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SentinelPro Privacy Policy

1. Introduction

ValServ Inc. ("ValServ" also referred to as "we" or "us") understands and respects the importance of the Personal Information we collect in order to manage our business and maintain commercial relationships. ValServ has developed the present privacy policy (the "Policy") to explain how we collect, use, and disclose ("Process") information about identifiable individuals ("Personal Information") such as you. This Policy also describes your Personal Information protection rights and how to exercise them.

Some provisions may exceed regulatory requirements. In such circumstances, ValServ has full discretion with respect to their application.

2. Notice Requirements

2.1 Accountability: Who is Responsible for my Personal Information?

ValServ is responsible for the Personal Information we Process. We have appointed a Chief Privacy Officer ("CPO") to oversee our compliance with applicable Personal Information protection legislation.

2.1.1 ValServ Contact details

ValServ Inc.
7405 Transcanada Route, Suite 100, Saint-Laurent (QC), H4T 1Z2, Canada
legal@valserv.com
514-733-1010

2.1.2 Contact details of our CPO

Yury Smagorinsky
7405 Transcanada Route, Suite 100, Saint-Laurent (QC), H4T 1Z2, Canada
legal@valserv.com
514-733-1010

2.2 Personal Information

2.2.1 Personal Information We Collect

The tables below outline the types of Personal Information we may collect about you, along with the business or commercial purposes for which we collect such information. Based on how you interact with us, one or more of these tables may apply to you.

Visitors

We may collect, or may have collected, the following categories of Personal Information about you if you visit our site, sign up for marketing materials, or otherwise engage with us before becoming a Customer (each, a “Visitor”):

Category Examples Business or Commercial Purposes
Personal Identifiers. Geolocation. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Internet or Other Similar Network Activity. Information on a consumer's interaction with an advertisement prior to visiting our site. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Device/IP Data. IP address, device ID, domain server, and type of device/operating system/browser used to access our systems, and other information from your user agent string. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Other Identifying Information Voluntarily Provided by Visitor. Emails, letters, text messages, or other communications sent to us. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.

Customers

We collect, or have collected, the following categories of Personal Information about you if you register an account with us (each, a “Customer”):

Category Examples Business or Commercial Purposes
Personal Identifiers. Name, email address, username, password and geolocation. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Commercial Data. Purchase history and subscription status. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Device/IP Data. IP address, device ID, domain server, and type of device/operating system/browser used to access our systems. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.
Other Identifying Information Voluntarily Provided by Visitor. Emails, letters, or other communications sent to us. Provide and improve our services, to personalize the services and share with you updates about our new products and services, as well as for marketing, consumer research and testing.

2.2.2 ValServ Processes the following Personal Information:

  1. Identity and contact information: including your name and email address when you register to become a Customer.
  2. Financial and payment information: ValServ uses a third-party provider to process financial information. If you sign up for a ValServ product, service or platform that permits payment of fees by credit or debit card, and you choose to pay using one of these methods, your payment information is provided directly to our third-party payment processor, Stripe. This information is transmitted securely via an encrypted connection. Stripe processes and stores your Personal Data and payment information in accordance with its privacy policy, available at stripe.com/us/privacy. ValServ does not collect or store any payment information. Stripe states that it is PCI compliant, and you can learn more about its security practices at stripe.com/help/security.
  3. Business information: including information provided in the course of the contractual or Customer relationship between you or your organization and ValServ, or otherwise voluntarily provided by you or your organization.
  4. Profile and usage information: including passwords to our website(s) or password protected products, services or platforms, your preferences in receiving marketing information from us, your communication preferences and information about how you use our website(s), including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs). To learn more about our use of tracking technologies and cookies please refer to Section 2.12 below.
  5. Technical information: including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating systems and platform. To learn more about our use of tracking technologies and cookies please check out the below section 2.12.

Please note: If you provide Personal Information to us about anyone other than yourself, your employees, counterparties, advisers or suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

2.3 Why do we Process your Personal Information?

2.3.1

ValServ Processes your Personal Information to manage our business and to maintain and develop commercial relationships. We only Process such information as is necessary for those purposes. If we are required to Process your Personal Information for a purpose that differs from the purposes described herein, we will obtain your consent before doing so, except in those circumstances set out in Section 2.8 below.

