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INTELLIPAY PRIVACY POLICY

Last updated: April 15, 2025

Effective date: May 22, 2024

Convenient Payments, LLC, dba IntelliPay (“IntelliPay”) is committed to maintaining robust privacy protections for its users.  The terms “we,” “us,” and “our” refer to IntelliPay, IntelliPay.com, and its affiliates. “You” refers to you, as a user of our website. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our website.

By using our website, you accept our Privacy Policy, and you consent to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy. In addition, by using our services, or services across partnered and unaffiliated sites, you are accepting the policies and practices described in this Privacy Policy and such other sites. Each time you visit our website, and any time you voluntarily provide us with information, you agree that you are consenting to our collection, use, and disclosure of the information that you provide.

“Customer” refers to the customer of an organization that provides the IntelliPay platform for accepting and processing payments.  “IntelliPay Platform” refers to the software developed by IntelliPay to accept and process transactions.

COLLECTION OF INFORMATION

Within this website, no account or personal information is obtained for storage on our or our transfer agent’s systems other than the information you enter. This information is used only to provide you with the information or materials that you specifically request.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We collect the domain name and other user information of site users and visitors to our website and aggregate information on what pages site users and visitors access or visit.

The information we collect is used to improve the content of our web page, used to notify site users and visitors about updates to our website, shared with agents or contractors who assist in providing support for our internal operations, and used by us to contact site users and visitors for marketing and advertising purposes, but not shared with other organizations for commercial purposes. This information is collected through web server logs and cookies that allow us to track the aggregated statistics and data from our visitors as they utilize our website.

DISCLAIMER

We provide you information on this website for informational purposes only.

We try to provide our site users and visitors with accurate and timely information. We have relied on sources we believe to be reliable; however, the website may include inadvertent technical or factual inaccuracies; as such, we do not warrant the accuracy or completeness of the information and/or materials provided, either expressly or impliedly, and expressly disclaim any warranties of merchantability or fitness for a particular purpose.

Decisions based on information contained on this site are the sole responsibility of the site user and visitor, and in exchange for using this website, you agree to hold us harmless against any claims for damages arising from any decision you make based on the information provided on this website.

Neither IntelliPay nor any of its affiliates, directors, officers or employees, nor any third party vendor, will be liable or have any responsibility for any loss or damage that you incur in the event of any failure or interruptions of this site, or resulting from the act or omission of any other party involved in making this site or the data or information contained in it available, or from any other cause relating to your access to, inability to access, or use of the site or these materials.

We reserve the right to withdraw or prohibit access to the site and to revise the software, materials, information, and services and products described on this website, at any time without notifying users.

PERSONAL INFORMATION AND NO SHARE CLAUSE

We do not collect personal information from you unless you provide it to us in conjunction with an application for a merchant account or any other service we offer. The information collected such as your name, company name, financial account information (e.g. credit card information, bank account information), date of birth, social security number, tax number, or Employer Identification Number, bank account number, email address, and phone number, is used for the underwriting, approval and set up required for the service you request.

We do not license, sell, rent, or trade any collected business information about your account or other personal information unless you request it. The personal information you provide is to help complete a transaction initiated by you, or the disclosure is otherwise lawfully permitted or requested.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

In the event of a merger, acquisition, or sale of all or a portion of IntelliPay’s business or assets, your personal information may be transferred to the acquiring entity. This transfer is essential to ensure the uninterrupted provision of services to our customers by the new entity.

SECURITY

The security of your personal information is important to us. We follow generally accepted standards designed to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at support@intellipay.com.

CORRECTING AND UPDATING YOUR PERSONAL INFORMATION

Upon request, we will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting your sales representative directly, or you may contact us at support@intellipay.com or 855-872-6632, Option 2. We will respond to your request within a reasonable timeframe.

CUSTOMER TRANSACTION INFORMATION

If you are a customer of an organization that offers the IntelliPay platform to accept and process transactions, and when as a customer make payments or conduct transactions through our application, we will receive your transaction information. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The implementation by the organization that provides the IntelliPay platform for payment processing will determine the payment methods that it enables you as a customer to use, and the payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to. When you as a customer make a transaction, we may also receive your name, email, billing or shipping address, and in some cases your transaction history to authenticate you.

When we conduct fraud monitoring, prevention, and detection activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection, and prevention services may use technology that helps us assess the risk associated with an attempted transaction.

