask for it from you. While the categories of personal information we collect directly from you will change over time and will depend on the circumstances of our request, they may include the following:

• Information you upload. You give us your personal information when you upload it to the Platform or otherwise give it to us when we provide our Services to you. This includes information we collect when you complete a transaction with us or the information you provide in the selections and data input fields in the Platform or upload a file or other information to the Platform. Depending on your role (e.g., a customer or care provider), this information may include:

• Birthdate;

• General type of healthcare being received, such as hospice care, nursing, therapy, or physiotherapy;

• Identity of your caregiver;

• Name, email, and contact details;

• Age;

• Next of kin;

• Job title;

• Your photo;

• Family and friends relationships;

• Interests, likes, and other information included in the story blocks of our Platform.

• Interactions with caregivers. The Platform allows caregivers to connect with patients. A caregiver may input personal information into the Platform as they provide services to a patient. If you are a patient interacting with these caregivers, we may receive information about you that you give to caregivers using our Platform.

• Business information. We may ask you for information about your business, your finances, expenses, tax details, details about your customers, vendors, or employees, or other business information when you use our Services.

• Contact data and account profile data. We collect personal information you give us directly to create an account or profile with us. For example, if you are an authorized user of our Platform you may be asked for information, such as an email address, first and last name, and username and password, to access our Services. You may also provide us with other optional information as part of your profile, such as avatars or profile images, other contact information, and links to social network profiles you have (including when used for authentication purposes).

• Data in contracts and other legal agreements. We may also collect information directly from you for contractual or legal reasons. For example, we may ask you for your address and other contact details to give you notices under the contract for our Services and to determine the taxes we may need to charge you.

• Information to verify your identity. At our request, you may give us information to verify your identity, which may include your name, date of birth, social security number, social insurance number, driver’s license number, passport number, government-issued identification details, and similar information to verify your identity.

• Communications. You may give us personal information you include in your communications with us, such as information you include in SMS (text) messages, form submissions on the Website, communication means in the Services, and other electronic messages between you and us (collectively, “Electronic Messages“), or by phone or mail.

• Marketing preferences, surveys, contests, or promotions. If you select preferences for marketing communications, participate in surveys or contests, or take part in our promotions, we may ask you for and you may choose to provide us with your personal information.

• Social and community content. When you post on our social media pages and the public areas of our Website (e.g., if you post a comment on an article we feature on the Website), you may be giving us personal information that you include in your content.

• Device data. If you grant permission in your device settings, certain features of our Services may have access to your device and the information stored on it to provide the functionality intended by our Platform. We will tell you which device permissions we need when you install our software.

• Payment processing information. If you have made a purchase through us, or if you make a financial transaction using our Services, we or any third-party payment processors we use will collect information about the purchase or transaction. This includes billing details, credit card information, account, and authentication information.

• Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive tools across the Platform.

b. Information about you that we get from other sources. We may receive personal information about you from other parties where you have provided consent to the third-party to share your information or where we are permitted by applicable law to receive the information. We protect and process the personal information we receive from third parties as described in this Privacy Policy, consistent with any additional restrictions imposed by the source of the information. Our third-party sources may vary over time and depend upon how you use the Services. For example, we receive information from:

• Users of our Services. If you are an authorized user of our Platform, an account administrator may give us personal information about you, such as your name and email addresses, to allow you to access and use the Services on behalf of the accountholder.

• Interactions with caregivers. The Platform allows caregivers to connect with patients. A caregiver may input personal information into the Platform as they provide services to a patient. This information may come directly from the patient, or it may be provided to the caregiver by the patient’s relative, personal representative, next of kin, or a friend or personal connection. These parties may give us personal information about you if you are a patient. This personal information is used by us in the ways intended by our Services; it is not used for other purposes without consent of the individual or an appropriate exception under applicable laws.

• Supplemental information and identity verification providers. We also collect personal information about you from third parties that assist us with verifying your identity.

• Service providers. We use a variety of third-party service providers to help us deliver our Services and these service providers may give us information about you. For example, we may get information from our marketing service providers to support our marketing initiatives, improve our Services, and better monitor, manage, and measure our ad campaigns, such as details about when our service provider shows you one of our ads on or through its advertising platform. We may hire research firms that help us understand our market and if allowed under applicable laws, these researchers may provide us with personal information. We may receive personal information about you or your interaction with the Services from certain third parties we use to support our troubleshooting activities, for example when we obtain information through customer support interactions, such as technical issues that have been submitted to us, call center recordings, call monitoring records, voicemails, photographs, file uploads, and chat records. We also sometimes use third-party integrations with our Platform or our Website, and the third-party providing the integration may collect personal information about you and provide it to us so that we may deliver our or make our Website or Platform available to you.

