Privacy Policy

"Personal information" means any information relating to an identifiable individual.

We do not consider business contact information to be personal information when it is used in a professional context.

This Policy does not apply to the personal information of employees, consultants, or other individuals associated with Propulsion.

To protect your personal information, we have implemented policies, practices, and procedures governing the management of the personal information we hold. We have implemented an internal program compliant with Law 25 governing the governance, security, retention, destruction, and management of confidentiality incidents.

These internal policies and procedures govern the collection, use, disclosure, retention, and destruction of personal information, as well as the handling of complaints, information security, and Propulsion's data governance. They also provide the framework for conducting privacy impact assessments when necessary, as well as preventing and responding to potential confidentiality incidents. All such policies and practices have been approved by our Privacy Officer.

The collection of your personal information through our Services complies with the requirements of this program.

Privacy Officer

The person with the highest authority in our organization has delegated management of the Personal Information Protection Program to the Privacy Officer. Their duties include managing and internally monitoring Propulsion's personal information protection program.

The Privacy Officer approves and implements personal information protection policies and procedures, ensures their proper operation, and reports to Propulsion's senior management on the effectiveness of the program.

The Privacy Officer is also responsible for providing you with the assistance required in the event of a question, complaint, or request regarding the protection of personal information:

Azaria Chavannes
President and Privacy Officer
Propulsion Technologies Inc.
410, rue de Marika
Québec, QC, G3G 1L6
support@propulsionsport.com

We are committed to responding promptly to your requests.

Upon receiving a complaint, the Privacy Officer will conduct an investigation. If the complaint is justified, the situation will be corrected. Regardless of our conclusion, we will keep you informed.

Propulsion must collect and process certain personal information so that you may use our Services.

When we collect your personal information, we ensure that we only collect the information necessary to achieve one of our purposes, which will have been previously disclosed to you, for example in this Policy. We use personal information in accordance with applicable privacy laws.

With your consent

As required by applicable privacy laws, Propulsion collects most of your personal information based on your voluntary consent, favouring collection directly from you.

Propulsion is committed to obtaining your explicit consent for the collection of any sensitive personal information.

Since our Services are intended for business clients, we do not have a direct business relationship with the end user of the Platform. For this reason, we require our clients to ensure that they have obtained all mandatory consents from end users of the Platform when necessary. End users should specifically have been informed that their personal information may be transferred to service providers, such as Propulsion.

We also require our clients to provide all legally required notices to end users of the Platform and to ensure that the use, collection, or disclosure of personal information between Propulsion and the client is authorized.

Other legally permitted basis

As permitted by applicable privacy laws, Propulsion may collect personal information without your explicit consent, for example to comply with obligations under applicable laws or to fulfill our contracts.

We collect personal information when you interact with our Services, including when you:

• create an account or update your profile information;
• use our Platform or our Site;
• subscribe to our Services;
• communicate with our customer service or support team;
• participate in surveys, contests, or promotions;
• submit comments, reviews, or other content;
• interact with our advertising and promotional content.

The personal information we collect may include, without limitation: your name, email address, phone number, communication preferences, IP address, device information, approximate location data inferred from the IP address, activity data, and information regarding your use of our Services.

Automatically collected data

• IP address;
• date and time of visit;
• browser, device, operating system;
• mobile identifiers (IDFA, AAID);
• pages viewed, links clicked.

Non-automatically collected data

• first and last name;
• email address;
• phone number (optional, used only for code/PIN authentication);
• account information;
• communication preferences.

Physical activity data (optional)

With your explicit consent, we collect step count, estimated distance, and activity duration. The user can disable access at any time.

We do not collect any GPS data or movement trajectory.

User-generated content

Our application includes a social wall. Content published on the social wall is visible only to authorized users within your organization. You may voluntarily publish photos, text and comments, and interactions (likes).

Access to the camera or gallery is activated only with your authorization and when you choose to upload a photo. Photos published may be visible to other users depending on the application's features. You may delete your content at any time.

