Privacy Policy of CanApply

Capitalized terms are defined in the CanApply Terms of Use. Please read them carefully.

To help you navigate through this document, here is a summary of CanApply's privacy policy (the “Policy”). You can go to any section of interest:

  1. Scope and application of the Policy
  2. Privacy officer
  3. Roles and responsibilities of CanApply personnel
  4. Definition of personal information
  5. What personal information do we collect?
  6. How do we collect your personal information?
  7. From whom do we collect your personal information?
    • Directly from you or from the person who has parental authority over you if you are a minor, or from your guardian or agent, if applicable.
    • From other sources
    • From the Platform
  8. How do we use Cookies?
  9. Why do we collect your personal information?
    • To provide you with our services
    • To manage our operations
    • To enable us to communicate with you
  10. What happens if you do not consent to the collection of your personal information?
  11. Who outside CanApply may have access to your personal information and how do we share it?
    • Third-party service providers whose intervention is necessary to provide you with the service.
    • The purchaser of CanApply if CanApply were sold or transferred or in certain other corporate transactions
    • Other third parties when required or authorized by certain laws
    • Other third parties, with your consent
  12. How long do we keep your personal information?
  13. What are the risks involved in processing your personal information?
  14. Is your personal information transferred outside Quebec?
  15. How can you change your choices regarding the protection of your personal information?
    • Indicate your choices when you register or by contacting us directly at any time.
    • Change the browser settings on your device
  16. How do we protect and store your personal information?
    • Safeguards in place
    • Where we store your personal information
    • How long we keep your personal information
    • Destruction of your personal information
  17. What rights do you have regarding your personal information?
  18. How can I access my personal information?
  19. How do I know if the Privacy Policy has been modified?
  20. Who should I contact if I have questions about the protection of my personal information?

1. Scope and application of the Policy

In the face of new challenges and dangers relating to the preservation of the security of personal information arising from online business, it is necessary to pay particular attention to the protection of privacy. That's why CanApply takes the privacy of your personal information seriously and is committed to respecting the confidentiality of the information it collects.

CanApply is committed to respecting, in accordance with this Policy and applicable laws in force in Canada and Quebec, the obligations concerning the collection and processing of your personal and confidential information obtained in the course of operating its business, so that everyone can benefit from the respect of their privacy.

The Policy applies to you in all situations where you interact with CanApply and we collect information about you, including when you visit our Platform, use our services or communicate with us by any means.

In doing so, CanApply wishes to ensure the accuracy, security and confidentiality of your personal information, and not to collect, use or disclose your personal information other than in accordance with this Policy and applicable laws.

The Policy describes the information that CanApply may collect in the course of its business, in any manner, from you.

The Policy also describes, among other things, how CanApply handles, stores and/or destroys your personal information, the purposes for which it is collected, how it is used and the circumstances under which it may be transferred to third parties. The Policy explains your rights with respect to the collection, transfer, use, retention and disclosure of your personal information.

Finally, the Policy describes the ways in which you can access, update or correct your personal information, and the choices you have regarding the protection of your privacy.

You agree that your personal information collected when filling out any online form for the purpose of contacting us, uploading content to the Platform, or providing other services, will be shared with appropriate and authorized CanApply personnel. CanApply will only disclose to third-party companies that perform activities on our behalf, and whose participation is strictly necessary for the delivery of the Services and/or the maintenance of our business relationship with you, as the case may be, the information necessary for these purposes (the aforementioned third parties may hereinafter be collectively referred to as "Third-Party Service Providers").

In some cases, at the time of collection of your personal information, we may provide you with additional information relating to the processing of your personal information. We may also, in some cases, obtain specific consent from you regarding the use or disclosure of your personal information. For example, CanApply may ask you to complete a form consenting to the transfer of your personal information to a Third-Party Service Provider, such as an immigration lawyer.

By browsing the Platform, accepting this Policy or providing us with personal information after having had the opportunity to review this Policy or any supplemental notice, you agree that your personal information will be treated in accordance with the Policy and the supplemental notice.

By providing CanApply with your personal information, you authorize CanApply to use and disclose your personal information to Third Party Providers, if any, in connection with the delivery of services, the management of our contractual relationship, our business relationship with you, and in accordance with this Policy and as authorized or required by law, as well as implicitly, if indicated by the circumstances.

In addition, CanApply will seek your consent before using your personal information for purposes other than those to which you originally consented under the Policy.