• Business partners. We may also collect information about you from our business partners that assist us with providing our Services, developing our business, and understanding our market. For example, if we partner with another company to collaborate on a new feature of our Platform, we may receive personal information about you from that other company.

• Linked third-party services. If you choose to integrate a third-party service that we make available to you, we may receive information from that third-party service according to your settings, agreements, or preferences with that third-party.

• Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our offerings, including to help combat fraud and illegal activity and to help protect your personal information.

• Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through webinars, conferences, or live events.

• Government agencies. We may receive information from government agencies, including from various tax agencies, to help verify your business information or to facilitate your use of our Services.

• Public information. We may collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.

c. Automatic data collection. We, our service providers, and our business partners may automatically collect personal information about you, such as:

• Information from your use of the Website and Services. We collect personal information about you when you use our Website and Services. This includes information like your Internet protocol (IP) address, your geographic location, the website you visited before coming to our Website, your browser type and settings, log data, your device information (for example, if you’re using a tablet, mobile phone, or desktop computer and the operating system), the date and time when you visited the Website, information about your browser configuration and plug-ins, your language preferences, and other unique identifiers.

• Usage information. We may collect information about your use of our Services, such as the pages you viewed on our Website, the services and features you used or interacted with on our Website or in our Platform, your browser or device type, and details about any links or communications with which you interacted.

• Location information. Certain features in the Platform may collect your precise location information, device motion information, or both, if you or your organization grant(s) us permission to do so through your device settings.

• Information stored locally. Some of our web-enabled desktop services and offerings synchronize with the information on your computer. If you choose to use our desktop services, in doing so we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.

• Communication interaction data. We or our third-party service providers may collect information from email providers, chat applications, communication providers, and social networks, such as your interactions with our email, text, or other communications (e.g., whether you open or forward emails). We may do this through use of pixel tags (also known as clear GIFs), which may be embedded invisibly in our emails.

• Online behavioral data. We may automatically collect certain personal information about your use and interactions with our Website, social media websites, and marketing campaigns that we or our service providers organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you has been viewed, delivered, opened, clicked on, whether it has bounced, or was treated as spam.

• Information from cookies and other tracking technologies. We collect information about you through cookies and similar tracking technologies to provide and support our Website and the Services.

d. Sensitive personal information. We generally prohibit sensitive personal information from being used with our Services, such as untruncated financial account identifiers (e.g., credit card numbers or bank account numbers), untruncated government issued identifiers (e.g., social insurance numbers), or other types of sensitive or special category data that is subject to specific or elevated data protection requirements under applicable laws, where the use of such data is not intended by the functionality of the Platform. If, however, we collect sensitive personal information from or about you, it will be identified at the time we request it. Please note we cannot monitor all data input into our Platform, Website, or other Services by Customers or third parties, including sensitive personal information, and to the maximum extent allowed by law, we will not be liable for how such sensitive personal information is collected, used, or shared.

e. Biometric information. Certain parts of the Platform make use of biometric personal information (“Biometric Information“). We will not collect your Biometric Information without first providing notice and obtaining your consent.

3. How do we use your information?

a. To make our Website and Services available to you. We use your personal information to provide our Website and Services to you and to respond to your requests. This may include:

• Providing the Platform to you;

• Running and managing our business, including resolving billing and financial disputes;

• Evaluating your eligibility for marketing offers, products, and services;

• Providing a product, feature, or service that you have requested through the Platform;

• Understanding your needs and interests, and personalizing your experience with the Services and our communications;

• Providing you with support and resolving disputes;

• Managing event registrations and attendance, including sending related communications to you

• Registering visitors to our offices for security reasons

b. To fulfill the purposes for which you provided the information to us. We use your personal information when you give it to us for a specific purpose or for reasons that were described when it was collected, such as providing Services to you, or any other purpose for which you provide it, including for any other reason described in this Privacy Policy.