Diagnostic and performance data

We use Sentry and/or Firebase Crashlytics to analyze errors, including crash logs, device model, operating system version, and application state at the time of the crash. This data is used solely to improve application stability.

We collect only the personal information necessary to fulfill the purposes defined in this Policy. We also collect anonymized analytical data, not considered personal information.

We use your personal information for the following purposes:

• to provide, update, and improve our Services;
• to personalize your experience and tailor the content we display;
• to inform you of updates, changes to our terms, conditions, and policies, special offers, promotions, or newsletters;
• to ensure security and prevent fraud;
• to communicate with you, including responding to your questions, requests, comments, complaints, and support inquiries;
• to analyze the use of our Services, including identifying usage trends and the effectiveness of our promotional campaigns;
• to comply with any applicable law or regulation, including responding to requests from public and governmental authorities, protecting our operations and legitimate interests, or pursuing available remedies;
• for any other purpose to which you have consented.

We do not use your photos or your activity data for advertising purposes.

If we wish to use your personal information for a purpose not mentioned above and for which you have not consented, we will ensure that we obtain appropriate consent or inform you of the change, when permitted by law.

Your personal information will not be sold to third parties.

We will share your personal information with third parties when necessary to provide our Services or respond to your request, if required by law or court order, or to fulfill tasks entrusted to us by contract with our clients.

With our employees

In the course of their work, our employees and managers may need to access your personal information, for example when you contact us. Their access is limited to what is necessary to perform their duties.

With our service providers

Our business partners may sometimes need to access or receive certain personal information to perform their services (payment processors, cloud hosting providers, maintenance, analytics, fraud detection, and development), such as Firebase (Auth, database, storage, and notifications), Google Cloud, and OVH.

These providers are subject to strict confidentiality commitments and may only use personal information to provide their services to Propulsion. Where required by Law 25, personal information is hosted and stored on Canadian soil.

Please note that these third parties may be located outside your country, province, or territory of residence. We have contractual arrangements with these third parties to ensure that your personal information is processed in accordance with applicable laws. Where required, we conduct privacy impact assessments before transferring personal information to another jurisdiction.

With authorities or persons authorized by law

We may share your personal information if required by law or if we believe in good faith that such action is necessary to comply with the law, a court order, or a legal proceeding; protect and defend the rights or property of Propulsion; enforce your compliance with agreements; prevent fraud or other illegal activity; or act in urgent circumstances to protect the personal safety of users or the public.

With potential buyers of our business

We may be required to share your personal information without your consent in the event of a merger, acquisition, or sale of all or part of the business, for example during due diligence. In such cases, we limit the sharing to what is necessary to assess the feasibility or relevance of the transaction.

We retain personal information for as long as necessary for the intended purposes, for up to seven years where accounting or legal requirements apply, or until the account is deleted.

Social content may be manually deleted by the user.

You may request the deletion of your account at any time by sending an email request to support@propulsionsport.com.

We implement technical, administrative, and physical safeguards to protect your personal information from loss, unauthorized access, disclosure, alteration, misuse, or destruction. These safeguards vary depending on the sensitivity of the data in our possession and are based on industry best practices. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

Your personal information is hosted by our service providers, who commit to using reasonable security measures to preserve the integrity and confidentiality of your personal information. We apply technical and organizational measures consistent with industry standards: encryption, restricted access, monitoring.

To protect your security, we use the most robust browser encryption available and store all our data on servers in secure facilities.

Our employees and providers are informed of the confidential nature of the personal information collected and are trained in appropriate security measures.

If you have questions about the security of your interactions with us, you may contact us at support@propulsionsport.com.

Children

We do not knowingly collect or use personal information from children under the age of 14. If we learn that we have collected personal information from a child under 14, it will be deleted as soon as possible. If a child under 14 has provided us with personal information, their parent or guardian may contact our Privacy Officer.