We only collect personal information that is reasonably required to provide and manage our services and operations. We collect your personal information in a variety of ways. For example, we collect it directly from you, from third-party Service Providers, or when you visit our Platform.

Finally, you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please be aware, however, that without your consent, CanApply may not be able to provide or continue to provide you with some of the services or information that may be useful to you.

If you provide CanApply or its Third Party Providers with personal information about another individual or entity, you agree that you have the necessary authorization to do so and/or that you have obtained all necessary consents from such third party to allow us to collect, use and disclose their personal information for the purposes set out in this Policy.

2. Privacy officer

Please feel free to contact our Privacy Officer with any questions or comments you may have regarding the Policy, how we handle your personal information, or to exercise your rights regarding your personal information.

Our Privacy Officer can be reached:

  1. by e-mail: devin@CanApply.ca / support@CanApply.ca; or
  2. by mail:
    NovaVidya Inc. - Privacy Officer
    384 Rue Crepeau, #408, H4N 0A6, Montreal, QC

3. Roles and responsibilities of CanApply personnel

Within CanApply, we have assigned roles and responsibilities as follows:

The Privacy Officer is responsible for:

  1. implementing privacy policies and procedures within CanApply;
  2. training our staff on privacy policies and obligations;
  3. keeping a register of incidents relating to the confidentiality of personal information;
  4. assessing the possible consequences of a privacy incident;
  5. notifying the Commission d'accès à l'information in the event of a privacy incident that could cause serious harm; and
  6. participating in the detection of confidentiality risks and notifying the persons responsible in the event of a confidentiality incident.

The Operations Manager is responsible for:

  1. ensuring that all employees have signed the confidentiality agreement and that it is recorded on the server;
  2. ensuring that employee access rights to the server are controlled;
  3. ensuring that all Third Party Service Providers have and comply with a privacy policy; and
  4. helping to identify risks of confidentiality breaches and notifying the responsible persons in the event of a confidentiality-related incident.

Administrative staff are responsible for:

  1. collecting personal information from clients;
  2. obtaining consent for the use of personal information and digitizing it in the patient's file;
  3. signing and respecting the confidentiality agreement; and
  4. participating in identifying risks of confidentiality breaches and notifying responsible persons in the event of a confidentiality incident.

CanApply trains and educates its employees ("Employees") by:

  1. explaining the clauses of the confidentiality contract when they are hired and reminding them of them annually thereafter;
  2. periodically reminding employees of confidentiality requirements at annual meetings; or
  3. raising awareness of confidentiality incident reporting.

4. Definition of personal information

Personal information is information that is specifically associated with a natural person and that can be used to identify that person, either in its own right or by combining it with other information held by CanApply or to which it may have access. Information that has been rendered anonymous or arranged so that it can no longer be used to identify a specific individual does not constitute personal information. For example, the mailing address of an individual's office is not personal information per se, except when it is mentioned in conjunction with other information about the individual, or when its mere mention would reveal personal information about the individual.

5. What personal information do we collect?

We collect the following personal information:

  1. Information about your identity and contact details, such as your first and last name, age, gender, residential address, telephone number, e-mail address, nationality, location, copy of an identification document, parents' name;
  2. Information about your educational background, including your transcripts, degree, English exam result;
  3. Information about specific services you have purchased from CanApply;
  4. Your payment information, such as the time and date of payment, the amount paid, the type of card used, the full name on the card and your credit card number, if you make a purchase on the Platform;
  5. Information collected automatically when you visit our Platform, such as visit or chat history or the time and date cookies were accepted, and preferences chosen.

6. How do we collect your personal information?

We collect your personal information in the following ways:

  1. when you save personal information on the Platform;
  2. when you create an account on the Platform and choosing a password;
  3. when you log on to the Platform as a registered user, initiate a service search;
  4. when you request a service;
  5. when you provide information in your account;
  6. when you communicate with us by telephone, e-mail or social media applications such as Instagram, WhatsApp, Telegram, Facebook; or
  7. by filling out a form to participate in a contest, inventory request, promotion or survey.

7. From whom do we collect your personal information?

We generally collect personal information in the following ways:

  1. a. Directly from you or from the person who has parental authority over you if you are a minor, or from your guardian or agent, if applicable.

    You may provide us with personal information directly, for example by e-mail, telephone call or text message, through third party applications, such as Telegram or WhatsApp.