c. To connect you with others. We may use your personal information to connect you with other people and businesses in the way intended by our Services. For example, if you are a patient we may connect you to a caregiver.

d. To determine your eligibility. We may use your personal information to evaluate your eligibility for marketing offers, products, and services.

e. To communicate with you. We use your personal information to communicate with you, including to send you Electronic Messages and other communications about the Services and your relationship with us.

f. To verify your identity. We may use your personal information to verify your identity. If we are interacting with you in person, such as when you attend our offices, events, or the location of others that are providing a venue on our behalf, we may use your personal information for security purposes, such as creating a visitor or attendee log. When you sign into your account, we may receive necessary information about you through single-sign-on (SSO) integrations (e.g., signing in through a social media or email account) or authentication applications to verify that you should have access to the data stored within the Platform or Website.

g. To market and promote our business to you. We use your personal information to market our Website, Services, and business to you, including through surveys and promotions. We may use your information to send you tailored marketing communications about products, services, offers, programs, and promotions of ours and those of our partners and measure the success of those campaigns. For example, we may send different marketing communications to you depending on what we think may interest you based on other information we hold about you, we may decide not to advertise our Services to you on a social media site if you already follow us, and we may choose to serve you a particular advertisement based on your service choices with us.

h. To customize your experience. We use your personal information to provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering your preferences.

i. To create inferences and for profiling. We use personal information we collect from you and the other sources identified in our Privacy Policy to create a profile about you to reflect your preferences, characteristics, behavior, and other similar characteristics to better understand you and how our Website and Services may be relevant to you. Some jurisdictions give individuals a right to have profiling activities restricted. Please contact our Privacy Officer with any requests or information about our use of your personal information for profiling.

j. To improve our Website, Services, and customer experience, and for general research and development. We use your personal information to analyze and learn about how you access and use the Website and Services, to evaluate and improve our Website and Services (including by developing new products and services and managing our communications), and to monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized, or aggregated information which does not focus on you individually. For example, if we learn that most people using our Services in a location or for a particular purpose tend to use a specific integration or feature, we might wish to expand on that integration or feature.

k. To de-identify or anonymize your personal information and to aggregate it with other data. We combine and anonymize information about your interactions with us to create de-identified personal information, anonymized data, and aggregated data for research and development, marketing, promoting, improving, and developing our Services. Personal information does not include information that has been anonymized in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information. We may use your personal information to create this kind of anonymized or aggregated data.

l. To make our Website and Services secure. We use your personal information to keep our Website and our Services secure, such as when we use your personal information to verify your access credentials or to display data to you.

m. To enforce our rights and to meet our obligations. We use your personal information to carry out our obligations and enforce our rights under contracts and our terms of service, for billing matters, or to comply with legal requirements. We may also use your personal information to protect our and others’ interests, rights, and property where we have a legitimate interest in doing so.

n. To comply with the law. We use your personal information to comply with applicable legal requirements, such as tax and other government regulations, contracts, and law enforcement requests.

o. Notices about our relationship with you. We will also use your personal information to give you notices about your relationship with us.

p. Whistleblower reporting. When you report any concern of non-compliance, unethical conduct, or other alleged violation of our policies or terms of service, personal information you provide will be processed as a part of the investigation of the allegations and retained in accordance with our internal policies until the investigation is complete. While we make every effort to maintain confidentiality, depending on the investigation, disclosing your identity to other individuals may be necessary.

4. When do we use your information?

a. Consent. We use your personal information when you have consented to the use of it in a particular way. When you consent, you can change your mind at any time and if you withdraw your consent, unless there is a clear and appropriate exception under applicable law, we will cease using your personal information. We’ll normally let you know when personal information is required, and the consequences of failing to provide it or withdrawing your consent. If you do not provide personal information when requested, you may not be able to use all or some of our Services if that information is necessary to provide you with the Service or if we are legally required to collect it.

b. Implied Consent. In some limited circumstances, in the ways allowed by privacy laws, and only when the information is not sensitive, we will use your personal information when your consent to its use is implied. For example, if we tell you that we will be collecting your personal information and using it for a certain purpose and you do not refuse your consent within a reasonable period of time, unless stated otherwise under privacy laws, we may imply your consent. This may happen, for example, if you call us and we advise you that we will be recording the conversation and you do not object or end the call.

c. Exceptions to Consent. In some circumstances, such as to respond to an emergency that threatens your security or to prevent fraud, we may use or disclose your personal information without your consent to the extent allowed by privacy laws.