This website is owned and operated by IntelliPay, and the information (and any intellectual property and other rights relating thereto) are and will remain the property of IntelliPay and its licensors and suppliers.  IntelliPay hereby grants you the right to view and use this website subject to the terms and conditions of this agreement.  You may download and/or print a copy of the information provided on this website for your personal use only.  Permission to reprint or electronically reproduce any document or graphic in whole or in part for any other purposes is expressly prohibited unless prior written consent is obtained from the respective copyright holder.  Modification of the website or information or use of the website or information for any other purpose is a violation of IntelliPay’s copyright and other proprietary rights and is strictly prohibited. You acknowledge that you do not acquire any ownership rights by using the website or the information. The trademarks, logos, and service marks displayed on the website (collectively the “Trademarks”) are the registered and unregistered Trademarks of IntelliPay, IntelliPay’s licensors and suppliers, and others.

BLOGS

Our website may offer publicly accessible blogs and may provide community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at support@intellipay.com.

TESTIMONIALS

With your consent, we may post your testimonial along with your name. If you want your testimonial removed, please contact us at support@intellipay.com.

EMAIL LISTS

We maintain email lists to keep interested parties informed about our company, events, products, support, promotions, and more. Emails are sent out periodically, and contain valuable information for our merchants, agents, partners, and other interested parties. The emails often contain web beacons, which collect information such as a cookie identifier and the time and date that the email was viewed or opened. They allow us to track how many people opened our emails. We do not sell the addresses on our list, but we may make information available to specific business partners, sponsors, or service providers.

To be removed from our mailing list, simply click the unsubscribe link provided within each email.

SMS COMMUNICATIONS

Collection and Use of Mobile Phone Numbers:

When you provide your mobile phone number and opt into our SMS messaging service, we collect and store this information to send you text messages as described in our terms. We may use this information to:

  • Send you transactional messages about your account or purchases
  • Provide promotional offers, updates, and information you’ve requested
  • Respond to your inquiries and support requests

SMS Data Retention:

We retain your mobile number and related messaging data for as long as you remain subscribed to our SMS service, plus any additional period required for legal compliance or business purposes.

Sharing of SMS Data:

We may share your mobile number with third-party service providers who help us deliver our SMS communications. These providers are contractually obligated to use your information solely for delivering our messages and according to our instructions

BEHAVIORAL TARGETING

We use Google AdSense to display advertising on our website and to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect non-personally identifiable information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here <http://www.google.com/privacy_ads.html>. Please note, this does not opt you out of being served advertising. You will continue to receive generic ads.

MINORS

We do not market to or solicit data from minors. The services we provide are for businesses with owners and principals 18 years of age or older.  You represent and warrant you are at least 18 years of age and that you possess the legal right and ability to use this site.  This site does not direct content to minors and does not intend to collect information from minors and therefore is not subject to the Child Online Privacy Protection Act.

INDEMNIFICATION

You agree to indemnify, defend and hold IntelliPay, our affiliates, licensors, suppliers, advertisers and sponsors, and our and their directors, officers, employees, consultants, agents, and other representatives, harmless from and against any and all claims, damages, losses, costs (including reasonable attorneys’ fees) and other expenses that arise directly or indirectly out of or from: (a) your breach of this agreement; and/or (b) your activities in connection with the website.

CALIFORNIA RESIDENTS

Please see our <California Privacy> Statement if you are a California resident.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this policy and our Terms of Service at any time.  We will notify you of significant changes to our Privacy Policy by placing a prominent notice on our site.  Significant changes will go into effect within 30 days following such notification.  Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.

CANADA

INTELLIPAY PRIVACY POLICY -PERSONAL INFORMATION PROTECTION AND ELECTRONIC DOCUMENTS ACT  (PIPEDA)

Effective Date: September 2, 2025

INTRODUCTION

Convenient Payments, LLC dba IntelliPay (“we”, “us”, “our”, or “IntelliPay”) is committed to fulfilling its responsibilities under the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and protecting the personal information of its clients and others. For the purposes of this privacy policy (the “Policy”), “you” and “your” refers to both customers and non-customers of IntelliPay.

This Policy applies to IntelliPay website and describes how IntelliPay collects, uses, and discloses your personal information. This Policy describes the choices that you have with respect to how IntelliPay handles your personal information whether you are a client or non-client and tells you how IntelliPay is accountable for the personal information that it collects.

IntelliPay may update this Policy from time to time. This Policy is current as of the approval date at the bottom of this Policy, and IntelliPay encourages you to review this Policy before you provide any personal information to IntelliPay.

