Privacy Policy

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?

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.

b. From other sources

c. From the Platform

8. Connected Gmail accounts

9. Use of artificial intelligence

10. Information about professors

11. How do we use cookies and similar technologies?

12. Why do we collect your personal information?

a. To provide you with our services

b. To manage our operations

c. To enable us to communicate with you

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

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

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

b. Professors you choose to contact

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

d. Other third parties when required or authorized by certain laws

e. Other third parties, with your consent

15. Is your personal information transferred outside Quebec?

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

a. In your account or by contacting us

b. Change the browser settings on your device

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

a. Safeguards in place

b. Where we store your personal information

c. Destruction of your personal information

18. How long do we keep your personal information?

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

20. Minors

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

22. How can I access my personal information?

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

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

1. Scope and application of the Policy

CanApply takes the privacy of your personal information seriously and is committed to respecting the confidentiality of the information it collects.

CanApply is operated by NovaVidya Inc., a company based in Quebec, Canada. CanApply is committed to respecting, in accordance with this Policy and applicable laws in force in Canada and Quebec, including the Act respecting the protection of personal information in the private sector (Quebec) and the Personal Information Protection and Electronic Documents Act (Canada), its obligations concerning the collection and processing of your personal information. Because CanApply serves applicants around the world, we also respect the additional rights that the laws of your place of residence may grant you, as described in Section 20.

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, create an account, use our services (including the Funding service, Packages, the Dana assistant and immigration lawyer referrals), connect a Gmail account, or communicate with us by any means.

The Policy describes the information that CanApply may collect, how CanApply handles, stores and destroys it, the purposes for which it is collected, how it is used and the circumstances under which it may be shared with third parties. It also explains your rights and the choices you have regarding the protection of your privacy.

Personal information you provide when filling out a form, uploading documents to the Platform or using our services will be shared only 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, the information necessary for these purposes (collectively, “Third-Party Service Providers”).

In some cases, at the time of collection, we may provide you with additional information about the processing of your personal information, or ask for your specific consent. For example, CanApply will ask for your consent before transferring your file to an immigration lawyer, and before you connect your Gmail account to the Platform.

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. CanApply will seek your consent before using your personal information for purposes other than those to which you originally consented.

We only collect personal information that is reasonably required to provide and manage our services and operations.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Without your consent, however, CanApply may not be able to provide or continue to provide some of its services.

If you provide CanApply or its Third-Party Service Providers with personal information about another individual, you confirm that you have the necessary authorization to do so and that you have obtained all necessary consents from that individual.

2. Privacy officer

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

Our Privacy Officer can be reached:

• by e-mail: support@CanApply.ca; or

• by mail:

NovaVidya Inc. - Privacy Officer

307-3155 Ernest-Hemingway, Saint-Laurent, QC H4R 0A2, Canada

3. Roles and responsibilities of CanApply personnel

Within CanApply we have assigned roles and responsibilities as follows:

The Privacy Officer is responsible for:

• implementing privacy policies and procedures within CanApply;

• training our staff on privacy policies and obligations;

• keeping a register of incidents relating to the confidentiality of personal information;

• assessing the possible consequences of a confidentiality incident;

• notifying the Commission d’accès à l’information du Québec and affected individuals in the event of a confidentiality incident that presents a risk of serious injury; and

• 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:

• ensuring that all employees have signed the confidentiality agreement and that it is recorded on the server;

• ensuring that employee access rights to our systems are controlled and limited to what each role requires, and that no employee reads a user’s Gmail content except as permitted in Section 8;

• ensuring that all Third-Party Service Providers have and comply with a privacy policy; and

• helping to identify risks of confidentiality breaches and notifying the responsible persons in the event of a confidentiality incident.

Administrative staff are responsible for:

• collecting personal information from customers;

• obtaining consent for the use of personal information and recording it in the customer’s file;

• signing and respecting the confidentiality agreement; and

• 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:

• explaining the clauses of the confidentiality contract when they are hired and reminding them of them annually thereafter;

• periodically reminding Employees of confidentiality requirements at annual meetings; and

• raising awareness of confidentiality incident reporting.

4. Definition of personal information

Personal information is information that concerns a natural person and that can be used to identify that person, directly or indirectly, either on its own or combined with other information held by CanApply or to which it may have access. Information that has been anonymized so that it can no longer be used to identify a specific individual does not constitute personal information.