    For instance:

    1. We collect your personal information when you fill out our registration form or when you update your personal information or import contacts, to provide you with the service you require.
    2. We collect personal information related to your educational record when you submit it to us electronically or by hand.
    3. When you participate in a free consultation with a member of our team, we collect the personal information necessary to provide you with the services you require.
    4. We collect your personal information when you use our chat service on the Platform to chat with Dana, the intelligent assistant (in this case, you must at all times comply with the instructions communicated via the chat service interface and in our Terms of Use, regarding the nature of the information you are authorized to share and you must avoid providing personal information where prohibited), or when you take part in community discussions.
    5. We collect your personal information when you fill out the following forms on our Platform: order form, opinion poll, resource download form, authorization to access User information form, support form, ad posting form.
  2. b. From other sources

    Occasionally, we may receive personal information from other sources. In such cases, we will only do so with your consent, or as required or permitted by law.

    For instance:

    1. If you are working with an immigration lawyer who is required to provide us with certain information relating to your file.
    2. When you give us access to some information on your social media pages.
    3. We might get access to your personal information through referral, affiliates, or recommendation programs, or through publicly accessible sources including events, fairs, and social media.
  3. c. From the Platform

    Cookies enable us to collect certain information during exchanges between your computer and our server. Cookies are files created by a website to record information about your computer's navigation on the site. They are automatically stored on your electronic devices, allow you to connect to the Platform at a later time and enable CanApply to personalize the Platform.

    It mainly includes the following information:

    1. Domain name;
    2. IP address;
    3. Browsing history;
    4. Analytics and performance;
    5. User behavior;
    6. Advertising/redirection;
    7. User language; and
    8. Third-party software served to the Users.

    Most cookies do not reveal your identity. They are only collected because of the technological requirements inherent in Internet browsing. Most browsers automatically accept cookies, but it is generally possible to modify this behavior. However, if you choose to refuse cookies, you may not be able to identify yourself or use certain functions of the Platform.

    The use of such information allows us to improve the service, personalize your experience and better track your past usage.

    In addition to the methods described above, we may also collect information using cookies or similar technologies, particularly during your visits to our Platform. These methods enable us to collect various types of information, including the pages you visit, the e-mails you read and other information.

    For example:

    1. We may use your geographic location to determine the language in which to display the Platform when you visit it.
    2. Subject to applicable laws, we may use the pages you visit on the Platform to show you personalized advertisements on the External Sites of our Third-Party Service Providers.

    We use the information thus collected to adapt the Platform to your preferences, to compile statistics about your consultation and use of our Platform and our electronic communications, such as our newsletters, in order to improve them, and to present you with CanApply advertisements with the help of our partners.

    The cookies we use include, but are not limited to, the following:

    1. Cookies, which are small text files that are stored on your computer when you visit a Web site, so that certain information can be saved between visits, such as your access data or language choice. Cookies allow you to log in quickly when you visit our sites.
    2. Pixels, which are small image files containing information about you, such as your IP address, that may be downloaded when you visit a Web site or open an e-mail. This enables us to understand your online behavior, monitor the delivery of our e-mails and present you with personalized advertising. These tools also allow our third-party tracking tools to collect information, such as your IP address, and transmit it to us as anonymized aggregate data (preventing us from identifying you). The personal information compiled and presented as aggregate data is the result of a synthesis and does not include any personal identifiers.

    We use Google Analytics, a service that uses cookies, to analyze your use of our Platform, to generate reports for us on the activities of visitors to the Platform and to offer other services related to the use of the Platform and the Internet. This information is not transmitted to us in a form that allows you to be identified.

    These Cookies are multiple, some expire when you close your browser and have no further effect while others may be retained. You may deactivate cookies at any time. In this case, CanApply does not guarantee optimal operation of the Platform.

8. How do we use cookies?

We use technologies such as cookies or pixels to perform various functions on our Platform. You will find more information on the use of these technologies in the cookie policy.

This information is also used to:

  1. To understand how you use the service but not to follow you in particular;
  2. Process your requests and answer your questions;
  3. Keep in touch with you and provide you with ongoing personalized service;
  4. Communicate with you (by e-mail, mail or otherwise) and send you promotional material or additional information about the services;
  5. Develop new products and services; and
  6. Conduct market and performance research to evaluate customer service, measure performance, enhance the user experience and improve services.

