POLICY ON THE PROTECTION OF PERSONAL INFORMATION

Date of last update: September 28, 2023

Version française: ici

INTRODUCTION

Respect for your privacy and the protection of your personal information is very important to Synode Inc (« Synode», « us », « We» or «OUR"). When you use our website located at www.synode.ai (the “Site") or you use our 3D instruction development software or we provide 3D instruction development services (collectively, the “Services), Synode ensures that it implements effective control measures aimed at protecting the confidential nature of the personal information in its custody. By using our Site and the Services and in order to offer you quality Services, we may have access to certain personal information, i.e. information that concerns you or which, taken separately or combined with other data, allows you to be identified. This information may include: title, first name, last name, email, postal address, telephone number, financial or credit or billing information, information relating to marketing and communication preferences, information relating to the use of our Site including technical information about visits or any other information collected through cookies and any other personal information that you consider useful to provide to us (the “Personal information"). Generally, Personal Information does not include your professional contact information such as your name, title, address or work telephone number.

The currentPrivacy Policy (the "Policy") defines the Personal Information we may collect from you, the reasons we collect it and how we use it and how we protect your Personal Information. We also want to inform you about how we transmit it, to technical reasons, to other entities or companies. This Policy also describes the choices you can make regarding the way we collect, use and protect your Personal Information.

WHAT INFORMATION WE COLLECT

Use of our Services

Log data, which may include your IP address, the pages you visit within our Services, the date and time you used the Services, the address of the web page you visited before use the Services, the URL that directed you to our Services, your browser type and settings, information about your device (such as make, model and operating system), information about your browser configuration, language preferences, unique identifiers and cookies.

We collect the following information when you use our Services:

Your personal information, including your name, email address, telephone number.

Billing and other payment information, including billing name and address, payment method details, such as credit card number or bank account information.

The Services you have purchased from us.

Depending on the Service chosen, you may be asked for additional information, including opinions, ratings, comments, information about your needs and preferences and information necessary to implement the Services.

Any other Personal Information provided.

Login, usage and support data

Usage data and analytics, which may include login frequency, features you use, duration and timing of use, different types of activities users undertake, and demographic information that we may ask you, such as your gender and age.

General location information, such as IP address and the region you are in when you connect and use the Services.

Customer support questions, problems and general feedback you choose to provide.

Surveys, events and marketing information

If you choose to participate in our surveys, contests, events, requests for information, we may collect information about you in connection with the survey, contest, request for information or event; your contact details, such as your name, email address, telephone number; and general information about you that you choose to provide, such as your housing preferences.

Using our Site or interacting with us by email

When you browse our Site or interact with us through emails, we collect information about you as described below, some of which is collected automatically:

When you use automated chat functionality (chatbots) to make an inquiry or otherwise, we may collect information about you, such as your name and email address, your specific inquiry, and information related to your use of our Site .

Log data, which may include your IP address, the pages you visit on the Site, the date and time of your visit to the Site, the address of the web page you visited before using the Site, the URL that directed you to our Services, your browser type and settings, information about your device (such as make, model and operating system), configuration information your browser, language preferences, unique identifiers and cookies.

Usage data and analytics, which may include login frequency, features you use, duration and timing of use, different types of activities users undertake, and demographic information that we may ask you, such as your gender and age.

General location information, such as IP address and the region you are in when you connect and use the Services.

If you would like additional information about our Services, use our “Create Alert” or “Request Quote” or similar features, sign up to receive information from us via email, register for an event, webinar or a contest, or upload certain content, we may ask you to provide us with your contact information, such as your name, telephone number and email address, as well as certain information about your needs or preferences.

Customer support questions, problems and general feedback you choose to provide.

Phone calls

If you communicate with us by telephone, we may record that call and ask you to provide us with your contact information, such as your name, address, telephone number, and email address.

Visits to our offices

If you visit our offices, you may be asked to register as a visitor and provide your name, email address, telephone number, and the time and date of your arrival.

IMPORTANT : If you provide us with Personal Information about other individuals, you represent that you have the authority to do so and, where applicable, that you have obtained the necessary consent, and you acknowledge that such information may be used in accordance with this Policy.

WHY IS YOUR INFORMATION COLLECTED AND HOW IS IT USED?

Synode collects and uses your Personal Information to:

provide you with the Services and information regarding the Services;

manage your file and communicate with you and maintain your customer account;

process payments for Services;

you send information regarding the Services or information you have requested or to respond to your requests and questions;

facilitate communications, including by collecting information about your device data and phone number;

communicate with you (via your telephone, an alert, an email, a letter or otherwise) and present you with advertising materials and additional information about our Services, products, surveys, contests, promotions and special offers, as well as providing our customer service;

help us learn more about your needs, preferences and interactions with our Service; And carry out statistics, market and performance studies to help us evaluate our Services, measure our performance and improve the experiences, Services and products we offer. Synode will not use your Personal Information for purposes other than those indicated in this document.