2.3.2 Purposes for which we Process Personal Information are as follows:

  1. To execute any obligations arising from a contract entered into between us and you or to take any steps linked to a contract, with you or your organization. This includes:

    • to register you as a Customer;
    • to provide and administer our services or other services or solutions, as instructed by you or your organization; and
    • to administer and manage our relationship with you, including accounting, auditing, and taking other steps linked to the performance of our business relationship, including identifying persons authorized to represent our Customers, suppliers or service providers.

  2. As required by us to conduct our business and pursue our legitimate interests, in particular:

    • to provide our services and to respond to and address any questions or concerns relating to our services;
    • to analyse and improve our services and communications, including our website operations, and to monitor compliance with our policies and standards;
    • to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
    • for insurance purposes; and
    • to collect information about your preferences to personalize and improve the quality of our communications with you.

  3. As required by us to conduct marketing or other promotional activity, including:

    • to communicate promotional material that you have requested and to which you may unsubscribe by clicking on the unsubscribe link or following the Unsubscribe instructions included in every mail; and
    • to support you in your participation in our marketing or continuing legal education programs, for example when you require accommodations for events or technical assistance for a webinar.

  4. As required to comply with any legal duties or to take legal action, including:

    • to protect our rights and safety as well as that on any third parties;
    • to comply with any legal requirements or court orders;
    • to prosecute and defend a court, arbitration, or similar proceeding; and
    • to communicate this information to any advisors who assist us in complying with legal, accounting, or security requirements.
  5. As otherwise permitted by law.
  6. In the event of a transaction: In the event ValServ or its assets are acquired by, or merged with, a third party, ValServ reserves the right to transfer or assign your Personal Information as part of that transaction, including in a merger, acquisition, sale, or other change of control. In the unlikely event of bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or under laws affecting creditors’ rights generally, ValServ may no longer have control over how your Personal Information is treated, transferred, or used.

ValServ will only provide you with marketing related information after you have, where legally required to do so, opted to receive those communications and have provided the opportunity for you to opt out at any time.

ValServ will not use your Personal Information for taking any automated decisions affecting or creating profiles other than as described above.

ValServ will not use Personal Information for a purpose other than for which it was collected except with your consent, unless:

  1. Legal, medical or security reasons make it impossible to obtain consent; or
  2. ValServ is permitted or required to do so by applicable laws.

2.4 How do we Collect your Personal Information?

The circumstances in which ValServ may collect Personal Information about you include:

  1. When you or your organization seek advice from us or use any of our online Customer services;
  2. When you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including in conversation with our employees;
  3. When you or your organization browse, complete a form (including information reporting a problem with the website) or make an inquiry or otherwise interact on our website or other online platforms you are willingly providing information which could be included in the collection of Personal Information. Depending on the circumstances, this may include Personal Information such as, but not limited to, physical mailing address, personal email address, phone number(s), and other details like gender, occupation, and other demographic information. More information on how our website Processes Personal Information can be found in Section 2.8 below; and
  4. When you attend our seminars or other events or sign up to receive information from us including training.

2.5 What Happens if I do not Provide my Personal Information?

We may need to collect Personal Information as outlined above in order to process your instructions, perform a contract we have with you or provide the services you signed up for. If you fail to provide the required Personal Information when requested, we will not be able to carry out your instructions, perform the contract we have or are trying to enter into with you or provide the services you signed up for.

2.6 How much Personal Information do we Require?

ValServ limits the Personal Information we Process to what is necessary for managing our business and maintaining and developing our commercial relationships, including providing our services to you.

2.7 How is your Personal Information Processed when Using our Website?

2.7.1 Information Collected from your Use of Our Site

To ensure our website is optimized for ease of use, and/or for future communications, ValServ or our service provider(s) may use cookies to collect standard internet information about how and when you use the website. This information may include, but is not limited to, your IP address and location data, weblogs, time, date, language preferences, browser used, referring web addresses, other communication data, searches conducted, and pages visited.