5. How do we share your personal information?
In addition to other scenarios we have discussed in this Privacy Policy, we may share your personal information in the following ways:

a. For certain product features. We may share your personal information in the ways intended by the functionality of our Services. For example:

• We may use third party integration services to enable you to use certain product features made available by third parties. When you use these third-party integrations, you consent to us sharing your personal information with the owner or operator of the third-party integration. You also acknowledge that you may be bound by the third party’s privacy policy. You may manage your data by visiting the third party’s security settings page or by contacting the third party.

• Our Services involve connecting individuals to businesses that may provide products or services requested by or of interest to the individual. When we connect businesses to individuals, we may share personal information to allow the parties to decide whether they wish to enter into a transaction or do business together. For example, we may share the personal information of a patient with a caregiver using the Platform to provide services to an individual.

b. Affiliates and subsidiaries. We may share personal information with our affiliates and subsidiaries when it is reasonably necessary or desirable, such as to help provide services to you or to analyze and improve the services we or they provide, or for other purposes that we identify at the time we collect the personal information from you.

c. Business partners. We may share personal information with our business partners. For example, we may share your personal information when our Website, Services, or other assets are integrated with the services of other parties, but only when you have been informed or would otherwise expect such sharing.

d. Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, and to send marketing and other communications on our behalf. We also use third parties to assist us to complete purchase and order requests, to provide us with managed cloud hosting and web services, and process credit card payments. We use a variety of technological solutions provided by third parties, which include, for example, customer relationship management (CRM) systems and technology to provide the necessary software, networking, infrastructure, and other services that we use to operate the Website and Services. We only share your personal information when you have been informed or would otherwise expect such sharing or as disclosed at the time the information is collected.

e. When you connect to your social media account. Some of our features enable you to connect to a social media account or share information on social media platforms. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Policy). You should take care only to share information on social media that you are comfortable sharing.

f. Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property, or interests, or to prevent fraud or abuse. We may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements. The laws regarding how this personal information may be used will vary by jurisdiction.

g. Our own advertising. We share personal information with third parties so we can provide you with tailored advertising for our business and measure and monitor its effectiveness. For example, we may share your actual or pseudonymized email address with a third-party social media platform on which we advertise to avoid serving ads to people who already use our Services.

h. Business transfers. If we’re involved in a reorganization, merger, acquisition, or sale of some or all our assets, your personal information may be transferred as part of that deal or the negotiation of contemplated deals.

i. To provide insights, metrics, and benchmarking data. We share personal information to provide insights, metrics, and information that other organizations, people, and companies may find useful as follows: to help promote or sell its own products or services; to provide market insights and economic data; or for other purposes we disclose to you at the time we collect the information. We only provide anonymized or anonymous aggregate data for such purposes unless we have your permission in advance or as otherwise disclosed at the time the information is collected.

j. For research. With appropriate controls, we may share information with third parties, such as academic institutions, government, and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that does not identify any individual.

k. For legal reasons. We may share your personal information with third parties for legal reasons without your consent, and as permitted by law, including: when we reasonably believe disclosure is required to comply with a subpoena, court order, or other applicable law, regulation or legal process; to protect our, our customers’, and others’ rights, property, or safety; to enforce, remedy, or apply our terms of service or other agreements; to detect or prevent fraud, cybersecurity attacks, or illegal activity; for debt collection; and with regulatory agencies, including government tax agencies, as necessary to help detect and combat fraud, or protect our customers, users, or as required for risk control programs.

6. Artificial Intelligence (AI) and automated decision-making.
We may use artificial intelligence, machine learning algorithms, and forms of automated decision-making. For example, we may use automated decision-making to prevent risk and fraud, to personalize your experience and make it more efficient, and to determine eligibility for certain services or features we offer on our Website and through our Services. We may also use such technologies to provide and improve the Website and Services and how we deliver them to you. Some jurisdictions give individuals a right to have these automated decisions reviewed by a person or otherwise limited. Please contact our Privacy Officer with any requests or information about our use of automated decision-making technologies with your personal information.

