Last Updated: October 30, 2025

This Privacy Policy explains how Valnet Inc., a corporation incorporated under the laws of Canada, having its head office at 7405 Transcanada Highway, Suite 100, Saint-Laurent, Quebec H4T 1Z2, and/or its subsidiaries (collectively “Valnet ”, “ us ” or “we”), collects, uses and protects your personal information, which we may collect from you or that you may provide when you visit any of our websites, including https://www.valnetinc.com/ and other digital properties that link to this Privacy Policy (our “Website(s)”) or otherwise use our Website(s) or applications (collectively referred to as services the “Services”).

This Privacy Policy does not apply to :

• Information we may collect from you offline; or information collected by any third-party, including through any application or content (including advertising) that may link to or be accessible from or through the Websites.
• Payment Information Processed by third-parties. Certain Services may require users to provide payment information directly to third-party payment processors.
• Social Media Integration. Users may link their account with third-party social media platforms. When accounts are linked, the social media platform may share certain data with Valnet as per its privacy policy. If you are accessing our Services through a social media account, please refer to the social media provider’s privacy policy for information regarding their data collection.
• Publicly Shared Information (e.g. in open forums, comment sections or user-generated content). Information shared through publicly viewable areas of our Services is not covered by this Privacy Policy.
• Business-Related Information. This Privacy Policy does not apply to information submitted for purposes unrelated to the Services, including employment applications and business inquiries.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Policy.

This policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

You can click on the following links to go directly to the corresponding sections of this Privacy Policy.

1. PERSONAL INFORMATION WE COLLECT
2. HOW WE COLLECT PERSONAL INFORMATION
3. COOKIE, PIXEL TAGS AND SIMILAR TECHNOLOGIES
4. HOW WE USE YOUR PERSONAL INFORMATION
5. SHARING YOUR PERSONAL INFORMATION
6. CHILDREN
7. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
8. YOUR PRIVACY RIGHTS
9. RESIDENTS OF CALIFORNIA
10. RESIDENTS OF NEVADA
11. RESIDENTS OF VIRGINIA
12. RESIDENTS OF THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, AND SWITZERLAND
13. HOW TO EXERCISE MY RIGHTS
14. RESPONSE TIMING AND FORMAT
15. LINKS TO OTHER WEBSITES
16. HOW YOUR INFORMATION IS STORED
17. DATA SECURITY
18. CHANGES TO OUR PRIVACY POLICY
19. CONTACT INFORMATION
20. LANGUAGES

1. PERSONAL INFORMATION WE COLLECT

In this Privacy Policy, we use the term “personal information” to refer to information that can be used by itself or in combination with other available information to identify or be associated with you. Directly identifying information includes, for example, information such as your name, email address, and date of birth. Personal information that is associated or linked to you includes data related to your interaction and usage of our Services.

We do not knowingly collect sensitive personal information or personal information of children under 13 years of age.

We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

We may collect the personal information categories listed in the table below. The table also lists, for each category, our use purposes, and whether we sell the information or share it with third-parties for cross-context behavioral advertising.

Category	Examples	Business Purpose	Categories of Third-parties With Whom Data is Shared/Sold
Identifiers.	A real name, alias, unique personal identifier, online identifier, Internet Protocol (IP) address, email address or account names.	We may collect your full name, IP address, device ID, and other similar identifiers to effectuate your orders, identify you as a user within the 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.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	We may collect your full name, billing address, telephone number, credit card number and other payment information to effectuate your orders, identify you as a user within the Services, to personalize the Services and share with you updates about our new products and services.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	We may collect your other purchasing or consuming histories or tendencies to personalize the Services and share with you updates about our new products and services.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	On the Website we will record your session for UX monitoring to improve our Services.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.
Geolocation data.	Physical location or movements.	We use your location data to personalize the Services and share with you updates about our new products and services.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.
Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	We may generate inferences based on your interactions with our Services. These inferences may reflect preferences, interests, or trends in how you use and engage with our content. Please note that such inferences are drawn solely from behavioral information (e.g., website activity, usage patterns) and not from other categories of Personal Information.	We share this information with third-party service providers, analytics, advertising and marketing partners, our affiliates, and otherwise as might be required for legal or regulatory purposes.For more detailed information please see section “Sharing Your Personal Information” below.