9. Why do we collect your personal information?

We use your personal information to provide you with our services, to manage our business, to communicate offers and information we believe may be of interest to you, to enhance your overall customer experience and for other purposes permitted or required by law.

Specifically, we use your personal information for the following purposes:

  1. a. To provide you with our services

    We use your personal information to provide you with our services and, more specifically, for the following purposes:

    1. to verify your identity;
    2. to manage customer accounts;
    3. to provide our services to our customers;
    4. to allow you to book an appointment online;
    5. to determine whether our products and services are appropriate for you;
    6. to administer your file, including your account on the platform, to better meet your needs; and
    7. to respond to your requests and questions.

    I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE CanApply TO RENDER ITS SERVICE IN SUPPORT OF THE UNIVERSITY APPLICATION PROCESS.

  2. b. To manage our operations

    We use your personal information for several purposes in connection with our business and operations, specifically to:

    1. manage and/or improve the Platform and facilitate its use;
    2. manage customer and business relationships;
    3. enable your participation in surveys or, where applicable, promotions, chats, seminars or workshops;
    4. monitor and investigate incidents; and
    5. meet our legal and regulatory obligations.

    I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE CanApply TO MANAGE ITS OPERATIONS.

  3. c. To enable us to communicate with you

    We use your personal information to communicate with you in a number of ways:

    1. to send you our newsletter;
    2. to inform you in a variety of ways (for example, by e-mail, telephone, text message or direct mail) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you; and
    3. to provide you with personalized advertising about our products or services, which we believe may be of interest to you.

    If you no longer wish to receive our marketing e-mails, please follow the unsubscribe procedure provided in each e-mail.

    I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ALLOW CanApply TO CONTACT ME

10. What happens if you do not consent to the collection of your personal information?

You may, at any time, refuse the collection of your personal information.

Please note, however, that with the exception of cookies, which are not required for the provision of services, we will not be able to provide the services offered without having access to your personal information.

11. Who outside CanApply may have access to your personal information and how do we share it?

CanApply staff and, with your written or oral consent and where necessary, our Third Party Service Providers, may have access to your personal information.

We may disclose your personal information to our Third Party Service Providers and other third parties - with your consent or where otherwise permitted by law - for the purposes described in this Policy and in accordance with applicable law. We do not sell your personal information, except in connection with the sale or transfer of part of our business.

We do not disclose your personal information to any person or entity outside of CanApply, except as set out below:

  1. a. Third-party service providers whose intervention is necessary to provide you with the service.

    We may disclose personal information to our Third-Party Service Providers. These Third-Party Service Providers help us provide our services, conduct our business, operate our technology systems and applications and infrastructure, and implement our internal procedures and advertising and marketing strategy. For example, they provide us with data hosting, e-mail deployment, marketing, sales and personal information processing or analysis services. We may also subcontract certain services we provide to our customers to third parties.

    BY USING CanApply'S SERVICES, YOU CONSENT TO YOUR PERSONAL INFORMATION TRANSITING THROUGH THE SYSTEMS OF SUPPLIERS WHO ENABLE US TO PROVIDE OUR SERVICE.

  2. b. The purchaser of CanApply if CanApply were sold or transferred or in certain other corporate transactions

    We may decide to sell or transfer all or part of our business or to a third party, merge with another entity, insure our assets, or enter into any other financing or other strategic corporate transaction (including insolvency or bankruptcy proceedings), restructuring, sale of shares or other change in control of CanApply.

    YOU CONSENT TO THE DISCLOSURE OF YOUR PERSONAL INFORMATION WHEN REQUIRED FOR THE PURPOSES OF SUCH A TRANSACTION.

  3. c. Other third parties when required or authorized by certain laws

    The law permits or requires the collection, use or disclosure of personal information without consent in limited circumstances (for example, to investigate or prevent suspected or actual unlawful activity, including fraud, or to assist law enforcement or government agencies).

    Please note that under the applicable laws of Quebec and Canada, CanApply may be required to disclose your personal information to authorized persons.

    For instance:

    • We may disclose personal information that we hold to protect an individual or group of individuals when there is reasonable cause to believe that there is a serious risk of death or serious bodily harm to the individual or group, such as a disappearance or an act of violence, including a suicide attempt, and the nature of the threat inspires a sense of urgency. The information may then be communicated to the person or persons exposed to this risk, to their representative or to any person likely to come to their aid. Only the information necessary for the purposes of the communication will be communicated;
    • We may also communicate information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for preventing, detecting or repressing crime or legal offences when the information is necessary for the purposes of a prosecution for an offence under a law applicable in Quebec.
  4. d. Other third parties, with your consent

    In addition to the purposes described above, we may, with your express or implied consent and in compliance with applicable law, communicate or disclose your personal information to persons or entities outside CanApply.