5. What personal information do we collect?

We collect the following personal information:

• 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, a copy of an identification document and, for minors, the name and contact details of a parent or guardian;

• Information about your educational background, including your transcripts, degrees, grades, English or other language test results and academic history;

• Documents and content you upload or write for your applications, such as your CV, statement of purpose (SOP), portfolio, research interests, and details of papers or projects (title, journal, year, abstract);

• Information about your outreach to professors: the professors you select, the email types and templates you choose, drafts generated or edited on the Platform, the emails sent, and the replies you receive from those professors;

• Information from your connected Gmail account, limited to what is described in Section 8;

• Your conversations with Dana, our intelligent assistant;

• Information about the services, plans and Packages you purchase, and your usage of them (for example, the number of emails sent under your plan);

• Your payment information, such as the date and amount of payment and the type and last digits of the card used. Card payments are processed by Stripe; CanApply does not store your full card number;

• Information collected automatically when you visit our Platform, such as device and browser information, IP address, pages visited, 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:

• when you create an account on the Platform and choose a password;

• when you provide or save information in your account or upload documents;

• when you search for professors, select them and generate or edit email drafts;

• when you connect your Gmail account and send emails through the Platform;

• when you purchase a plan or a Package;

• when you chat with Dana;

• when you communicate with us by telephone, e-mail or messaging and social media applications such as Instagram, WhatsApp, Telegram or Facebook; or

• when you fill out a form to participate in a promotion or survey.

7. From whom do we collect your personal information?

We generally collect personal information in the following ways:

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 through the Platform, by e-mail, telephone or text message, or through third-party applications such as Telegram or WhatsApp.

For instance:

• We collect your personal information when you fill out our registration form, update your account or upload your documents, to provide you with the service you require.

• We collect personal information related to your educational record when you submit it to us.

• We collect your personal information when you chat with Dana, the intelligent assistant. You must at all times comply with the instructions communicated in the chat interface and in our Terms of Use regarding the nature of the information you may share, and avoid sharing personal information where prohibited.

• We collect your personal information when you fill out forms on our Platform, such as the order form, survey, support form or the form authorizing access to your information.

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:

• From an immigration lawyer you are working with, who is required to provide us with certain information relating to your file.

• From professors who reply to emails sent from your connected Gmail account.

• Through referral, affiliate or recommendation programs, or through publicly accessible sources, including events, fairs and social media.

c. From the Platform

When you use the Platform, we and our Third-Party Service Providers automatically collect certain information through cookies and similar technologies, as described in Section 11.

8. Connected Gmail accounts

The Funding service lets you send outreach emails to professors from your own Gmail address. To do so, you may connect your Gmail account to the Platform using Google’s secure authorization (OAuth). Connecting is optional. Before you connect, the Platform shows you a notice explaining what CanApply will access, and you must actively tick a consent box, which is never pre-ticked. We record the date, language and version of the notice you accepted.

CanApply requests two Google permissions (“scopes”):

• gmail.send, to send the emails you have reviewed and approved on the Platform, from your own address, to the professors you selected. Each email is sent individually on your instruction. CanApply does not send mass or unsolicited emails, and daily sending limits apply.

• gmail.readonly, used exclusively to check the email threads started by your outreach, in order to detect replies from professors and delivery-failure (bounce) notices. When a reply is detected, CanApply updates the status of your request, displays the reply in your Follow-up view and stops any scheduled follow-up reminders to that professor.

CanApply does not read, store or process any other emails in your mailbox, and does not request permission to modify or delete your emails.

How we use and share Gmail data. Gmail data is used only to provide the features described above. We do not sell Gmail data, use it for advertising, or transfer it to third parties, except as necessary to provide these features, to comply with applicable law, or as part of a merger, acquisition or sale of our business. We do not use, transfer or disclose Gmail data to train, retrain, fine-tune or improve any generalized artificial intelligence (AI) or machine learning (ML) models. Any AI-assisted analysis of Gmail data is performed through zero-data-retention enterprise APIs, strictly for real-time processing, without persistent retention by the AI provider.

Human access. CanApply personnel are strictly prohibited from reading your email content unless you give explicit affirmative consent for technical support, or where it is necessary for security purposes (such as investigating abuse) or to comply with applicable law.

Limited Use. CanApply’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The Google API Services User Data Policy is available at https://developers.google.com/terms/api-services-user-data-policy.

Disconnecting and deletion. You can disconnect your Gmail account at any time from the Funding Setup page on the Platform or from your Google Account permissions page. When you disconnect, CanApply revokes its access with Google, immediately deletes your access tokens and stops sending or reading emails. Professor replies already displayed in your Follow-up view remain in your account until you delete them or delete your account. You may ask us at any time to delete all data obtained from your Gmail account by writing to CanapplyDevelopment@gmail.com, and we will do so within thirty (30) days. When you delete your account, data obtained from your Gmail account is deleted promptly, and in any case within thirty (30) days; it is not subject to the one-year retention period described in Section 18.

Your use of Gmail remains subject to Google’s own privacy policy.

I CONSENT TO CanApply ACCESSING MY CONNECTED GMAIL ACCOUNT TO SEND THE EMAILS I APPROVE AND TO READ THE REPLIES AND DELIVERY NOTICES IN THE THREADS STARTED BY MY OUTREACH.

9. Use of artificial intelligence

CanApply uses artificial intelligence (AI) services provided by third parties to help generate and personalize email drafts, to suggest professors that match your profile, and to power Dana, our intelligent assistant. To do so, relevant parts of your information (for example, your research interests, education, CV content, paper details and the professor’s public profile) are sent to these AI providers for processing.

CanApply may use different AI providers over time. Whichever provider we use, we only use enterprise services whose terms prohibit the provider from using your information to train or improve its models, and which do not retain your information after processing (zero data retention). CanApply itself does not use your personal information, including Gmail data, to train, retrain, fine-tune or improve any generalized AI or machine learning model. The providers we use may be located outside Quebec and Canada, including in the United States.

Drafts generated with AI are suggestions. You remain able to review, edit and approve every email before it is sent. No email is sent to a professor without your approval.

If you do not want your information to be processed by AI providers, please contact our Privacy Officer. Some features, such as AI-generated drafts and Dana, may then be unavailable.

10. Information about professors

To help you find suitable supervisors, the Platform includes information about professors and researchers, such as their name, academic title, institution, department, professional e-mail address, research interests and publications. This information is compiled from publicly available sources, mainly university and institutional websites, and is used solely to enable applicants to identify and contact relevant academics about graduate opportunities.

When a professor replies to an applicant, the reply is stored in that applicant’s account as described in Section 8.

Professors and researchers may ask to have their information corrected or removed from our database at any time by writing to support@CanApply.ca. We will process such requests within thirty (30) days.

11. How do we use cookies and similar technologies?

Cookies are small files stored on your device by a website. They allow the Platform to remember you, keep you signed in, remember your preferences (such as your language) and help us understand how the Platform is used.

We and our Third-Party Service Providers use the following technologies:

• Essential cookies, which are necessary to sign you in, keep your session secure and remember your choices. These cannot be disabled without affecting the Platform.

• Analytics cookies, including Google Analytics, which help us understand how visitors use the Platform, compile statistics and improve our services.

• Advertising cookies and pixels, including the Meta Pixel and Google Ads, which allow us to measure the effectiveness of our advertising and show you CanApply advertisements on third-party sites and applications based on your visits to our Platform.

The information collected in this way may include your IP address, device and browser type, language, pages visited, actions taken on the Platform and the site that referred you. Subject to applicable law, we may use your approximate geographic location to determine the language in which to display the Platform.

Where required by law, we will ask for your consent before placing analytics or advertising cookies. You can change your choices or delete cookies at any time through your browser settings. If you refuse certain cookies, some features of the Platform may not work properly.

12. 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, and for other purposes permitted or required by law. Specifically:

a. To provide you with our services

• to verify your identity;

• to create and manage your account;

• to match you with professors, generate and personalize your email drafts, send the emails you approve and display the replies you receive;

• to provide the Packages and other services you purchase, including immigration lawyer referrals where you request them;

• to determine whether our products and services are appropriate for you;

• to process your payments and manage your plan and usage limits; and

• 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.

b. To manage our operations

• to manage and improve the Platform and facilitate its use;

• to manage customer and business relationships;

• to enable your participation in surveys, promotions, seminars or workshops;

• to prevent fraud and misuse of the Platform, including misuse of the email-sending feature;

• to monitor and investigate incidents; and

• to meet our legal and regulatory obligations.