CONSENT 

By visiting IntelliPay website, by providing your personal information to IntelliPay, or by completing a transaction with IntelliPay, you are consenting to the collection and use of your personal information on the terms set out in this Policy. If you provide IntelliPay with personal information about other individuals, then by doing so you are representing and warranting to us that you have obtained their consent and are doing so in compliance with applicable law.

You can choose not to consent to the collection or use of your personal information. If you do not consent, then do not provide IntelliPay, or any of its third-party service providers, with any of your personal information and do not use any parts or functions of IntelliPay website that require you to provide personal information.

You can also withdraw your consent at any time by providing IntelliPay with reasonable notice. However, if you withdraw your consent, IntelliPay may not be able to offer all or any of its services to you, including payment processing. If you decide to withdraw your consent, please contact IntelliPay’s CEO using the contact information under “Who is Accountable for IntelliPay’s Privacy Policy”.

You cannot withdraw your consent retroactively, and any personal information you previously provided may remain subject to certain contractual or legal obligations that IntelliPay agreed to before you withdrew your consent.

WHAT IS PERSONAL INFORMATION? 

Under PIPEDA, “personal information” means information about an identifiable individual. This includes any factual or subjective information about an identifiable individual such as, among other things, your name, residential address, email address, gender, phone number and date of birth, but does not include business contact information.

This policy does not apply to non-personal information, such as business contact information IntelliPay collects, uses or discloses solely for the purpose of communicating or facilitating communication with you in relation to your business or profession.

WHAT PERSONAL INFORMATION DOES INTELLIPAY COLLECT?

When you visit IntelliPay’s website or use its services, IntelliPay may collect the following types of information from you:

  • Corporate identification information
  • Personal identification information
  • Financial information (e.g. credit card information, purchase order numbers or any other payment information for billing purposes)
  • Usage information, including information about your preferences
  • Additional information from or about you when you communicate with us, contact us or respond to a survey

These types of information may include, among other things, your name, residential address, email address, gender, phone number, credit card and billing information, and information about your employment status.

WHY DOES INTELLIPAY COLLECT PERSONAL INFORMATION? 

IntelliPay may collect personal information from you for the following purposes:

  • Merchant registration and administration
  • To provide you with services which include, among other things, technical support, merchant account applications and management, payment of merchant processing fees as part of participation in a fee-based option
  • IntelliPay updates and newsletters
  • To perform analytics and customize your online experience
  • To advertise to you and perform marketing activities related to IntelliPay events and services
  • To enable our service providers and suppliers to provide our products, services and promotional information to you

IntelliPay may also collect personal information where required to fulfill its legal and regulatory obligations.

HOW DOES INTELLIPAY COLLECT PERSONAL INFORMATION? 

Personal Information That You Provide

IntelliPay collects personal information from customers and non-customers that is provided in writing, via electronic media, verbally over the telephone or in person. For example, IntelliPay may collect personal information from you when you sign-up for a merchant account, when you use our software or services to process payments, implement an IntelliPay API, when you complete a survey, or when you sign-up for certain benefits and services.

Collection by Third-Party Service Providers

When you make a payment using IntelliPay’s software, gateway or systems, whether online or in person, the payment is processed through a third-party payment processor on IntelliPay’s behalf. To process a payment, the third-party payment processor will collect your personal information from you or us (in cases where you have asked us to enter it for you), including your name, email address, credit card number, billing address and other billing and delivery information. In this case, this Policy will no longer apply to the information collected by the payment processor and the collection, use and storage of your personal information will be governed by the payment processor’s terms, conditions and privacy policies.

IntelliPay’s website may contain other links to external or third-party websites. This Policy only applies to personal information that IntelliPay collects, uses and discloses, and does not apply to personal information that is collected by third party processors or any other third-party suppliers or service providers. IntelliPay does not possess, have access to, or keep any of the personal information you provide through third-party payment processors other than the fact that your purchase has been completed. To provide a particular service, third-party service providers may transmit or store your personal information outside of Canada, and it may therefore be subject to the laws of that jurisdiction. IntelliPay is not responsible or liable for the privacy practices, content, or activities of any third-party website, whether linked or otherwise. We strongly recommend that you review the privacy policies that are applicable to any external webpages before you disclose any personal information.

COLLECTION OF PERSONAL INFORMATION USING TRACKING TECHNOLOGIES

When you visit or interact with our website, services, tools or messaging, we or other authorized service providers may use cookies, web beacons and other similar technologies to collect information. IntelliPay may use cookies, web beacons and similar technologies for a variety of reasons, primarily to help us customize your online experience and to help us compile aggregate statistics about your usage of our website and our services. These are the types of cookies and tracking technologies that IntelliPay may use:

Essential: These are necessary for the operation of IntelliPay’s websites, services and tools.