2.8 Do we Share your Personal Information?

ValServ may share your Personal Information only in the following circumstances and with the following recipients:

  1. With our subsidiary undertakings and/or affiliates for the purposes of providing you with our services;
  2. With third-parties including certain service providers we have retained in connection with the services we provide, such as servers, cloud providers; or other necessary entities, for the purposes of providing you with our services;
  3. On a confidential basis with third-parties for the purpose of collecting your feedback on our services, to help us measure our performance and to improve and promote our services;
  4. With companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes, and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such Personal Information is shared;
  5. With courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
  6. With service providers who we engage within or outside of ValServ, domestically or abroad, (e.g. shared service centres), to Process Personal Information for any of the purposes listed above on our behalf and in accordance with our instructions only; and
  7. If we engage in a commercial or business transaction - as defined by applicable privacy legislation - in which case, we may disclose your Personal Information to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.

Please note: ValServ, its third-party service providers and other third parties to whom we disclose information under this Policy may perform activities outside of Canada. Any Personal Information that is Processed in countries outside of Canada may be subject to the laws of those countries. As a result, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement officials in countries outside of Canada. You may seek additional information regarding the Processing of your Personal Information outside of Canada by contacting our CPO at the contact details found in Subsection 2.1.2 above.

2.9 How Long do we Retain your Personal Information?

Personal Information that ValServ collects and Processes as a controller for the purposes identified above is not kept by us for longer than necessary for the purposes for which the Personal Information is Processed. The length of time for which we retain Personal Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. When we no longer have a legitimate business need to retain your Personal Information, we will either delete or anonymize it.

2.10 How do we Ensure your Personal Information is Accurate?

ValServ uses reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up to date as possible. We do not routinely update your Personal Information, unless such an update is necessary. In order to help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide to us.

2.11 How do we Safeguard your Personal Information?

ValServ is committed to protecting the confidentiality, integrity, and availability of your Personal Information. We employ security safeguards that are customary and appropriate in view of the sensitivity of the information, including physical, organizational and technological measures. Examples of such measures include restricted access to offices, training of personnel, limiting access to information on a "need-to-know" basis, using passwords and well-defined internal policies and practices.

Unfortunately, the transmission of information via the internet is not completely secure. Although we make significant efforts to protect your Personal Information, we cannot guarantee the security of data transmitted to our website. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure.

ValServ is committed to being transparent about our policies and invites you to contact the CPO with any question you may have or to visit our website.

2.12 Tracking Technologies and Cookies

2.12.1 Tracking technologies used

ValServ utilizes tracking technologies, namely Urchin Tracking Module ("UTM") parameters to measure the effectiveness of marketing campaigns, and "pixel tags" to monitor website performance, support site functionality and to provide the services requested by our Customers.

UTM parameters are employed to identify the source of a hyperlink, the medium through which the hyperlink was accessed, and the specific marketing campaign or promotion associated with such hyperlink. These parameters are used for marketing analytics purposes. On the SentinelPro website, UTM parameters are used to track marketing sources, mediums, and campaign parameters of Visitors to the website. On Customer website(s), UTM parameters are used to track marketing sources, mediums, and campaign parameters of visitors to our Customers’ websites.

Pixel tags are small graphic images embedded in webpages or emails, containing a unique identifier, which allow ValServ to collect data such as page views, view duration and scroll depth. Pixel tags are not stored locally on a user’s device, and are utilized to monitor website-related statistics and support essential site functionality and performance monitoring. On the SentinelPro website, pixel tags are implemented to collect metrics necessary for functionality and performance monitoring. Pixel tags are also provided by ValServ to its Customers for implementation on their websites to collect metrics necessary for the services’ functionality and performance monitoring.

When a Visitor accesses our SentinelPro website via a URL containing UTM parameters, our website may use pixel tags to detect these parameters and store them in a cookie placed on your browser. This allows us to preserve the association between the UTM parameters and your visit as you navigate across different pages on our SentinelPro website.

The information collected via the tracking technologies described above is used for analytics, functionality and performance measurement purposes and helps us improve our services and marketing strategies. You can limit UTM tracking by clearing cookies from your browser or using private browsing.

ValServ does not collect Personal Information from Visitors or Customers through targeted advertising cookies, nor do we engage in targeted advertising practices on behalf of our Customers.