7. Your rights and choices.

a. Rights to access, update, or change personal information. Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, or change your personal information.

b. Rights to delete personal information. Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to delete or de-index your personal information. Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. When we delete your personal information, it will no longer be retrievable. Please ensure you have exported or otherwise saved your personal information before you ask us to delete it.

c. Withdrawal of consent. If we rely on consent for the collection, use, or disclosure of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the collection, use, or disclosure of your personal information before your withdrawal of consent. Please note that if you withdraw consent, certain features of the Service may not have full functionality because certain features rely on your personal information to work as intended.

d. Data processing. Some jurisdictions’ laws may give you the right to restrict or object to the processing of your personal information or to exercise a right to data portability (e.g., to transfer your data to another processor).

e. Data portability. Some jurisdictions’ laws may give you the right to data portability (e.g., to transfer your data to another processor).

f. Commercial electronic messages. Like many other companies, we may ask you to sign up to receive emails, text (SMS) messages, and other Electronic Messages from us. If you no longer wish to receive those messages, you can opt-out by following the unsubscribe link in the messages or by contacting us.

g. Complaints. You have the right to lodge a complaint with a competent supervisory authority, subject to applicable law.

8. How to exercise your rights.
You can exercise your rights under this Privacy Policy and applicable privacy laws by contacting us at feedback@echobox.ca or by calling our offices, or accessing, updating, or changing your personal information directly in your account with us (if we provide that functionality on the Website or in the Platform) or by following any instructions on opting-out of collection, use, or disclosure of your personal information that we make available to you. Please note that we may need to verify your identity in connection with your requests, and such verification process may require you to provide us with additional information (e.g., government identification). If we are unable to verify your identity or request, we may not, in accordance with applicable law, be able to fulfill your request

9. Please use caution when posting on the public areas or features of our Website and Services.
You may be able to post or make public communications on certain areas of our Website or Services, such as comments and questions fields, discussion forums, in-Platform communication functions, and other public discussion mechanisms. These kinds of communications are made at your own risk. Although we may monitor or even control these types of public posts, we are under no obligation to do so. We also cannot control the actions of other users of the Website or Services, including how they will use your public posts and any personal information you include in them. We cannot and do not guarantee that unauthorized persons will not view your public posts or respect your privacy.

10. Where we may store and process your information.
We are based in Alberta, Canada and we may process, store, or transfer personal information in Canada and any of its provinces or territories.

We or our third-party sub-processors may also process, store, or transfer personal information outside of Canada. Locations other than Canada may have different privacy laws, which may be more or less protective. If we move personal information to a location other than Canada, the governments, courts, law enforcement, or regulatory agencies of that country may have access to your personal information through their laws. In addition to Canada and any of the provinces within Canada, your personal information may be collected, used, disclosed, or stored for any purpose stated in this Privacy Policy in these other regions:

United States

GDPR

When we transfer, store or process personal information outside of your jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Statement and applicable law.

Some of the recipients of your personal information are located in countries for which the European Commission or UK Government (as and where applicable) have issued adequacy decisions, which means that these countries are recognized as providing an adequate level of data protection under applicable UK or European data protection laws and the transfer is therefore permitted under Article 45 of the GDPR.

Other recipients of your personal information are located in countries outside the European Economic Area (EEA) or the UK that are not the subject of an adequacy decision. In these cases, we may use the Standard Contractual Clauses approved by the European Commission or, as may be applicable, the International Data Transfer Agreement approved by the UK Government, to help ensure your personal information is protected.

We may be subject to the investigatory and enforcement powers of the Federal Trade Commission and other US law enforcement agencies in accordance with applicable US data privacy laws.

11. How do we keep your personal information secure?
We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, and any other personal information entrusted to us. Our information security systems apply to people, processes, and information technology systems on a risk management basis. No method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee the absolute security of your personal information.

12. How long do we keep your personal information?
In general, we keep your personal information throughout your relationship with us. Once you terminate your relationship with us, we will continue to store archived copies of your personal information for legitimate business purposes in accordance with applicable laws, like defending or enforcing a contractual claim, for audit purposes, to resolve disputes, and to comply with the law. We will continue to store anonymous or anonymized information, such as website visits, statistical and usage data, or benchmarking data, without identifiers, to improve our Website and Services. There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

13. Children and privacy.
Our Website and its features and the Services are not meant for children under 13 years of age. If you are under 13 years old, please do not give us your personal information. If you are the parent or guardian of someone under 13 years of age, please do not give us personal information of that person.

