General Privacy Policy of TCHAT N SIGN

TCHAT N SIGN, owner and operator of the TCHAT N SIGN platform, is committed to protecting the privacy and personal information of individuals who use the TCHAT N SIGN platform and TCHAT N SIGN services.

You acknowledge and agree that the Terms of Use ("TCHAT N SIGN Terms of Use") govern your use of the TCHAT N SIGN platform. All capitalized terms have the meaning assigned to them in the TCHAT N SIGN Terms of Use, unless otherwise indicated in this General Privacy Policy.

This Privacy Policy describes TCHAT N SIGN's practices for ensuring the protection of personal information in connection with the use of the TCHAT N SIGN platform and TCHAT N SIGN services, as well as individuals' rights regarding the collection, use, disclosure, retention, access, correction and deletion of personal information. TCHAT N SIGN's Privacy Policy and practices comply with all applicable federal and provincial laws and regulations, including the requirements of Law 25 (Act to modernize legislative provisions respecting the protection of personal information).

TCHAT N SIGN reserves the right to modify this Privacy Policy at any time at its sole discretion. The date of the last update is always indicated in the upper left corner of this Privacy Policy. We will notify you of any material changes to this Privacy Policy by posting a notice on the home page (pop-up window) of the TCHAT N SIGN platform for a reasonable period following such changes. We encourage you to regularly review this Privacy Policy to stay informed of any modifications. If you continue to use the TCHAT N SIGN platform or provide us with personal information after the date of updates, we will consider that you have accepted the updated version of this Privacy Policy.

If you have any questions, comments, requests or complaints regarding this Privacy Policy or our practices, please contact us by email at [email protected].

1. What types of information do we collect?

We may collect two types of information from users:

Personal Information: Personal information is information that identifies you, including, but not limited to, your name, address, phone number, email address, gender, age, marital status, education level, intentions, preferences and opinions.

Non-Personal Information: Non-personal information is information that does not identify an individual, such as aggregate statistical data (e.g., average time spent on the TCHAT N SIGN platform, number of web pages viewed, etc.) or other anonymous data, such as the type of browser used to access the TCHAT N SIGN platform and its version, location data, your MAC address and passive data from your mobile device (if your mobile device's Wi-Fi connection is enabled) and registration information from third parties when you log in using Facebook or other platforms to access our TCHAT N SIGN services. Please check your privacy settings with these third-party services to ensure you are only sharing the information you wish to share.

We collect personal information when you express interest in obtaining additional information about our TCHAT N SIGN services, to use the TCHAT N SIGN platform or our TCHAT N SIGN services. TCHAT N SIGN then asks you to provide personal information, such as your name, company name, address, phone number and email address ("Required Information").

When you, as a customer, subscribe to the TCHAT N SIGN platform, TCHAT N SIGN may also ask you to provide, for the benefit of the payment service providers with whom we work, financial or billing information, such as billing name and address, credit card number ("Billing Information") in accordance with the Payment Terms, it being understood that TCHAT N SIGN does not hold Billing Information at any time, which is held by the payment service providers with whom we work.

When you browse the TCHAT N SIGN platform, TCHAT N SIGN may also collect information using common data collection tools, such as cookies and web beacons ("Platform Navigation Information"). Platform Navigation Information includes standard information from your web browser (such as browser type and language), your Internet Protocol ("IP") address, and your activities on our TCHAT N SIGN platform (such as web pages you visit or links you click).

Personal Information, Required Contact Information, Billing Information, Platform Navigation Information, and any other information you submit to TCHAT N SIGN or through TCHAT N SIGN services are collectively referred to as "Data".

2. Why do we collect and use Data?

We collect your Data only for purposes justified by our business activities and our TCHAT N SIGN services. We collect Data to:

• identify you and communicate with you;
• respond to your requests regarding our TCHAT N SIGN services;
• conduct our business activities;
• comply with legal requirements;
• provide our TCHAT N SIGN services;
• analyze, personalize and improve the user experience;
• provide greater security and better fraud protection;
• provide you with personalized and practical information about our TCHAT N SIGN services, improvements, recommendations, advertisements and promotional communications that we believe are relevant to you;
• improve the TCHAT N SIGN platform and TCHAT N SIGN services;
• obtain your feedback through surveys.

3. How is the collected Data used?

Data collected by TCHAT N SIGN is either obtained directly from you (you provided it yourself), or when you consented to share information from your mobile devices with us for a superior personalized browsing experience.

TCHAT N SIGN collects Data, whether or not considered Personal Information, that is necessary to send important notices and resolve customer service issues, including those that may arise in billing matters. Additionally, if you, as a customer, have given your express consent when creating your TCHAT N SIGN account, TCHAT N SIGN may contact you to announce special offers or promote TCHAT N SIGN services in any way.