Performance Related: These allow IntelliPay to assess the performance of IntelliPay’s website, services and tools. It may include analytics to help determine how visitors use IntelliPay website. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Enhanced Functionality: These identify users when they sign in, keep track of preferences, interests or past items viewed.

Advertising or Targeting: These can be first- or third-party cookies and web beacons which can be used to deliver content, including advertisements relevant to member interests, on IntelliPay website or on third party sites. This includes monitoring whether you have clicked on an advertisement.

You can control and/or choose to delete cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may not be able to access some services and functionalities of IntelliPay’s website.

What Does IntelliPay Use Personal Information For?

IntelliPay only uses personal information for the purposes described in this Policy, and only in accordance with the terms of this Policy and in accordance with all applicable laws. If IntelliPay intends to use personal information for any other purpose, then IntelliPay will ask you for your consent for that particular purpose.

INFORMATION SECURITY AND SAFEGUARDS 

The security of your personal information is important to us. IntelliPay protects personal information through appropriate physical, organizational, and technological security safeguards based on the sensitivity of the information, including:

Physical Measures:

  • Locked filing cabinets and restricted access to offices
  • Secure disposal of physical documents containing personal information
  • Controlled access to facilities where personal information is stored

Organizational Measures:

  • Security clearances and background checks for employees with access to personal information
  • Limiting access to personal information on a need-to-know basis
  • Regular privacy and security training for employees
  • Confidentiality agreements with employees and contractors

Technological Measures:

  • Encryption of personal information during transmission and storage
  • Firewalls and intrusion detection systems
  • Secure authentication and access controls
  • Regular security updates and vulnerability assessments

We follow generally accepted standards designed to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at support@intellipay.com.

IntelliPay restricts access to personal information to those employees who need access to personal information in order to perform their roles and responsibilities.

INTERNAITONAL DATA TRANSFERS 

Personal information collected by IntelliPay may be stored and processed in the United States through our cloud service providers and third-party processors. When your personal information is processed outside Canada, it becomes subject to the laws of that jurisdiction, including laws that may permit foreign law enforcement agencies, courts, or national security authorities to access your personal information without your knowledge or consent.

Any personal information that IntelliPay receives through electronic means is stored in the cloud through a third-party service provider whose servers and back-up servers are located in the United States. Any personal information that IntelliPay collects in person, via mail or over the phone is kept securely, with appropriate safeguards, at the offices of IntelliPay.

DATA BREACH NOTIFICATION 

IntelliPay will report any breach of security safeguards involving personal information that poses a real risk of significant harm to individuals to the Office of the Privacy Commissioner of Canada (OPC) as soon as feasible after determining the breach has occurred. We will also notify affected individuals of such breaches within the same timeframe.

Real Risk of Significant Harm includes circumstances where the breach could reasonably be expected to result in:

  • Identity theft
  • Fraud
  • Financial loss
  • Damage to reputation
  • Physical harm
  • Humiliation
  • Damage to relationships
  • Loss of employment or business opportunities
  • Other similar harms

When we notify affected individuals of a breach, we will provide:

  • A description of the circumstances of the breach and its cause (if known)
  • A description of the personal information involved in the breach
  • The steps IntelliPay has taken to reduce the risk of harm
  • The steps individuals can take to reduce their risk of harm or mitigate its effects
  • Contact information for someone who can answer questions about the breach

We maintain records of all security breaches involving personal information for a minimum of 24 months, regardless of whether they meet the reporting threshold. These records contain sufficient detail to enable the OPC to verify our compliance with mandatory reporting requirements.

If you believe you have been affected by a data breach involving IntelliPay, please contact us immediately using the information provided in the “Who is Accountable” section below.

DOES INTELLPAY KEEP PERSONAL INFORMATION?

Within the IntelliPay website, no account or personal information is obtained for storage on our or our transfer agent’s systems other than the information you enter. This information is used only to provide you with the information or materials that you specifically request.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreement. We do not license, sell, rent, or trade any collected personal information unless you request it. The personal information you provide is to help complete a transaction initiated by you, or the disclosure is otherwise lawfully permitted or requested.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

In the event of a merger, acquisition, or sale of all or a portion of IntelliPay’s business or assets, your personal information may be transferred to the acquiring entity. This transfer is essential to ensure the uninterrupted provision of services to our customers by the new entity. We will provide notice of such transfer and any choices you may have regarding your personal information.