2. HOW WE COLLECT PERSONAL INFORMATION

The Services may collect information from users and users’ devices as follows:

Directly from You. For example, when you sign up for a newsletter, participate in polls, or contests, we may collect certain information from you, including your name, email address, and date of birth.

If you choose to participate in, register or access any of our services including, but not limited to, online accounts, or online content, such as community forums, commenting features, surveys, mod uploads/downloads, or newsletters, we will request and receive personal information such as your name, email address, date of birth, login details, including username and password or other contact details you may provide, as required. This personal information will then be held by us in accordance with this Privacy Policy, as it is necessary for us to carry out the services for which you registered. We may also use this information to improve the function of our Services, online accounts and services and to prevent any abuse of our Services.

Information from Affiliates and Related Companies. Valnet may receive information that affiliates or related companies have collected from a user or device through their account systems, products, or services. For example, we may receive such information if you log in via a third-party platform.

Information from Third-Parties. Valnet may receive information that third-parties collected from a user or device through their services or websites. Such access and use will be consistent with the third-party’s privacy policy.

Information from Advertisements. Valnet may collect information when you interact with advertisements or partner platforms.

Indirectly from You. When you visit our Websites, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Websites, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Websites, and information about how you interact with the Websites. We refer to this automatically-collected information as “Device Information”.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

3. COOKIE, PIXEL TAGS AND SIMILAR TECHNOLOGIES

The technologies we use for this automatic data collection may include the following:

Cookies. A cookie is a piece of data stored your computer tied to information about the user. We and some of our business partners (for example, advertisers) use cookies on our Services. These cookies track usage of our Services for security, analytics and targeted advertising purposes.

We use the following types of cookies:

Essential Cookies: These cookies are essential to the provision of our Services.

Functionality Cookies: These cookies help us remember choices you have made while on our Services, remember your preferences, and personalize your experience on our Services.

Analytics and Performance Cookies: These cookies help us collect statistical and analytical usage to help us analyze your usage of our Services.

Social Media Cookies: These cookies allow you to interact with content on certain social media platforms, such as “liking” our articles. Depending on your social media setting, the social media network will have record of this and may display your name or identifier in relation to this action.

Advertising and Targeted Advertising Cookies: These cookies track your browsing habits and location to provide you with advertising in line with your interests. Please see our "Advertising and Marketing" section below for further details.

Shared ID Cookies: These cookies store a unique user ID in the first party domain and is accessible to our ad partners. This simple ID can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. You can opt out of the Shared ID tracking cookie by clicking here.

Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. If you wish to disable cookies, you may do so through your individual browser options. For further information regarding cookies and how to manage them, please see https://allaboutcookies.org/.

Web Beacons. Pages of our Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Log Files. Like most standard website servers, we use log files. This includes logging the following information: IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/timestamp, and number of clicks to analyze trends, administer our Services, track user’s movement in the aggregate, and gather broad demographic information for aggregate use.

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Websites are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see our Choices About How We Use and Disclose Your Information section below for more details.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use the personal information that we collect generally to enable the functionality of the Services, tailor services to you, send marketing communications, news and updates about the company, etc.

Additionally, we may use information collected for a variety of business purposes such as:

• Providing you with tailored content, services, advertisements and offers from our Websites;
• Responding to your questions and providing news and updates from our Websites;
• Providing you with access to features of the Services;
• Verifying your identity;
• Communicating about your account(s) and activities on the Services;
• Sending notice of changes to our policies;
• Improving the effectiveness of our Services, customer service and offerings;
• Conducting research and analytics related to our operations;
• Protecting our legal rights and interests and enforcing our Terms of Service;
• Processing applications and transactions;
• Posting your content and consumer reviews on the Services, our social media pages and related third-party sites that feature our Websites;
• Contacting you about content shared by you about our Websites and the Services.