Synode strives to limit the collection of Personal Information to what is strictly necessary to accomplish the purposes for which it is collected. We will not disclose or use your Personal Information for any other purpose, but note the following clarifications and exceptions:

Law application : We may share your Personal Information to respond to law enforcement requests, court orders or other legal processes or if we believe that such disclosure is necessary to investigate, prevent or respond to activities illegal, fraudulent, physical threats to you or others or as required by any other applicable law or regulation and to the extent necessary to protect the property, interests and rights of Synod.

Aggregated statistics and reports: We use and freely disclose data in an anonymous form, for example, for statistical, analytical, calibration, management and quality improvement purposes in relation to the Services, or for the development or provision other products and Services by Synode or for the benefit of all users of its Services generally. Synode guarantees, however, that this aggregated and anonymized data will never be able to identify you, in any way whatsoever, nor contain Personal Information.

Our employees and authorized service providers (“Authorized Personnel”): Authorized Personnel may have access to your Personal Information for the purpose of helping us provide the Services. Authorized Personnel access and use this Personal Information in accordance with our instructions, only if they have a need to know such information, and under strict confidentiality and security obligations. Please be aware that we ensure that our Authorized Personnel manage this information with all necessary discretion and rigor, and comply with this Policy and the legal and regulatory requirements in force.

Business transfers: Synode may be involved in the sale of all or substantially all of its business or any other similar transaction. As part of this transaction, we may assign or disclose your Personal Information to the organization that acquires Synode, whether actual or potential, but we will require that organization to agree to protect the confidentiality of your Personal Information in a manner consistent with to this Policy.

Explicit consent: Synode may also disclose your Personal Information if you request it or expressly consent to it.

CONSENT

As a general rule, Synode will obtain the necessary Personal Information directly from you, with your consent, subject to exceptions provided for by law. Personal Information will only be used for the purposes for which it was collected unless you obtain your consent. We may also collect Personal Information from third parties or from publicly accessible records as permitted by law or if we have obtained the necessary consent. Synode will not collect, use or disclose Personal Information without your consent unless it is authorized or required to do so by law. Please note that you have the right to refuse to provide us with Personal Information. You also have the right, subject to reasonable notice and applicable legal or contractual restrictions, to withdraw your consent regarding the use of Personal Information already collected by contacting our Personal Information Protection Officer at the contact details below. . Refusal to provide information or withdrawal of your consent may prevent us from providing or continuing to provide you with some of our Services. Additionally, we provide “opt-out” or “unsubscribe” instructions on our electronic communications to allow you to opt-out of future electronic communications.

YOUR PERSONAL INFORMATION AND THIRD PARTIES

The Services or our Site may reference, integrate or link to third party sites. These third party sites ("Third Party Sites "), the links to which are provided to you only as a convenience and are not under our control. These Third Party Sites are governed by their own privacy policies and may collect your Personal Information. The Third Party Sites are not developed , sold or designed by Synode. Accordingly, Synode does not guarantee and is not responsible for the collection, use and disclosure of your Personal Information by the Third Party Sites. This Policy does not apply not to the practices of third parties and Synode assumes no responsibility for your use of these Third Party Sites or your access to the Third Party Sites through the Services or the Site. By using the Services or our Site, or by accessing Third Party Sites through our Services or our Site, you release Synode from any liability for the actions, practices and omissions of these third parties. Please review the Policy of each Third Party Site you visit. We do not rent or sell your Personal Information to third parties.

In addition, by subscribing to the Services, you grant Synode the right to share your Personal Information with third party service providers acceptable to us and who will use such information to help us respond to your requests and carry out the Services. Please note that we will only share Personal Information necessary for the use of these third party services, solely for the purpose of providing the Services to you, and that we will ensure that these third party providers agree to keep this information confidential and secure.

Service Providers retain the information they need to perform the functions for which they have been appointed and we do not authorize these third parties to use or disclose personal information for their own marketing or other purposes. Synode will never sell or exchange your personal information for payment.

TRANSFER OF PERSONAL INFORMATION ABROAD

Please note that some of our service providers who process, manage or store Personal Information on our behalf may be located overseas. Therefore, it is possible that certain Personal Information concerning you may be transferred to another country and that it may be subject to the laws of that country. However, we ensure that we protect the Personal Information that we have in our custody, including Personal Information entrusted to a supplier whether located in Canada or abroad. Our policies and practices regarding the protection of Personal Information require that a written commitment be signed by this service provider in order to respect its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes implementing robust and effective security measures, but also prohibiting you from disclosing your information to others. PROTECTION OF PERSONAL INFORMATION

We take appropriate measures to maintain the confidentiality of Personal Information and to protect such Personal Information against loss, as well as unauthorized access, disclosure, copying, use or modification, taking into account, in particular , the sensitivity of the information and the purposes for which it is intended.

Synode uses commercially reasonable and appropriate physical, electronic and managerial procedures and generally accepted industry standards to safeguard and secure the Personal Information we collect.