DOES INTELLIPAY DISCLOSE PERSONAL INFORMATION? 

IntelliPay may disclose personal information with the following categories of third parties to the extent required to fulfill the purposes described in this Policy:

  • Payment processors and financial institutions for transaction processing
  • Technology service providers for cloud storage, website hosting, and technical support
  • Professional service providers such as legal counsel and auditors
  • Government authorities when required by law or to comply with legal processes
  • Business partners in connection with joint services or promotional activities (with your consent)

When we share personal information with third parties, we require them to protect your information in accordance with applicable privacy laws and contractual obligations.

ACCESSS TO YOUR PERSONAL INFORMAITON 

IntelliPay will give you access to any of your personal information that we have collected, used or disclosed, upon your written request, to the extent permitted or required by law. You can at any time challenge the accuracy or completeness of the personal information we have that is related to you.

How to Request Access:

  1. Submit a written request to our Privacy Officer using the contact information below
  2. Provide sufficient information to verify your identity
  3. Specify the personal information you wish to access

Response Timeline: IntelliPay will endeavor to respond to requests that it receives within 30 days of receiving your request. If IntelliPay is not able to respond to your request within that timeframe, IntelliPay will notify you in writing of the delay and the expected response date.

Exceptions to Access: We may not be able to provide access to personal information if:

  • The information contains personal information about other individuals that cannot be separated
  • The information is protected by solicitor-client privilege
  • Providing access would reveal confidential commercial information
  • The request is frivolous or vexatious
  • Legal restrictions prevent disclosure

If we deny your access request, we will explain the reasons for the denial and inform you of your right to challenge this decision with the Office of the Privacy Commissioner of Canada.

CHALLENGING COMPLIANCE AND COMPLIANT PROCEDURES 

IntelliPay has established procedures for receiving, investigating, and responding to complaints about our compliance with this Privacy Policy and PIPEDA requirements.

How to File a Complaint:

  1. Contact our Privacy Officer using the information provided below
  2. Provide a clear description of your complaint
  3. Include any relevant documentation or evidence
  4. Provide your contact information for our response

Our Investigation Process:

  • We will acknowledge receipt of your complaint promptly
  • We will investigate the matter thoroughly and impartially
  • We will provide you with our findings and any corrective actions taken
  • We will inform you of additional steps you can take if you are not satisfied with our response

External Complaint Options: If you are not satisfied with IntelliPay’s response to your complaint, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

  • Website: https://www.priv.gc.ca/en/contact-the-opc/contact-the-information-centre/
  • Mail: Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Québec K1A 1H3
  • Phone: 1-800-282-1376

OPENNESS AND TRASNPARENCY

This Privacy Policy serves as our primary means of making information about our privacy practices readily available. Additional information about our privacy practices can be found in:

  • Our Terms of Service (available at [website URL])
  • Our Cookie Policy (available at [website URL])
  • Our Data Processing Agreements with third parties

We are committed to making our privacy practices understandable and accessible. If you have questions about any aspect of this Policy, please contact our Privacy Officer.

WHO IS ACCOUNTABLE FOR INTELLIPAY’S PRIVACY POLICY

IntelliPay has appointed a Privacy Officer who is accountable for our compliance with PIPEDA and this Privacy Policy.

If you would like to withdraw your consent to the use or disclosure of your personal information described in this Policy, or if you have any questions, concerns or complaints about this Policy, please contact IntelliPay’s CEO and Privacy Officer:

Casey Leloux
CEO and Privacy Officer
IntelliPay
12884 S Frontrunner Blvd., Suite 220
Draper, UT 84020 USA
Email: Casey.leloux@IntelliPay.com
Phone: (877) 855-6632

IntelliPay takes its obligations and responsibilities under PIPEDA seriously and will make every effort to resolve any concerns you may have about how your personal information is handled. However, if you are not satisfied with IntelliPay’s efforts to resolve your concern, you may contact the OPC by visiting the OPC website at: https://www.priv.gc.ca/en/contact-the-opc/contact-the-information-centre/, or writing to the OPC at the address below:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec K1A 1H3

Document Version: 1.0
Effective Date: September 2, 2025
Last Reviewed: September 2, 2025
Next Review Date:

This policy incorporates all mandatory requirements under PIPEDA including the 10 fair information principles and enhanced breach notification obligations effective November 1, 2018.