5. SHARING YOUR PERSONAL INFORMATION

We may share your personal information with the following categories of service providers:

Third-Party Service Providers: We may rely on third-party service providers to perform a variety of services on our behalf, such as, without limitation, e-commerce providers, payment card processors, telephone and technical support providers, hosting, data storage and processing service providers, and research and analytics providers. Our partners, including ad partners, may collect data in relation to your usage of our Websites as disclosed herein. All such data will only be collected with your prior explicit consent. If we provide your information to service providers, then we require that the service providers keep your personal information secure, and only handle it for limited purposes for which it is provided. We do not authorize the service providers to disclose your personal information to unauthorized parties or to use your personal information for their direct marketing purposes. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us.

Analytics: We may collect, and we may engage third-party analytics providers to collect metrics and information regarding your use of the Services, including evaluating how visitors use our Services to develop new features, improve existing features or inform sales and marketing strategies. We use Google Analytics to help us understand how our customers use the Website – you can read more about how Google uses your personal information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Advertising and Marketing: We use third-party advertising companies to serve ads when you visit our Services. These companies may use information (not including your name, address, email address or telephone number) about your visits to our Services and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

Advertisers, acting as third-party vendors, may use cookies to collect usage and demographic information in order to deliver advertisements through our Services. We make commercially reasonable efforts to review the policies of our advertising partners to help ensure their practices align with applicable data privacy laws and recommended data security standards.

The following is a non-exhaustive list of the advertising partners we work with along with their respective privacy policies, which you may consult to learn more about each partner’s data uses:

• Amazon: https://www.amazon.ca/gp/help/customer/display.html/?ie=UTF8&nodeId=918814
• Blis: https://blis.com/privacy-centre/
• CPM Star (Aditude): https://www.aditude.com/privacy
• Criteo: https://www.criteo.com/privacy/
• Epsilon: https://legal.epsilon.com/global-privacy-policies/
• Equativ: https://equativ.com/about-us/;
• Fluct: https://en.fluct.jp/#about
• Google Ad Exchange: https://policies.google.com/privacy
• Google Ad Sense: https://policies.google.com/privacy
• Gumgum: https://gumgum.com/terms-and-policies/privacy-policy
• Index Exchange: http://www.indexexchange.com/privacy/
• Insticator: https://cool.co/publisher-experiences/privacy/
• Kargo: https://kargo.com/privacy
• Magnite: https://www.magnite.com/legal/
• Media.net: https://www.media.net/privacy-policy/
• One Tag: https://www.onetag.com/privacy/
• OpenX: https://www.openx.com/privacy-center/privacy-policy/
• Optidigital: https://optidigital.com/privacy-policy/
• Ozone Project: https://ozoneproject.com/website-privacy-cookie/
• PubMatic: https://pubmatic.com/legal/privacy-policy/
• Pulsepoint: https://pulsepoint.com/legal/platform-privacy-policy
• Rich Audience: https://legal.richaudience.com/privacy-policy/
• Rise: https://risecodes.com/wp-content/uploads/2023/03/Risecodes.com-Privacy-Policy-March-23-2023.pdf
• Seedtag: https://www.seedtag.com/privacy/
• Sharethrough: https://privacy-center.sharethrough.com/en/
• Smaato: https://www.smaato.com/privacy/
• Sonobi: http://sonobi.com/privacy-policy/
• Sovrn: https://www.sovrn.com/legal/privacy-policy/
• Teads: https://privacy-policy.teads.com/
• The Trade Desk: https://www.thetradedesk.com/legal/website-privacy-policy
• TripleLift: https://triplelift.com/privacy/
• Undertone (Perion): https://perion.com/privacy-policy/
• Unruly: https://unruly.co/legal/privacy/
• Vidazoo (Perion): https://perion.com/privacy-policy/
• Xandr/Appnexus: https://www.microsoft.com/en-us/privacy/privacystatement
• Yieldmo: https://www.yieldmo.com/privacy-policy/

Affiliates: We may share information, including personal information, with companies affiliated with Valnet, and they will use that information only for the purposes that are consistent with those described in this Privacy Policy.