Depending on applicable laws, your place of residence, and how you interact with the Services, you may be granted certain rights regarding the personal information we hold about you. You may have the right to:

• access your personal information and correct it if it is inaccurate or incomplete;
• request the deletion of your personal information;
• obtain additional information, for example about categories of third parties with whom we share your personal information;
• object to processing carried out based on our legitimate interests and request that we restrict such processing;
• request the portability of your personal information in a structured, commonly used, and machine-readable format;
• refuse to receive marketing communications from Propulsion;
• withdraw your consent at any time. Withdrawal will not affect the legality of processing carried out before withdrawal;
• file a complaint with a supervisory authority, such as a privacy commissioner or the Commission d'accès à l'information.

How to exercise your rights

You may review, correct, update, modify, or delete the personal information you have provided us by using your account.

You may also exercise the rights listed above by submitting a written request to our Privacy Officer. For your protection, we will only process requests originating from the same email address you use to log into your account. We may also need to verify your identity. We strive to respond promptly, usually within 30 days.

In the context of the processing activities covered by this Policy, Propulsion does not make decisions based solely on automated processing producing legal effects or similarly significant effects.

Submitting a complaint

You may file a complaint with Propulsion's Privacy Officer if you are dissatisfied with our handling of your personal information or with our compliance with this Policy. You are also entitled by law to file a complaint with a privacy commissioner or any other competent supervisory authority.

Your choices regarding use and disclosure

Only the information you provide when using our Site may be used by Propulsion for marketing purposes. No information collected by the Propulsion mobile application is used for marketing or advertising purposes.

You may unsubscribe from our electronic marketing communications at any time; disable the collection of approximate location data inferred from your IP address in your device or browser settings; and disable non-essential cookies according to the procedure outlined in the "Cookies" section.

The Propulsion mobile application collects no location data.

A cookie is a small text file stored in a designated location on your computer, mobile device, tablet, or any other device when you use your browser to visit an online service. This Policy includes within the term "cookie" other tracking technologies, including web beacons and tracking pixels. All personal information we collect using cookies is processed with the same level of confidentiality as all other personal information we hold.

Essential cookies

These cookies are necessary for the operation of the Site and provide basic functions, including maintaining your session and preventing security threats. We cannot disable them without affecting the functioning of the Site. You may block or delete them by modifying your browser settings.

Non-essential cookies

Non-essential cookies provide certain features for functional, analytical, or advertising purposes. We will ask for your consent before using them.

• Functional cookies: they support non-essential features of our Site, such as embedding videos or enabling content sharing on social media.
• Advertising cookies: they help us track the effectiveness of our advertising campaigns and personalize our ads.
• Analytical cookies: they store information such as the number of visitors or the pages they visited, and help us analyze the performance of our Site.

Managing cookies

You may manage and disable cookies through your browser's settings and your device's advertising settings. If you refuse cookies, you may not be able to use all features of the Site.

Online advertising

On our Site, we may collect your personal information to present you with advertisements and may work with online advertising companies. Advertisements are displayed only on our website, never within the Propulsion application.

We may also use your mobile advertising identifier to measure the effectiveness of advertising campaigns: "IDFA" on iOS, "AAID" on Android. These identifiers are used solely to measure the effectiveness of our external marketing campaigns. You may reset the IDFA or AAID or limit their use in your device settings.

Social media features

Our Site includes social media features such as LinkedIn, Facebook, or Instagram share buttons. If you use these features, they collect your IP address, the page you visit, and create a cookie to enable these features to function properly.

This Policy may be amended from time to time to maintain compliance with applicable laws and to reflect any changes to our data collection processes. When we make significant changes to this Policy, we will notify you by sending a notice either on our Site or by email. In all other circumstances, posting a new version of the Policy on our Site or your continued use of the Services will constitute sufficient notice and acceptance of the changes.

For any questions related to a technical issue with our Services, we invite you to contact us at support@propulsionsport.com.