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

c. To enable us to communicate with you

• to send you service messages about your account, plan and outreach;

• to send you our newsletter;

• to inform you by e-mail, telephone or text message about our programs, services, special offers, promotions or events that may be of interest to you; and

• to show you personalized advertising about our services.

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

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

13. 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 analytics and advertising cookies and marketing communications, which are not required to provide our services, we will not be able to provide the services offered without access to your personal information.

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

CanApply staff and, where necessary, our Third-Party Service Providers may have access to your personal information. We do not sell your personal information, except in connection with the sale or transfer of all or part of our business as described below.

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

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

These Third-Party Service Providers help us provide our services, operate our technology and infrastructure, and carry out our marketing. They may only use your personal information to perform services on our behalf.

For instance:

• Our Platform and files are hosted on Google Cloud, in data centers located in Canada;

• Payments are processed by Stripe;

• AI providers help generate email drafts, match professors and power Dana, as described in Section 9;

• Google processes the emails sent from, and replies received in, your connected Gmail account, as described in Section 8;

• Google Analytics, Meta and Google Ads provide analytics and advertising services, as described in Section 11; and

• We may use an e-mail service provider to send you our newsletter and service messages.

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

b. Professors you choose to contact

When you send an outreach email, the professor receives the content of that email and any documents you chose to attach, such as your CV, transcripts, portfolio or SOP. You decide which professors receive which information.

c. 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, merge with another entity, or enter into any other financing or 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.

d. 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 unlawful activity, including fraud, or to assist law enforcement or government agencies). In such circumstances, we will disclose only as much personal information as is reasonably necessary.

For instance:

• We may disclose personal information to protect a person or group of persons when there is reasonable cause to believe that there is a serious risk of death or serious bodily injury, and the nature of the threat inspires a sense of urgency. Only the information necessary for the purposes of the communication will be communicated;

• We may communicate information to the Director of Criminal and Penal Prosecutions or to a body responsible for preventing, detecting or repressing crime or statutory offences when the information is necessary for a prosecution under a law applicable in Quebec.

e. Other third parties, with your consent

With your express consent or at your request, we may share your information with other persons or entities, such as an immigration lawyer to whom you have asked to be referred.

15. Is your personal information transferred outside Quebec?

Some of your personal information may be transferred outside Quebec. Our Platform and files are hosted in Canada. However, some Third-Party Service Providers whose intervention is required to provide our services, such as Stripe, Google, Meta and our AI providers, may process your information in other Canadian provinces, in the United States or in other countries where they operate.

Prior to any transfer of your personal information outside Quebec, CanApply performs a privacy impact assessment and ensures, including through contractual obligations, that the information will receive adequate protection. When your information is processed in another jurisdiction, it may be subject to the laws of that jurisdiction, including laws permitting disclosure to its authorities.

16. 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 necessary to provide our services, without affecting the services you receive from CanApply. You have various options for making your choices:

a. In your account or by contacting us

You can disconnect your Gmail account at any time, choose not to receive marketing messages by clicking on “unsubscribe” in any marketing e-mail, or contact our Privacy Officer. Even if you have chosen not to receive marketing messages, we may still send you service messages about your account. 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

You can delete or block cookies at any time using your browser settings, and adjust your advertising preferences in your Google and Meta account settings. If you do so, you may not be able to use some features of the Platform.

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

CanApply has adopted appropriate administrative, technical and physical 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 the sensitivity of the information and the purposes for which it is used. CanApply requires that each employee, agent or representative abide by this Policy.

a. Safeguards in place

Access to your personal information is restricted at all times to those CanApply employees and agents who need it to perform their duties. For instance, we use the following measures:

• encryption of data in transit (TLS/HTTPS);

• secure access to our premises;

• secure, access-controlled servers and computers;

• firewalls and password-protected networks;

• secure authorization (OAuth) for connected Gmail accounts, so that CanApply never receives your Gmail password, with access tokens stored encrypted;

• confidentiality agreements with our employees;

• internal privacy policies; and

• regular updating of security measures.

b. Where we store your personal information

Your personal information is stored on Google Cloud servers located in Canada. Some Third-Party Service Providers may access, process or store your personal information outside Quebec or Canada, as described in Section 15.

c. Destruction of your personal information

When we no longer need your personal information, we securely destroy it or anonymize it, in accordance with the laws applicable in Quebec.