**Promotional and Reward Partners: ** We may share information, including personal information, to third-party service providers.

**Legal or Regulatory Purposes: ** We may disclose personal information to third-parties when legally required to do so, in response to governmental or regulatory requests, or when it believes in good faith that such action is necessary to: (a) comply with applicable laws, legal processes, or lawful requests such as subpoenas or search warrants; (b) protect and enforce the rights or property of Valnet or its affiliates; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

6. CHILDREN

Our Services are not intended for individuals under the age of 16, and we do not intentionally collect personal information from individuals who we have reason to believe are under the age of 16. If we learn that we collected any personal information of children under the age of 16 we will immediately delete such information and the corresponding account.

If you are under 16, do not use or provide any information on our Services, create an account or provide us with any information about yourself, including your name, address, telephone number, email address, or any username you may use.

If you become aware of any personal information we have collected from individuals under age 16, please contact us at data@valnetinc.com.

7. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Services may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated third parties for promotional purposes, you may opt out by clicking the “Do Not Sell My Personal Information” link located at the bottom of the Website you are accessing.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by following the same link.

Opt-Out Preference Signal. You may opt out by broadcasting an Opt-Out Preference Signal, such as the WebChoices Tool and AppChoices Tool (on the browsers and/or browser extensions or device that support such a signal). To download and use either tool, click here:** ** https://youradchoices.com/control.

You can choose to opt-out or unsubscribe from a newsletter or other emails you may receive from us by utilizing the “unsubscribe” link or mechanism noted in such emails, at any time. For forum account deletion requests, where applicable on our Services, you may request deletion of your account by following the instructions provided on the applicable forum’s Website. You can also submit a request to access or erase your data, or any other request to exercise your rights under applicable privacy legislation by contacting us at data@valnetinc.com. Should you have multiple email addresses subscribed or registered with us, you may continue to receive newsletters and/or communications until you unsubscribe each email address provided and/or delete your account(s).

8. YOUR PRIVACY RIGHTS

The states of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information;

• Access and delete certain personal information;

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah);

• Data portability;

• Opt-out of personal data processing for:

• - Targeted advertising (excluding Iowa);

• - Sales;

• - Profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah); or

• - Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights, please contact us as described below.

**Right to Appeal. ** This right provides you with the opportunity to appeal a decision made by us in connection with a rights request.

9. RESIDENTS OF CALIFORNIA

This privacy notice for California Residents supplements the information contained in this Privacy Policy and applies to visitors, users, and others who reside in the State of California. Consumers residing in California have certain rights with respect to their personal information under the California Consumer Privacy Act as amended by the California Privacy Rights Act (“**CCPA”).

Collection and Use of Personal Information. In the preceding 12 months, we collected the following categories of Data: identifiers, personal information categories listed in the California Civil Code Section 1798.80. (e), commercial information, internet or other similar network activity, and geolocation data. For examples of more specific information we collect and the sources of such collection, please see Sections 1-4 in the Privacy Policy. We collect your Data for the business and commercial purposes described in Section 4.

Disclosure of Personal Data. We may share your personal information with third-parties as described in Section 5 above. In the preceding 12 months, we disclosed the following categories of your personal information for business or commercial purposes:

• Identifiers;
• Personal information categories listed in the California Civil Code Section 1798.80(e);
• Commercial information;
• Internet or other similar network activity; and
• Geolocation data.

All categories of personal information listed here may be shared with third-parties as listed in Section 5 above.

Sale of Personal Information. California law requires that we provide transparency about your personal information we “sell,” which for the purposes of the CCPA means scenarios in which personal information is shared with third-parties/partners in exchange for valuable consideration. In the preceding 12 months, we may have “sold” the following categories of your personal information, depending on how the CCPA is interpreted: identifiers, personal information categories listed in the California Customer Records statute, commercial information, internet or other similar network activity, and geolocation data.California law requires that we provide transparency about your personal information we “sell,” which for the purposes of the CCPA means scenarios in which personal information is shared with third-parties/partners in exchange for valuable consideration. In the preceding 12 months, we may have “sold” the following categories of your personal information, depending on how the CCPA is interpreted: identifiers, personal information categories listed in the California Customer Records statute, commercial information, internet or other similar network activity, and geolocation data.**

Your Rights. Please see Section 8 above.

California Rights for Minor Users. California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove information provided by you or publicly posted by you. To make such a request, please submit a verifiable consumer request to us. Please see Section 10 below for more details on how to make a request.**

California Do Not Track Disclosures. “Do Not Track” is an internet browser setting regarding tracking and your browser may allow you to set a DNT signal indicating that you do not wish your online activity to be tracked. As there are currently no agreed upon standards for the DNT signals or how to respond to them, our system does not support and cannot act on DNT signal headers that we may receive.

California’s “Shine the Light” Law. (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes (if any). To make such a request, please send an email to** data@valnetinc.com.

10. RESIDENTS OF NEVADA

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal data to third-parties who may license or sell that data. To exercise this right, please email us at data@valnetinc.com with the subject line “Nevada Do Not Sell Request,” and include your name and the email address associated with your account.

11. RESIDENTS OF VIRGINIA

You have the right not to receive discriminatory treatment from us for exercising your privacy rights under the Virginia Consumer Data Protection Act (VCDPA). Unless otherwise permitted by the VCDPA, we will not:**

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through discounts, benefits, or penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price, rate, level, or quality of goods or services.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, AND SWITZERLAND

If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

As provided under applicable law and subject to any limitations in such law, you have the following rights:

Access. You may ask us to provide you with a copy of the personal information we maintain about you, including a machine-readable copy of the personal information that you have directly provided to us, and request certain information about its processing.

Rectification. You may ask us to update and correct inaccuracies in your personal information. You also may ask us to complete information you believe is incomplete.

Erasure. You may ask to have your personal information anonymized or deleted, under certain conditions.

Restrict Processing. You may request that we restrict the processing of your personal information, under certain conditions.

Object to Processing. You may object to processing of your personal information, under certain conditions.

Data Portability. You may request that we transfer the data that we collected to another organization, or directly to you, under certain conditions.

Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your personal information at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.

Right Not to Be Subject to Automated Individual Decision-Making. You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulatory, and as that you direct your complaint to use first by sending an email at: data@valnetinc.com.

If you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right under the GDPR (as defined below) to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place. The EU Commission has a list of supervisory authorities here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm⁠.

Basis for Processing

The legal bases we rely on to process your personal data depend on the Services you use and how you interact with them. They primarily include:

Consent. You may have consented to the use of your personal information, for example to send you electronic marketing communications. Consent can be withdrawn at any time. This will not affect the lawfulness of the processing before you withdrew your consent.

Contract. We need your personal information to provide you with our Services, to complete your requested transactions, and to respond to your inquiries.

Legal. We may also process your personal information when necessary to protect your or another individual’s vital interests. We may use your personal information as reasonably necessary to assess and ensure compliance with applicable laws, legal requirements, and our policies; to protect our assets or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice or to establish, exercise or defend legal rights); and in response to a court order or judicial or other government subpoena or warrant.

Legitimate Interest. We or a third-party have a legitimate interest in using your personal information, such as preventing fraud. We only rely on this legal basis when such legitimate interests are not overridden by your interests or your fundamental rights and freedoms.