TCHAT N SIGN may also collect information about users from other sources to which you have previously consented to have your information collected, used and disclosed. We may combine this information with the Data we already have about you to improve our TCHAT N SIGN services. This allows us to update our databases, better understand your needs, analyze our records and identify new users.

TCHAT N SIGN uses Platform Navigation Information to operate and improve the TCHAT N SIGN platform. We may also use Platform Navigation Information alone or in combination with Data to provide personalized information about our TCHAT N SIGN services. To learn more about the use of Platform Navigation Information, please refer to section 4 "Platform Navigation Information" below.

4. TCHAT N SIGN Platform Navigation Information

Cookies, Web Beacons and IP Addresses

TCHAT N SIGN uses common data collection tools, such as cookies and web beacons, to collect information when you browse the TCHAT N SIGN platform. As described in more detail below, we use these cookies or similar technologies to analyze trends, manage the TCHAT N SIGN platform and the TCHAT N SIGN services we offer, track user movements on our TCHAT N SIGN platform and between our TCHAT N SIGN services, and provide personalized content.

Cookies

TCHAT N SIGN uses browser cookies to make your interactions with our TCHAT N SIGN platform possible. When you visit our TCHAT N SIGN platform, TCHAT N SIGN's servers send a browser cookie to your computer or device. TCHAT N SIGN uses session cookies. Session cookies exist only during a session. They disappear from your computer or device when you close your browser or turn off your computer. They are used to authenticate you and give you access to our TCHAT N SIGN platform and our TCHAT N SIGN services.

Specifically, the TCHAT N SIGN website uses the following cookies:

Third-Party Cookies

TCHAT N SIGN uses Google and Google Analytics services to collect, compile and analyze Data to better understand how the TCHAT N SIGN website is used. TCHAT N SIGN uses these cookies to collect aggregate and anonymous Data for a limited period. The Data is used, among other things, to monitor and analyze the use of the TCHAT N SIGN website, improve its functionality, and more precisely select content and design, all with the aim of meeting user expectations. This type of cookie is not used on the TCHAT N SIGN platform.

Web Beacons

TCHAT N SIGN uses web beacons alone or in combination with cookies to compile information about how users respond to TCHAT N SIGN emails. Web beacons are transparent electronic images that can recognize certain types of information on your computer, such as cookies, whether you have visited a website or service linked to the web beacon, and the description of a website or service linked to the web beacon. For example, TCHAT N SIGN may place web beacons in marketing emails that inform it when you have opened the email.

Log Files, IP Addresses, URLs and Other Data

Like most websites, we automatically collect certain information to analyze aggregate trends and administer the TCHAT N SIGN platform and TCHAT N SIGN services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the web), device and application identification numbers, your location, the type of browser you use, the Internet service provider or mobile service operator you use, the pages and files you viewed, your searches, your operating system and system configuration information, and the date and time of your use. This information is used to analyze aggregate trends and help us improve the TCHAT N SIGN platform and TCHAT N SIGN services, track and aggregate non-personal information, and provide the TCHAT N SIGN platform and TCHAT N SIGN services. For example, the TCHAT N SIGN platform uses IP addresses to provide a security trail of activities in your TCHAT N SIGN account, or activities of signers using the TCHAT N SIGN platform or activities of visitors to the TCHAT N SIGN platform.

5. Sharing of Collected Data

Unless otherwise indicated in this Privacy Policy, TCHAT N SIGN does not share, sell, rent or trade Data with third parties for promotional purposes.

TCHAT N SIGN uses a third-party service provider to manage payments. This service provider is not authorized to store, retain or use Billing Information except for the purpose of processing payments on behalf of TCHAT N SIGN. This service provider has its own privacy policy but is contractually required to keep all personal information provided to it confidential. Additionally, the service provider is prohibited from using the Data for any other purpose.

TCHAT N SIGN reserves the right to access, retain and disclose any information, including your Data, that we deem necessary to comply with the law, a court order or a government request.

6. International Transfer of Collected Data

With the exception of Data that may be stored in the United States as part of the VoIP services offered by TCHAT N SIGN (including, but not limited to, caller identification, date, time and duration of the call) for which we deal with providers whose servers are located in the United States, we store Data in Canada. To facilitate TCHAT N SIGN's international operations, we may access this information from anywhere in the world. This Privacy Policy applies regardless of the country from which we access the Data.

7. Consent

By accepting this Privacy Policy, you give us permission to collect, use, process and disclose your Data for the purposes specified above.