In certain circumstances, you have the right to have your personal information deleted without undue delay, including where:

• the personal information is no longer required for the purposes for which it was collected;

• you withdraw your consent to processing based on consent;

• you object to processing for direct marketing purposes; or

• the personal information has been processed unlawfully.

Exceptions apply where processing is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

18. How long do we keep your personal information?

We keep your personal information for as long as your account is active and as necessary to provide our services. When you delete your account, we keep your personal information, including your uploaded documents and email drafts, for one (1) year after the deletion of your account, after which it is securely destroyed or anonymized.

Data obtained from your connected Gmail account, including professor replies, follows the specific rules in Section 8: it is deleted within thirty (30) days of your request or of the deletion of your account, rather than after one year.

Some information may be kept longer where the law requires it, for example payment and billing records that we must keep for tax and accounting purposes, or where it is needed to resolve a dispute or enforce our agreements.

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

Given the risks inherent in the use of computer systems, we cannot guarantee the absolute security of any information you transmit to us. If you have reason to believe that personal information has been compromised, please contact us as indicated in Section 2. It is your responsibility to keep your password confidential.

CanApply keeps a register of confidentiality incidents and implements internal practices to limit or prevent their consequences. A confidentiality incident may be:

• unauthorized access to personal information;

• use of personal information not authorized by law;

• 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 confidentiality incident that presents a risk of serious injury, CanApply will notify you and the Commission d’accès à l’information du Québec, and any other authority required by applicable law.

20. Minors

Our services are intended for prospective university and graduate applicants. If you are under the age of majority in your place of residence (or under 14 in Quebec), you may only use the Platform with the consent of a parent or legal guardian, who may be asked to confirm their consent and may exercise your rights on your behalf. If we learn that we have collected personal information from a minor without the required consent, we will delete it.

21. 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.

• Access: the right to ask whether we hold personal information about you and, if so, to access it. For security reasons, we may need to verify your identity.

• Rectification: the right to request the correction of incomplete or inaccurate personal information. You can also modify most of your personal information directly on the Platform at any time.

• Withdrawal of consent: the right to withdraw your consent to the use or disclosure of your personal information, subject to legal and contractual restrictions. Deleting your account on the Platform withdraws your consent to the processing of your data, subject to the retention described in Section 18.

• Deletion and de-indexation: the right to request that your personal information be deleted or no longer disseminated, in the circumstances provided by law.

• Restriction: the right to request that a particular person or category of persons not have access to information you identify.

• Portability: the right to receive your personal information, or have it transferred to another organization, in a structured and commonly used technological format.

• Complaint: the right to make a complaint to our Privacy Officer. If you are not satisfied with our response, you may file a complaint with the Commission d’accès à l’information du Québec or, where applicable, with the Office of the Privacy Commissioner of Canada.

If you reside in the European Union, the United Kingdom or another jurisdiction with similar laws, you may also have the right to object to certain processing, to restrict processing, and to lodge a complaint with your local data protection authority. Where these laws apply, we process your information on the basis of your consent, the performance of our contract with you, our legal obligations, or our legitimate interests in operating and improving our services.

22. How can I access my personal information?

Upon request, we will provide you with access to your personal information within thirty (30) days of receiving your request. Access is free of charge, but a reasonable fee may be charged for transcribing, reproducing or transmitting the information.

It is your responsibility to provide accurate, truthful and complete information. If you notice any errors in your personal information, please update it on the Platform or contact our Privacy Officer as indicated in Section 2.

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

We may make changes to this Policy from time to time. Changes will be effective when we post the revised Policy on this page. If we make material changes, we will post a notice on our Platform or notify you by e-mail. Your continued use of our services after the posting of the modified Policy indicates your acceptance of the changes. If you do not accept the changes, you must stop using our services. The “Effective Date” indicated at the top of this Policy is the date it was last updated.

24. 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, please contact our Privacy Officer, whose contact details are set out in Section 2 of this Policy.