In addition, the Personal Information that we hold is therefore only accessible to people who are entitled to read it and who consult it only when necessary in the exercise of their functions. To do this, we ensure in particular that we restrict access to our offices and computer equipment, train our staff and require our agents and suppliers of goods and services with access to Personal Information to sign confidentiality agreements and to implement security measures deemed equivalent. Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create or store Personal Information always involves a certain risk. If you believe that your Personal Information has been compromised, we invite you to contact our Personal Information Protection Officer at the contact details mentioned below. MINORS

Our Site and our Services are designed for use by people aged 18 and over. Synode does not knowingly collect Personal Information from children under 18 years of age.

However, as there is no minimum age for signing a lease alone, if a minor under 14 years of age wishes to use our Site and our Services, the collection of this minor's Personal Information cannot be done without consent. of the holder of parental authority or guardian. If we learn that we have unintentionally collected Personal Information from people under the age of 14, without obtaining the consent of the holder of parental authority or guardian, we will ensure that it is deleted from our files as quickly as possible. If you are the holder of parental authority or the guardian of a minor under 14 years of age and you know that your minor child has provided Personal Information, we invite you to contact our personal information protection manager at the contact details mentioned below so that we can take the necessary actions.

STORAGE PERIOD

With the exception of non-identifiable and anonymized information that Synode may retain in perpetuity and in any reasonable location, Synode will host and retain your Personal Information for the period necessary for the purposes provided for in this Policy and to ensure that we are in compliance. with our legal and regulatory obligations. You may at any time withdraw or modify your consent relating to our use of your Personal Information, or request that we permanently delete it, subject to conditions imposed by law.

If you wish to learn more about the retention period of your Personal Information, we invite you to contact our Privacy Officer whose contact details appear below.

ACCESS, RECTIFICATION AND UPDATING OF PERSONAL INFORMATION

You have the right to access and obtain copies of your Personal Information. You also have the right to update, rectify and correct any Personal Information that you believe is inaccurate or incomplete. To do this, please submit a written request to this effect to the person responsible for the protection of personal information at the address below, who will respond to you in writing no later than 30 days from the date of receipt of any request. in this regard.

If you wish to obtain copies of your Personal Information, we may be required to charge you a small fee, which will be disclosed to you in advance, simply to cover the costs of transcription, reproduction or transmission.

ELECTRONIC COMMUNICATIONS (EMAILS)

Your email address may be used to send you electronic communications from time to time. At any time, you can ask us to stop sending you electronic communications by contacting Synode's Privacy Officer at the contact details below or by using the "unsubscribe" instructions at the bottom of any such communications.

COOKIES AND OTHER TRACKING TECHNOLOGIES ON OUR SITE, THROUGH OUR SERVICES AND IN EMAIL COMMUNICATIONS.

We use common information collection tools, such as usage data collection tools, cookies, and similar technologies to automatically collect information that may contain Personal Information from your computer or from your mobile device when you browse our Site, use our Services or interact with emails we have sent you.

By accessing and browsing our Site and using our Services, you consent to the use of cookies in accordance with the terms of this Policy. You can control and manage cookies in different ways. Please remember that deleting or blocking cookies may have a negative impact on your user experience and certain parts of our Site may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser's controls, often found in your browser's "Tools" or "Preferences" menu. More information on how to change your browser settings or how to block, manage or filter cookies can be found in your browser's help file or on sites such as www.allaboutcookies.org.

CHANGES TO THIS POLICY

Synodreserves the right to make changes to this Policy at any time. All such modifications will be posted on the Site and will be effective immediately upon posting. We will take reasonable steps, as necessary, to notify affected individuals of any material changes.When we make changes to this Policy, we will revise the “last updated” date indicated at the beginning of this Policy. You can contact our Privacy Officer at the address(es) listed above to obtain a current copy of this Policy.

TERMS OF USE OF THE SITE AND SERVICES

The terms of use of the Site and Services, which are available at www.synode.ai, contain important provisions that disclaim and exclude the liability of Synode and others with respect to your use of the Services, as well as as provisions determining the applicable law and exclusive jurisdiction for the resolution of any dispute concerning your use of the Site and the Services. Each of these provisions also applies to any dispute that may arise in connection with this Policy and the collection, use and disclosure of your Personal Information, and they have the same force and effect as if they had been reproduced directly in this Policy.

QUESTIONS, COMMENTS, COMPLAINTS AND PRIVACY OFFICERS

Synode is responsible for the Personal Information in its custody or control and has designated a privacy officer who must ensure compliance with this Policy and applicable privacy laws. If you have any questions, comments, concerns or complaints regarding this Policy and Synode's privacy practices, we invite you to contact our Privacy Officer, either ●Taki Eddine Alimat, at the following coordinates:

Synode Inc 135 R. Main North Hatley, QC J0B 2C0 E-mail : support@synode.ai

You also have the option of filing a complaint in writing to the Commission d’Access à l’information – Direction de la surveillance at the following address: 900-2045, rue Stanley, Montréal, Québec, H3A 2V4 or by email at: cai.communications@cai.gouv.qc.ca.

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