14. How to contact us about privacy questions.
If you have a question or a concern about our Privacy Policy or your personal information, please get in touch with us. Our Privacy Officer can be reached at feedback@echobox.ca.

15. Changes to our Privacy Policy.
We may update this Privacy Policy from time to time to reflect, for example, changes to our privacy practices or for other operational, legal, or regulatory reasons. If we make material changes to this Privacy Policy, we will give you notice of such changes by posting the revised policy on our Website, and where appropriate, by other means. By continuing to use the Website or the Services after these changes are posted, you agree to the revised policy.

Region specific terms

Additional terms may apply to you based upon the country you reside in or the products you use. These additional privacy terms, notices, and statements are below.

1. Québec privacy statements.

a. Québec residents. This section applies only to Québec residents. It describes how we collect, use, and share personal information of Québec residents in our capacity as an “enterprise” under the Act respecting the protection of personal information in the private sector (“Private Sector Act”) and your rights with respect to that personal information. For purposes of this section, the term “personal information” has the meaning given in the Private Sector Act but does not include information exempted from the scope of the Private Sector Act. Please note that we may claim legal exemptions for certain types of personal information from all or certain parts of the Private Sector Act. In some cases, we may provide a different privacy notice to certain categories of Québec residents, such as employees and job applicants, in which case that notice will apply instead of this section.

b. Data residency. Personal information may be communicated outside of Québec. Unless exempted under the Private Sector Act, prior to communicating personal information outside of the province we take into account (1) the sensitivity of the information, (2) the purposes for which it is to be used, (3) the protection measures that would apply to it, and (4) the legal framework applicable in the jurisdiction in which the information would be communicated, including the legal framework’s degree of equivalency with the personal information protection principles applicable in Québec. The information may be communicated if the assessment establishes that it would receive protection equivalent to that afforded under the Private Sector Act. We also ensure that where required under the Private Sector Act, the communication of the information is subject to a written agreement that considers the results of our assessment and, if applicable, the terms agreed upon to mitigate the risks identified in the assessment.

c. De-indexing. Under certain conditions, you may have the right to have the personal information we make available about you through hyperlinks de-indexed or re-indexed with correct information. To exercise this right, please contact our Privacy Officer.

d. Portability. You may request portability of your personal information in a readily usable format. To make such a request, contact our Privacy Officer or access the settings available in your account.

e. Access. You may request a copy of the personal information by contacting our Privacy Officer or accessing the settings available in your account.

f. Correction. You can edit and correct your personal information at any time by changing it directly in our products and services or by contacting our Privacy Officer or accessing the settings available in your account.

g. Withdraw consent. If we communicate your personal information with your consent, you can withdraw your consent at any time.

h. Third persons to whom we communicate your personal information. If applicable, you have the right to be given the name of the third person for whom your personal information is being collected, and the names of the third persons or categories of third persons to whom it is necessary to communicate the personal information for the purposes for which it was collected.

2. United Kingdom (UK) and European Economic Area (EEA) statements.

a. UK and EEA residents. This section applies only to UK and EEA residents. It describes how we collect, use, and share personal information under: (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation) ( “EU GDPR”); (ii) the Switzerland Federal Act on Data Protection of 19 June 1992 (SR 235.1) and its subsequent revisions (“FADP”); and (iii) the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom’s European Union (Withdrawal) Act 2018 (“UK GDPR” and collectively with EU GDPR and FADP, “European Privacy Laws”); and (iv) any and all applicable national data protection laws made under, pursuant to or that apply in conjunction with any of (i), (ii), or (iii); in each case as may be amended or superseded from time to time. For the purposes of this Privacy Policy, “personal information” means “personal data” under European Privacy Laws.

b. Legal basis of processing. We use your personal information only as permitted by law. Applicable European Privacy Laws require us to have a “legal basis” for each purpose for which we collect your personal information. Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the type of personal information and the specific context in which we collect it. However, we will normally process personal information from you when:

• We have your consent to do so;

• We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefits of the Services and operate our business;

• The processing is in our legitimate business interests, such as operating our businesses, improving, and developing the Services, communicating with you, marketing our offerings and services, and personalizing your experience, and to detect illegal activities; or

• To comply with legal requirements, including applicable laws and regulations.

c. Your European Privacy Law rights. As a resident in a region where European Privacy Laws apply, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Access. You may request a copy of your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Correction. You can edit and correct your personal information at any time by changing it directly in our products and services.

• Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. You may delete your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Objection and restriction. You may object to our processing of your personal information or ask us to restrict processing of your personal information.

• Portability. You may request portability of your personal information.

• Withdraw consent. If we process your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

• File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information. You can find your data protection regulator here.

• Manage marketing communications from us. You have the right to opt-out of direct marketing. To update your marketing communication preferences, you can go to the marketing preference tools in your account settings or contact us. You may also click unsubscribe at the bottom of the marketing emails.

• Cookies and other tracking technologies. You have the right to opt-out of interest-based advertising, including through cookies and tracking technologies, through the means we provide on our Website.

• Automated decision making and profiling. You have the right to not have your personal information be subjected to automated decision making or profiling.

3. Australia privacy statements.

a. Australian residents. This section applies only to Australian residents. It describes your rights and

b. Your Australian rights. As a resident in a region where Australian Privacy Law applies, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Update your privacy settings. You may update your privacy settings by visiting your account settings.

• Access. You may request a copy of your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Correction. You can edit and correct your personal information at any time by changing it directly in our products and services.

• Objection and restriction. You may object to our processing of your personal information, including for marketing purposes, or ask us to restrict processing of your personal information. If you request that we stop processing some or all of your personal information or you withdraw (where applicable) your consent for our use or disclosure of your personal information for purposes set out in this privacy notice, we might not be able to provide you all of the Services generally offered to our customers.

• Manage marketing communications from us. You have the right to update your marketing communication preferences, which you can do by accessing the marketing preference tools in your account settings or by contacting us. You may also click unsubscribe at the bottom of the marketing emails.

4. Colorado privacy statements.

a. Colorado residents. This section applies only to Colorado residents. It describes how we collect, use, and share Personal Data of Colorado residents in our capacity as a business under the Colorado Privacy Rights Act (“CPA”) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the CPA but does not include information exempted from the scope of the CPA. Please note that we may claim legal exemptions for certain types of personal information and certain companies in our group of companies from all or certain parts of the CPA.

b. Your Colorado privacy rights. As a Colorado resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Access. You may request a copy of your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Correction. You can edit and correct your personal information at any time by changing it directly in our products and services.

• Opt-out of tracking for targeted advertising purposes. You can submit requests to opt-out of tracking for targeted advertising purposes by visiting the “Manage Cookies” or “Privacy Settings” link in the footer of our website. We do not otherwise “sell” your Personal Data to third parties for monetary consideration.

• Opt-out of profiling. You can opt-out of the automated processing of your Personal Data to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements, to the extent this results in decisions that produce legal or similarly significant effects.

• Sensitive Personal Data. We will not process your sensitive personal data without your consent.

• Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Colorado privacy rights.

• Authentication. To protect your Personal Data from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect that your account has been accessed without your authorization, we may ask you to provide additional personal information for verification.

5. Connecticut privacy statements.

a. Connecticut residents. This section applies only to Connecticut residents. It describes how we collect, use, and share Personal Data of Connecticut residents in our capacity as a business under the Connecticut Data Privacy Act (“CDPA”) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the CDPA but does not include information exempted from the scope of the CDPA. Please note that we may claim legal exemptions for certain types of personal information and certain companies in our group of companies from all or certain parts of the CDPA.

b. Your Connecticut privacy rights. As a Connecticut resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Access. You may request a copy of your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Correction. You can edit and correct your personal information at any time by changing it directly in our products and services.

• Sensitive Personal Data. We will not process your sensitive personal data without your consent.

• Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Connecticut privacy rights.

6. Virginia privacy statements.

a. Virginia residents. This section applies only to Virginia residents. It describes how we collect, use, and share Personal Data of Virginia residents in our capacity as a business under the Virginia Consumer Data Protection Act (“VCDPA”) and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the VCDPA but does not include information exempted from the scope of the VCDPA. Please note that we may claim legal exemptions for certain types of personal information and certain companies in our group of companies from all or certain parts of the VCDPA.

b. Your Virginia privacy rights. As a Virginia resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Access. You may request a copy of your personal information by contacting our Privacy Officer or accessing the settings available in your account.

• Correction. You can edit and correct your personal information at any time by changing it directly in our products and services.

• Sensitive Personal Data. We will not process your sensitive personal data without your consent.

• Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your Virginia privacy rights.

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