International Transfers

To provide the Services, we may transfer your personal information outside of the country in which it was collected and where the level of protection of personal information may be different than in your country. If we do so, we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision on contractual protections for the transfer of your personal information, or on another approved derogation for a specific situation, such as your explicit consent. For more information about how we transfer personal information internationally, or to obtain a copy of the safeguards we use for such transfers, please contact us as specified below.

13. HOW TO EXERCISE MY RIGHTS

If you would like to exercise any of these rights please contact us by:

• Emailing us at data@valnetinc.com;
• Calling us toll-free at 1-833-979-3525; or
• Filling out the request form here.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.

Your request must:

• Provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person; and
• Describe your request with sufficient detail for us to properly understand, evaluate, and respond to it.

If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Privacy Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

14. RESPONSE TIMING AND FORMAT

We will confirm receipt of your request within fifteen (15) business days . If you do not receive confirmation within the 15-day timeframe, please contact us at data@valnetinc.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

15. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to be aware when they leave our Services, and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Policy applies solely to information collected by our Services.

Our Services may utilize YouTube API Services and the unbranded YouTube embedded player for certain content on our platform. By using these Services, including the unbranded YouTube video player, you agree to comply with YouTube’s Terms of Service, the YouTube API Services Terms of Service, and Google’s Privacy Policy. You can review and adjust your Google privacy and security settings at: https://myaccount.google.com.

16. HOW YOUR INFORMATION IS STORED

All information collected through our Services is stored on servers located in the United States. Our servers are certified under the EU-U.S. Data Privacy Framework.**

IP address and user agent string data from all visitors is stored in rotating log files on Amazon servers for up to seven (7) days. All of our employees, agents and partners are committed to keeping your data confidential.

We store your personal information for as long as necessary to provide you with the Services or as otherwise permitted by law. This means we may retain your personal information even after you close your account with us in order to (i) to comply with our legal and regulatory obligations, (ii) to make or defend legal claims, (iii) to protect against the fraudulent activity of others, (iv) to enforce our Terms of Service and/or this Privacy Policy, (v) to administer our Services and keep them safe and secure, and for internal operations (including, but not limited to, research, statistics, troubleshooting, data analysis, testing, operations, rankings, surveys and similar purposes); and (vi) to disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations or those of any of our affiliated parties; (c) to protect our rights, privacy, safety or property, or that of our affiliated parties, users or others; and/or (d) to allow us to pursue available remedies or limit the damages that we may sustain.

Rather than delete your information, we may de-identify it by removing identifying details.

17. DATA SECURITY

We take reasonable precautions in order to ensure the security of your information. We implemented physical, organizational, contractual and technological security measures with a view of protecting your personal information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your personal information are those with a business ‘need-to-know’ or whose duties reasonably require such information. Despite the measures outlined above, no method of information transmission or information storage is absolutely secure or error-free, and as such, we cannot guarantee absolute security.

We use AWS servers, which comply with ISO 27018:2019, a code of practice that focuses on protection of personal information in the cloud.

In the event that we become aware of any data security breach, alteration, unauthorized access or disclosure of any personal information, we will take all reasonable precautions to protect your information and will notify you as required by applicable laws.

18. CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy to reflect changes in the law, our practices, our Services or our service features. When we do so, we will notify you by changing the date at the top of the policy.

If you object to any of these changes, you may opt out by notifying us at data@valnetinc.com . You may also opt back in at any time by emailing us at the same address.

All changes will be effective immediately upon posting, however we will always update the effective date of such changes at the top of this Privacy Policy. Please review this Privacy Policy periodically so that you are aware of our most current policies and practices.

19. CONTACT INFORMATION

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us as follows:

By e-mail: data@valnetinc.com

**By mail: ** Valnet Inc., 7405 Transcanada Highway, Suite 100, Saint-Laurent, Quebec H4T 1Z2.

If you need to access this Privacy Policy in an alternative format due to a disability, please contact us at data@valnetinc.com.

20. LANGUAGES

In the event of any conflict or inconsistency between this policy in English and any translation thereof in any other language, the English version shall prevail.