    For instance:

    • With your consent or at your express request, we may share your information with your immigration lawyer, among others.

12. How long do we keep your personal information?

We store your personal information at our offices, with our archive service and on our computer servers. Unless otherwise required by law, we retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected. The length of time may vary depending on the nature of the information.

13. What are the risks involved in processing your personal information?

Given the risks inherent in the use of computer systems, however, we cannot ensure or warrant the security and confidentiality of any information you transmit or provide to us, and you do so at your own risk. If you have reason to believe that personal information has been compromised, please contact us as indicated in Section 2 of the Policy. If a password is used to protect the User's account and personal information, it is the User's responsibility to keep the password confidential.

CanApply undertakes not only to keep a register of confidentiality incidents but also to implement internal practices to limit or prevent the consequences of a confidentiality incident involving personal information.

A privacy incident may be:

  • unauthorized access to personal information;
  • the use of personal information not authorized by law;
  • the unauthorized disclosure of personal information; or
  • the loss of personal information or any other breach in the protection of such information.

In the event of a privacy incident involving your personal information held by CanApply, CanApply will notify you and the Commission d'accès à l'information du Québec of any privacy incident that presents a risk of serious harm.

14. Is your personal information transferred outside Quebec?

Some of your personal information may be transferred outside Quebec. In this case, the servers of third-party service providers whose intervention is required to provide services are located in Canadian provinces or territories, in USA, and in Germany.

Prior to any transfer of your personal information outside Quebec, CanApply performs a privacy impact assessment specific to the intended transfer. CanApply ensures that the safeguards in place are adequate to protect the personal information being transferred.

15. How can you change your choices regarding the protection of your personal information?

You can always withdraw your consent for your personal information to be used for purposes other than those that are absolutely necessary to provide our services, without affecting the services you receive from CanApply.

For example: You can always opt-out of receiving marketing communications from CanApply.

You have various options for making your choices:

a. Indicate your choices when you register or by contacting us directly at any time

You can always indicate your choice not to receive marketing messages from CanApply by e-mail by clicking on "unsubscribe" in any e-mail you receive.

Please note that even if you have indicated your choice not to receive marketing messages from us, we may still contact you regarding a service in accordance with applicable law (for example, to send you a customer service message). In addition, it may take up to 10 business days to register a change of preference in all our files.

b. Change the browser settings on your device

We use technologies to enhance your customer experience and present you with offers, including personalized advertising. By means of technologies such as cookies, for example, our Platform recognizes you when you use it or return to it and can thus offer you a seamless experience. You can delete or deactivate some of these technologies at any time using your browser. However, if you do so, you may not be able to use some of the features of our Platform.

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16. How do we protect and store your personal information?

The security of your information is important to us and we are committed to protecting your privacy through a variety of administrative, physical and technical safeguards. We retain your personal information only as long as necessary to provide our services to you, to manage our business and to comply with our legal and regulatory obligations.

The personal information that CanApply collects is stored in a secure environment. CanApply has adopted appropriate measures to maintain the confidentiality of personal information and to protect it against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, taking into account, among other things, the sensitivity of the information and the purposes for which it is to be used. In addition, CanApply requires that each employee, agent or representative of CanApply abide by this Policy.

a. Safeguards in place

To protect your personal information, we employ administrative, technical and physical safeguards. Our goal is to prevent unauthorized access, loss, misuse, disclosure or modification of the personal information in our possession. We ensure that access to your personal information is restricted at all times to those CanApply employees and agents who are authorized by law to have access to it. We also use these safeguards when disposing of or destroying your personal information.

CanApply is also committed to maintaining a high level of security by integrating the latest technological innovations to ensure the confidentiality of your transactions in order to protect personal information from unauthorized access, use or disclosure.

For instance, we use the following measures:

  • Secure Sockets Layers (SSL);
  • Secure access to your premises;
  • Secure access to your servers and computers;
  • Firewalls;
  • Use of password-protected data networks;
  • Confidentiality agreements with your employees;
  • Internal privacy policies;
  • Regular updating of security measures; or
  • Encrypted and secure electronic communications.

b. Where we store your personal information

We use all reasonable security measures, which may include imposing contractual obligations on our Third Party Service Providers, to protect your personal information wherever it is used or stored.