8. Communication Preferences

TCHAT N SIGN offers users who provide their contact information the ability to choose how we use the information provided. You can manage the marketing emails and non-transactional communications you receive by clicking the "Unsubscribe" link at the bottom of marketing emails or from your TCHAT N SIGN account. Additionally, you can contact us using the information in the "Contact Us" section below. We will not contact you if you have closed your account, your information will not be retained.

9. Withdrawal of Consent

You may withdraw your consent (unsubscribe) at any time by sending a written request to [email protected] or by mail to the address indicated in the "Contact Us" section below. We will obtain your consent before using your Data for any purpose other than those described above. Your Personal Information will be deleted once it is no longer necessary for the purposes described above.

10. Access, Correction and Updating of Your Information

You may request personal information that we have collected by sending us an email at [email protected] or by mail to the address indicated in the "Contact Us" section below. Once we receive your request, we will send you all the information we have collected within one week, free of charge. For your protection, we may ask you for proof of identity. We reserve the right to refuse access to requested information. You will be informed of the reasons for this refusal.

TCHAT N SIGN may retain your information for a period consistent with the original purpose of collection. TCHAT N SIGN may also retain your personal information as long as necessary to pursue its legitimate business interests, conduct audits, comply with its legal obligations, resolve disputes and enforce its contracts.

Upon request and subject to proof of identity, you may correct, delete or modify any Data you have previously provided to us through the TCHAT N SIGN platform and our TCHAT N SIGN services. There is no charge to access and correct your personal information.

As a customer, if you have created an account with TCHAT N SIGN, you can update your user settings, profile, electronic signature and IP telephony settings by logging into the TCHAT N SIGN platform with your username and password. You can then modify your profile or settings. To update your Billing Information, cancel your account or request that we return or delete your account Data, please contact your account representative or our customer service team. You can make any other request for access, correction, modification or deletion of your Data by email at [email protected] or by mail to the address indicated in the "Contact Us" section below. Requests for access, correction, modification or deletion of your Personal Information will be processed within a reasonable time.

11. User Data

Users using the TCHAT N SIGN platform may submit Data or information to TCHAT N SIGN services for electronic hosting and processing. TCHAT N SIGN will not view, share, distribute or reference such Data except as necessary to provide TCHAT N SIGN services or if required by law.

12. Security

TCHAT N SIGN employs strict security measures to protect Data in its custody and control against loss or theft, as well as against unauthorized disclosure, copying, use, modification or access. The measures we take are physical, organizational and technological. Our employees are aware of the importance of maintaining the confidentiality of Data. When Data is no longer needed to meet the purposes for which it was collected, we take all necessary precautions to dispose of or destroy it in a manner that prevents any unauthorized party from accessing it. We have internal procedures in place to protect Data and receive and respond to your requests or complaints. Our employees are trained and familiar with our policies and practices. We have appointed a privacy officer who ensures that we comply with this Privacy Policy and applicable laws. Our Privacy Officer is: Jeannot Plamondon, Privacy Officer, Tchat N Sign Solutions inc., 375 Boulevard De Quen, Alma, Quebec, G8B 5P2, Email: [email protected]. In accordance with Law 25, TCHAT N SIGN conducts Privacy Impact Assessments (PIAs) for any project involving the collection, use or disclosure of personal information that presents high risks to privacy.

13. Automated Decisions and Artificial Intelligence (Law 25, art. 12.1)

In accordance with Article 12.1 of Law 25, TCHAT N SIGN informs you of the use of automated decision technologies:

The TCHAT N SIGN platform may use artificial intelligence systems to:

• Automatically detect and prevent sensitive data leaks in communications;
• Analyze message content to identify personal information requiring enhanced protection;
• Suggest compliance actions to users;
• Improve service quality through usage pattern analysis;
• Transcribe voice audio in real time when the AI Assistant feature is enabled (premium feature, disabled by default, requires explicit activation by team administrator). Voice audio is processed by Angany AI on servers located in Canada (Quebec) and is not retained after transcription.

You have the right to be informed when a decision concerning you is made exclusively by automated processing. You may request that this decision be reviewed by a natural person by contacting [email protected].

TCHAT N SIGN does not use fully automated decision systems that produce legal or significant effects on users without human intervention.

14. Data Retention Periods

In accordance with Law 25 (art. 63), TCHAT N SIGN retains your personal data only for as long as necessary for the purposes for which it was collected. Here is our retention schedule:

Upon expiration of these periods, data is securely destroyed or irreversibly anonymized.

15. Subprocessors and Third Parties with Data Access

In accordance with our transparency obligations, here is the list of subprocessors that may have access to your personal data in connection with the provision of TCHAT N SIGN services:

All our subprocessors are bound by contractual agreements ensuring the protection of your personal data in accordance with applicable standards and this Privacy Policy.

