Conditions and policies

PRIVACY AND PROTECTION OF PERSONAL INFORMATION POLICY

Last update - May 17th, 2024

This policy (the "Privacy Policy") describes the manner in which and the purposes for which Tedy Financial Technologies Inc. ("Tedy", "we", "us", "our") collects, accesses, uses, processes, retains, protects and discloses personal information, personal data and any information that relates to an individual and allows that individual to be identified (the "Personal Information") in the course of its activities, services and administration (its "Activities"), in compliance with the Act. 

This Policy applies in particular to Personal Information that is collected from users of or visitors to the Tedy website and platform or from our customers, partners, users, and all persons doing business with us ("you", "Users", "your", "yours"). 

Acceptance Of The Policy

Your participation in our Activities and your use of our website (the "Website") and the Tedy platform (the "Tedy Platform") signifies your acknowledgement, acceptance and consent to our Policy and any changes in effect at the time of participation. If you do not agree with our Policy, please do not solicit our Activities and visit our Website and the Tedy Platform.

We reserve the right at any time, in our sole discretion and without liability, to update or modify the Privacy Policy without notice, and your continued access or use of the Services, the Tedy Platform or our Site will mean that you accept the updated or modified Privacy Policy. If we change it, we will update the "Last Updated Date" at the top of the Privacy Policy. By continuing to access the Site, the Tedy Platform or to use the Services, you are indicating that you agree to be bound by the revised Privacy Policy. If the revised Privacy Policy is not acceptable to you, please do not use the Site, the Tedy Platform or the Services. Be sure to check this page periodically for the most current version of the Privacy Policy.

For Which Purposes Do We Collect Your Personal Information?

We collect your Personal Information in order to carry out and optimize our Activities. We process your Personal Information only for the purposes for which you provided it to us, in accordance with this Privacy Policy and any applicable law, including with respect to the required form of consent.

More specifically, we use your Personal Information to: 

• Communicate with you and keep you informed about our Activities;
• Collect traffic data to evaluate our Activities;
• Optimize and personalize navigation on our Website and the Tedy Platform;
• Process refunds;
• Meet our legitimate interests.

Access To Your Personal Information

We collect your Personal Information when you directly and voluntarily provide it to us through our Website and Tedy Platform or in your interactions with us in person, by e-mail, telephone, mail, chat, online form, messaging and commenting on our social media or otherwise. The Personal Information you voluntarily provide to us may include:  

• Your first and last name ;
• Your e-mail address ;
• Your postal address ;
• Your telephone number ;
• Your date of birth ;
• Any other information, documents and comments you send us.

The Personal Information We Collect

We collect your Personal Information when you use the Activities, the Website, the Tedy Platform and we receive it from third-party companies that help us optimize our Activities. The Personal Information we collect from third parties is data generally associated with your digital identity, which is transmitted and dissociated from your personal identity when you browse online. These third-party sites are governed by their own policies relating to your personal information, which may differ from ours and may be applicable according to their own policies. This data includes :

Personal Information automatically collected by our Tedy Website and Platform

We collect certain Personal Information automatically when you connect to our Website or the Tedy Platform, including certain information about your computer or mobile device and data about your interaction with our Website, including operating system, browser type, make and model of your connecting device, your IP address, data about the path you take on our Website. This data collected automatically by cookies is not associated with your personal identity by Tedy.

Cookies

Tedy, like many website operators, may use a standard technology called "cookies" on the Website. Cookies are small data files that are downloaded to your computer when you visit a particular Inernet Site. You can enable cookies by turning them on in your browser; however, if you do not wish to enable cookies, some areas of the Sites may not function properly.

Personal Information from analytical tools

When you access our Website, we collect certain data from third-party analysis tools, such as Google Analytics or your mobile communications service provider. This data may include, for example, gender, age, municipality of residence and interests. This data is not associated with you personally and is transmitted to us in aggregate form by third-party analytics services. 

Personal Information from social media

We collect Personal Information transmitted by social networking websites or applications when you interact with profiles we hold on these social networking sites or applications. These sites or applications are governed by their own policies regarding your Personal Information, which may differ from ours and may be applicable.

Note that several tools, guides and options are available to you to avoid or limit the sharing of your Personal Information while browsing our Website, all from your browser settings.

Access To And Processing Of Personal Information

We do not sell your Personal Information.

Access to your Personal Information is limited to our employees who have the necessary access authorizations to carry out our Activities and the processing of your Personal Information is done solely for the purposes described in this Privacy Policy.

The processing of your Personal Information may be done using technology service providers, for example, Microsoft, MailChimp, Adobe and other technology service providers essential to the operation of our Activities. This includes technology service providers specializing in retargeting that process certain data without associating it with identifiable individuals. Our service providers are required to protect your Personal Information from unauthorized access, collection, use or disclosure and are held to the same level of protection of Personal Information as we are. Our service providers agree in writing to maintain the confidentiality of the data, not to use it for any purpose other than to provide services to us, and not to disclose your Personal Information to third parties.

To meet our legal obligations, we may have to disclose your Personal Information we have collected to third parties if expressly authorized or required to do so by law, or if we are compelled to do so by a competent authority, statute, regulation, warrant, subpoena or court order. We may disclose Personal Information in connection with legal proceedings if necessary to protect our rights or those of our Users.

Storage Of Personal Information

We keep your Personal Information until you ask us to destroy it or when our Activities no longer require us to keep it. By agreeing to this Privacy Policy, you consent to the retention of your Personal Information. We ensure that we retain your Personal Information in accordance with applicable legislation. 

Unless we are legally required or contractually bound to keep your Personal Information in Canada, it may be transferred outside of Canada. For example, some of our service providers may access, process or store your Personal Information outside your province or territory or outside Canada for the purposes of providing services to us. In the event that we transfer Personal Information outside of Quebec to our service providers for the purpose of collecting, using, disclosing or retaining Personal Information, we will conduct a Privacy Impact Assessment in accordance with applicable legislation prior to such transfer.  Our service providers are bound to the same level of protection of Personal Information as we are and are committed to using security measures to preserve data integrity and confidentiality.

Security Of Your Personal Information  

We work with external service providers specializing in IT security to ensure that we maintain best practices in IT, cybersecurity, encryption and data governance based on "least privilege" and "need to know".  

Computer security measures have been put in place in respect of our Activities to protect the loss, misuse and alteration of information under our control, including your Personal Information. Please note, however, that no data security measure can be guaranteed to be totally effective. Consequently, we cannot certify or guarantee the security of your Personal Information or other data held by us. You transmit Personal Information and other data to us at your own risk. In accordance with applicable laws, we have set up a confidentiality incident register.  

What Are Your Rights  

Access and rectification rights  

In accordance with applicable privacy laws:

• you have the right to ask us whether we hold any Personal Information about you and to obtain a copy of it if we do; and   
• you have the right to rectify any Personal Information that is inaccurate, incomplete or equivocal, or if its collection, communication or retention is not in compliance with or authorized under the Act respecting the protection of personal information in the private sector, RLRQ, c. P-39,1, you may demand that it be rectified.    

If you wish to have access to the Personal Information we hold about you, or if you wish to amend any Personal Information we hold about you that is inaccurate, you may make a written request to us at the data controller's address set out at the end of this Policy. 

We will respond to your request promptly (within 30 days of receipt).

Right to withdraw consent  

If you wish to withdraw your consent to the processing and storage of your Personal Information, please notify us in writing at the controller's address listed at the end of this Privacy Policy.

Upon receipt of notice of revocation of your consent, we will stop retaining your Personal Information within a reasonable period of time, which will vary depending on the Personal Information we have collected and the purpose for which we have collected it. 

Please note that if you continue to use the Website, the Tedy Platform or the Activities, it will not be possible to prevent the processing of your Personal Information. The only way to stop the processing of your Personal Information is to stop visiting the Website, the Tedy Platform, using the Activities and communicating with Tedy.

Please note that, in certain circumstances, we may refuse a request to delete your Personal Information, for example when the Personal Information is required to comply with the law, with a contractual agreement between the parties or in connection with a claim.  

Right to be forgotten

If the dissemination of your Personal Information (i) contravenes the law or a court order, or (ii) seriously harms your reputation or privacy, you may request in writing to our Privacy Officer that we restrict the dissemination of your Personal Information or that hyperlinks associated with your name that provide access to your Personal Information be de-indexed (i.e. removed from search results). Our Privacy Officer will respond to the request in writing within 30 days of receipt, unless applicable government authorities extend the time within which we must provide our response.

Right to portability 

Upon your written request, we will disclose to you, in a structured and commonly used technological format, any computerized Personal Information we have collected from you. At your request, we may also provide this information to a person or organization authorized to collect your Personal Information.  

Opposition

In certain circumstances, you have the right to object to the processing of your Personal Information that we carry out to meet your legitimate interests. Your rights in this respect depend, among other things, on where you live. If you wish to object to the processing of your Personal Information, please notify us in writing at the address of the controller indicated at the end of this Privacy Policy.

Complaint  

If you reside within the European Union, you have the right to lodge a complaint about the processing of your Personal Information with a privacy enforcement authority. This authority varies according to your country of residence.

If you reside outside the territory of the European Union, this Privacy Policy is governed by the laws and regulations applicable in Canada, and the Canadian authorities are exclusively competent to receive any complaint or claim based on this Privacy Policy or on Tedy's processing of your Personal Information.  

Verifications

We reserve the right to verify the identity of individuals seeking access to their Personal Information. Any information collected for this purpose will not be used for any other purpose.

Privacy Contact And Complaints Officer 

If you have any questions or concerns about this Privacy Policy, the processing of your Personal Information, or if you wish to exercise your rights or make a complaint, please contact Sydney Taylor-Wingender, CPO and Privacy Officer, directly by e-mail at sydney@tedy.app. The Privacy Officer is also responsible for, among other things, approving the privacy policies and governance practices we are required to establish and implement, and participating in the conduct of Privacy Impact Assessments ("PIAs") when required by law.

Please note that we will endeavour to respond to your questions, concerns or complaints as quickly as possible.

If we discover that our security measures have been breached and that there is a real risk of harm to you, we will contact you, unless prohibited by law.