Unless we are legally required or contractually bound to keep your personal information in Canada, it may be transferred outside Canada, as described in Section 13. For example, some of our Third Party Service Providers may access, process or store your personal information outside your province or territory or outside Canada for the purposes of the services they provide to us. In such cases, personal information is governed by the laws of the jurisdiction in which it is used or stored, including any laws permitting or requiring disclosure to governmental authorities or agencies, courts and law enforcement authorities in that jurisdiction. CanApply ensures that its Third-Party Service Providers are located in jurisdictions that provide a level of protection for personal information consistent with the laws applicable in Quebec.

c. How long we keep your personal information

We retain your personal information for as long as is necessary to provide our services to you, to manage our business and to comply with our legal and regulatory obligations. When we no longer need your personal information, we securely destroy it or make it anonymous (so that it can no longer be used to identify you).

d. Destruction of your personal information

Personal information is destroyed according to the rules set out in the regulations enacted by the laws applicable in Quebec regarding the management and protection of personal information.

In certain circumstances, you have the right to have your personal information deleted without undue delay. These circumstances are as follows:

  • Personal information is no longer required for the purposes for which it was collected or otherwise processed;
  • You withdraw your consent to processing based on consent;
  • You object to the processing under certain rules of applicable data protection legislation;
  • Processing is carried out for direct marketing purposes; and
  • The personal information has been processed unlawfully.

However, there are exclusions to the right to erasure. General exclusions include where processing is necessary:

  • For the exercise of the right to freedom of expression and information;
  • To comply with a legal obligation; or
  • To establish, exercise or defend legal claims.

17. What rights do you have regarding your personal information?

The law gives you various rights in relation to your personal information. To exercise any of these rights, please contact our Privacy Officer at the coordinates indicated in section 2 at the beginning of this Policy.

Access: the right to ask whether we hold any personal information about you and, if so, to request access to that personal information. To the best of our ability, we will provide access to information in a timely manner. However, for security reasons, we may need to verify the identity of the requester.

Rectification: the right to request rectification of any incomplete or inaccurate personal information held by us. You might modify any personal information on our Platform, at any time.

Withdrawal of consent: the right to withdraw your consent to the disclosure or use of personal information held by us, subject to applicable legal and contractual restrictions. CanApply may no longer be able to provide you with certain services if you withdraw your consent. Deleting your account on the Platform is how you can withdraw consent to the processing of your data.

Restriction or refusal of access: the right to request that a particular stakeholder or stakeholder category not have access to one or more pieces of information that you have identified.

Complaint: the right to make a complaint to our Privacy Officer as identified in Section 2 in connection with this Policy and the complaint handling procedure. If you are not satisfied with the way we have handled your personal information, or if you believe that a violation of privacy laws has occurred, you may file a complaint with the Commission de l'accès à l'information du Québec. To file a complaint, please use the appropriate form available on the Commission d'accès à l'information du Québec website.

Portability: You have the right to request that your personal information be communicated to you or transferred to another organization in a structured and commonly used technological format.

18. How can I access my personal information?

You have a right of access to the personal information we hold about you, subject to any restrictions provided by law. Upon request, we will provide you with access to your personal information within thirty (30) days of receiving your request. Access to personal information is free of charge, but a reasonable charge may be made for transcribing, reproducing or transmitting such information.

It is your responsibility to provide accurate, truthful and complete information. If you notice any errors in your personal information or if you need to update it, please notify us as indicated below.

You may make a request by contacting us using the Privacy Officer contact information at the beginning of the Policy.

19. How do I know if the Privacy Policy has been modified?

We may make changes to this Policy from time to time. Any changes we make to this Policy will be effective when we post the revised Policy on this Web page. If we make material changes to the Policy, we will post a notice on our Platform or contact you by e-mail to notify you, where required by law. Your continued use of our services following the posting of the modified Policy indicates your acceptance of the changes to the Policy, subject to any additional requirements that may apply. If you do not accept the changes to our Policy, you must stop using our services. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The "Effective Date" indicated at the top of this Policy is the date it was last updated.

20. Who should I contact if I have questions about the protection of my personal information?

If you have any questions about how we handle your personal information, we invite you to contact our Privacy Officer, whose contact details are set out in Section 2 of this Policy.

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