2.13 What are your Rights

2.13.1 You have various rights with respect to our use of your Personal Information:

  1. Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information. To do so, please contact us at the details provided at Subsection 2.1.2. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information.
  2. Accuracy: We aim to keep your Personal Information accurate, current, and complete. We encourage you to contact us by writing to our CPO as detailed in the above Subsection 2.1.2 to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.
  3. Cessation of Dissemination: You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order. You also have the right to request that we cease disseminating your Personal Information where the following conditions are met:
    • the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
    • the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
    • the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.
  4. Mobility: You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. (iii) This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.
  5. Complaints: If you believe that your Personal Information protection rights may have been violated, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.
  6. You may, at any time, exercise any of the above rights, by contacting the CPO or using our contact methods available at https://sentinelpro.com/pages/contact.

2.13.2 Access to Information

You may enquire about your Personal Information by contacting our CPO as detailed in the above Subsection 2.1.2. In circumstances where we are not able to provide access, we will advise you in writing.

ValServ may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request.

You may learn more about the process or obtain assistance in completing an access request by contacting the CPO.

2.13.3 Right to Withdraw Consent

If you have provided your consent to the Processing of your Personal Information, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact the CPO.

Once we have received notification that you have withdrawn your consent, we will no longer Process your information for marketing purposes. However, we may continue to Process your Personal Information for both pre-contractual and contractual performances and requests when it is necessary to enable you to utilize some or all of our services.

2.14 How do we Resolve your Concerns?

Any report, concern, complaint or incident of which we become aware that involves conduct that may contravene the Policy will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry and implement solutions, as appropriate.

2.14.1 Incident Reporting and Escalation Process

We take all potential or actual Personal Information breaches seriously. You may report your concerns about the Processing of your Personal Information directly to our CPO. The CPO will engage the appropriate levels of management to assist with resolution of the issue.

2.14.2 Alternative Actions

While we are committed to resolving all Personal Information matters internally, nothing in the Policy precludes you from contacting the appropriate federal or provincial privacy commissioner.

2.14.3 Prohibition Against Retaliation

We will not retaliate against a Person who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.

3. Privacy Protection for Children

Our website and services are not intended for children. We do not knowingly collect children’s Personal Information. If we learn that we have collected Personal Information through our services from a child without the consent of their parent or guardian as required by law, we will comply with applicable legal requirements to delete the information. If you are a parent or guardian of a child from whom you believe we have collected Personal Information in a manner prohibited by law, please contact us.

4. EU, UK, and Swiss Resident Rights

If the Processing of Personal Information about you is subject to European Union, United Kingdom or Swiss data protection laws, you have certain rights with respect to that information:

  1. You can request access to, and rectification or erasure of your Personal Information;
  2. If any automated Processing of Personal Information is done with your consent or under a contract with you, you have a right to transfer or receive a copy of the Personal Information in a usable and portable format;
  3. If the Processing of Personal Information is based on your consent, you can withdraw consent at any time for future processing. However, we may continue to Process your Personal Information for both pre-contractual and contractual performances and requests when it is necessary to enable you to utilize some or all of our services; and
  4. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

You have the right to lodge a complaint about ValServ’s practices with respect to your Personal Information with the supervisory authority of your country or EU Member State, but we encourage you to first contact us with any questions or concerns. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

5. Roles and Responsibilities

ValServ is responsible for communicating the Policy and ensuring that employees fully comply with all relevant aspects of the Policy and the accompanying guidelines.

5.1 Business and Infrastructure Units

Business or infrastructure units that Process Personal Information other than as required, are responsible for ensuring that these activities comply with the Policy.

5.2 ValServ Chief Privacy Officer (CPO)

The CPO is responsible for:

  1. Developing ValServ’s Personal Information protection strategy;
  2. Developing and maintaining the Policy, accompanying guidelines and any other policy or procedure related to Personal Information and ensuring they comply with applicable law; and
  3. Serving as the official liaison with the federal and provincial commissioners.

6. Maintenance and Review

The Policy is effective as of August 6, 2025, and supersedes all prior versions.

ValServ reserves the right to interpret the Policy at its sole discretion and to make changes as it deems appropriate from time to time without the requirement of advanced notice.

Personal Information protection legislation continues to evolve and, as a result, this Policy may be amended by us from time to time at our full discretion without any prior notice or liability to you or any other persons. The Processing of your Personal Information by us will be governed by the version of this Policy in effect at that time.