This list may be updated. The current version is always available on this page.

16. Data Subject Rights (Law 25 - Quebec)

If you are subject to Law 25 in Quebec, you have specific rights regarding your personal data:

• Right of Access: You can obtain confirmation from us whether or not your Data is being processed by TCHAT N SIGN and obtain a copy. You can also obtain information about the purposes of the processing, the categories of Data in question, the identity of the persons to whom the Data has been or will be disclosed, where it is stored, the source of the Data if not collected from you, and other information about our profiling activities by sending a request to [email protected]. We will respond within a reasonable time after receiving proof of identity.
• Right to Correction: You may update or correct your Data at any time through your TCHAT N SIGN account with immediate effect or by sending a request by email to [email protected]. We will respond within a reasonable time after receiving proof of identity and correct inaccurate Data within thirty (30) days of receiving your request.
• Right to be Forgotten: In certain cases, you may ask us to delete your Data from our records. The decision to delete or not delete your Data is based on several factors, including compliance, record keeping and other constraints beyond our control. To request deletion of your Data, please "Delete your account" from your TCHAT N SIGN account. Your Data will be deleted from our active servers within 7 days, subject to applicable legal retention obligations as set out in Section 14 of this Privacy Policy (including, without limitation, billing data retained for 7 years as required by applicable law), or please send an email to [email protected]. We will respond within a reasonable time after receiving proof of identity.
• Right to Restrict Processing: You may grant, withdraw or restrict your consent to the processing of your Data at any time by sending a request by email to [email protected].
• Right to Portability: If you wish to receive a copy of the Data we hold about you in a readable format, please send a request by email to [email protected]. We will respond within a reasonable time after receiving proof of identity.
• Right to Object: You have the right to object to the processing of your Data at any time, including for marketing purposes, including profiling in connection with direct marketing, by sending a request by email to [email protected] or by changing your settings in your TCHAT N SIGN account.

17. Privacy Incident

An incident (hereinafter "Privacy Incident") constitutes:

• Access to personal information unauthorized by law;
• use of personal information unauthorized by law;
• unauthorized disclosure of personal information;
• loss or any other breach of personal information.

In the event of a Privacy Incident, TCHAT N SIGN will take reasonable steps to minimize the risk of harm and to prevent similar incidents from occurring in the future. TCHAT N SIGN will communicate to you the details of the Privacy Incident affecting some of the personal information held by TCHAT N SIGN as soon as possible when such incident is likely to result in a risk of serious harm to the affected person. This communication will describe, in clear and simple terms, the nature of the Incident and will contain at least the information and measures mentioned in points a, b, c, and d above.

TCHAT N SIGN will document any Privacy Incident in its Privacy Incident register, indicating the facts of the Personal Data breach, its effects, and the measures taken to remedy it. In accordance with Law 25, TCHAT N SIGN will notify the Commission d'accès à l'information (CAI) with diligence and, when the incident presents a serious risk of harm, within a maximum of 72 hours of becoming aware of it. This notification will, at a minimum:

• Describe the nature of the Privacy Incident breach, including, if possible, the categories and approximate number of affected persons and the categories and approximate number of Personal Information records affected;
• indicate the name and contact details of the privacy officer or any other point of contact from whom additional information can be obtained;
• describe the likely consequences of the Privacy Incident;
• describe the measures taken or proposed by TCHAT N SIGN to remedy the Privacy Incident, including, where applicable, measures to mitigate the negative consequences.

18. Hyperlinks

The TCHAT N SIGN platform may contain links to other websites. By activating these hyperlinks, you will leave our TCHAT N SIGN platform and be directed to third-party sites, which may have different privacy policies and terms of use than those of the TCHAT N SIGN platform. You follow links to other sites at your own risk. You will not hold TCHAT N SIGN responsible for the content of third-party websites linked to the TCHAT N SIGN platform, and TCHAT N SIGN is not responsible for the use of such third-party websites. In no event shall TCHAT N SIGN's links to an external website be construed as an endorsement or acceptance of responsibility for the content or use of that site. TCHAT N SIGN makes no representations as to the quality, security, relevance or reliability of external websites or the content or materials they contain. When you visit external websites, you should review their privacy policies and terms of use to learn more about the personal information they collect, why they collect it and how they use it. Hyperlinks are posted on the TCHAT N SIGN platform to provide you with easy access to a variety of information.

Have a question? Contact us

You may send your questions, comments, requests and complaints regarding this Privacy Policy or our practices regarding personal information by email to [email protected] or by mail to: