COGNITO COACH™

Confidentiality and privacy policy

1. PROTECTION OF YOUR PERSONAL INFORMATION

This Privacy and Confidentiality Policy (the "Policy") explains the types of

personal information that are collected in the course of providing the

service (as defined in the Terms of Use and Non-Exclusive License for the

service, which can be consulted by clicking on the following hyperlink

https://www.cognitocoach.com/legal/utilisation.pdf (the "Terms of Use"))

by Dipôle Solutions inc. ("Cognito Coach™", "Cognito™", "Cognito-

app™") in favor of the client, the use of these and the contexts of

disclosure. Cognito Coach™ understands the importance of protecting

the personal information of its clients and is committed to respecting

their right to privacy. For the purposes of this Privacy Policy, the term

"customer" refers to you, as an individual, or to the legal entity receiving

the service, its subsidiaries and other affiliates. If you do not have the

authority to do so, or if you do not agree with the provisions of this policy,

please do not use the service.

Please note that Cognito Coach™ may change this policy at its sole

discretion and without notice. It is your responsibility to review the terms

of the Policy for changes from time to time. The collection, use and

disclosure of your personal information will be subject to the version of

the Policy then in effect, which is the version posted on the Cognito

Coach™ customer interface and available through the use of the Service

on any given date.

This Policy is an integral part of the Terms of Use.

2. DEFINITION OF PERSONAL INFORMATION

Personal information is any factual or subjective information about an

identifiable individual. However, Personal Information does not include

business contact information, if such contact information is used to

communicate with an individual in connection with his or her

employment, occupation or profession.

3. CONSENT

Subject to certain exceptions, Cognito Coach™ shall obtain the consent

of the client for the collection, use and disclosure of Personal

Information. Consent may be express or implied. Consent must also be

meaningful, that is, the client must understand the nature, purpose and

impact of the collection, use or disclosure of personal information to

which they are consenting. Consent may be provided orally, in writing,

electronically, or by a person acting on behalf of the customer, such as

an agent or attorney duly authorized for that purpose. Express consent

is generally given when the client completes and signs an application or

enrollment form and submits it to Cognito Coach™. Implied consent

occurs when Cognito Coach™ can reasonably infer that the client has

consented, as a result of action or inaction on the part of the client, or

because of the circumstances.

Please be advised that your use of the Service confirms that you are at

least the age of majority in your place of residence.

4. COLLECTION OF INFORMATION

Cognito Coach™ limits the collection of personal information to that

which is necessary for the stated purposes. Any collection of personal

information of the customer made in the context of the payment of the

subscription fee to the service through the online payment platform

used by Cognito Coach™ will be subject to the terms of confidentiality

and protection of personal information applicable to the use of this

payment platform. It is not safe to transmit your payment data, including

your credit card number, by email, SMS or through social media. In order

to protect this data, please only transmit it through the online payment

platform used by Cognito Coach™.

5. USE OF INFORMATION

5.1 Essentially, the personal information collected allows Cognito

Coach™ to identify the client, to communicate with him and to

personalize its service. Cognito Coach™ reserves the right to use the

personal information obtained to conduct market research in order to

adequately meet the needs of its customers and thus improve its service.

5.2 If you have consented to have your email address added to Cognito

Coach™ mailing list, you may, at any time, choose to no longer receive

marketing communications or the newsletter sent by email by

unsubscribing using the hyperlink included in these communications.

5.3 Cognito Coach™ does not sell personal information about its clients

to third parties and does not use or disclose such personal information

for purposes other than those for which it is collected.

5.4 Applicable laws and regulations provide for certain exceptions to this

Policy and the use of your personal information. These exceptions may

affect privacy practices. For example, Cognito Coach™ may collect, use

or disclose the personal information of its clients in the following

situations:

(a) if the collection of information is clearly for your benefit and your

consent cannot be obtained in a timely manner;

(b) if the information is deemed by law to be in the public domain

money laundering and anti-terrorist financing laws; or

(d) in connection with tax returns to the appropriate authorities or other

disclosures required by law.

6. THIRD PARTY SERVICES

6.1 When used herein, the term "Third Party Services" means computer

programs, websites, of a third party to which you voluntarily grant access

in connection with the use of Cognito Coach™. Your use of the Third

Party Service is subject to the policies of the Third Party Service. We

advise you to read the terms and conditions of the policies of the third

party sites you use.

6.2 Cognito Coach™ use of information received through APIs from third

party services (Google, Microsoft, Apple, Stripe, PayPal, Zapier...) will

comply with the user data policy of the API services, including the limited

use requirements determined by them.

6.3 Google: When you click on "Authorize Google", you will be

automatically redirected to the Google OAuth API page, via an SSL

(Secured Socket Layer) connection. Cognito Coach™ will ask you for

specific access permissions to allow us to connect to your Google

calendar. Once these permissions are obtained, we must save the

authorization token in order to continue accessing your calendar, in

order to continuously synchronize with our users' COGNITO subscription.

This server is encrypted and secure. Our goal is to allow you to view all

your calendars in a centralized view.

We then use this information in the following two ways:

a) the agendas selected to be displayed in the Cognito Coach™ calendar

will allow you to consult, without the possibility of modification, the

summary of these events;

b) the destination calendar for Cognito Coach™ activities will allow

Cognito Coach™ activities to be synchronized with events in this

calendar. These events can be added/modified/deleted, depending on

the actions taken on the associated Cognito Coach™ activities in

Cognito Coach™. You can log out of your Google account at any time.

7. PROTECTION OF INFORMATION

Cognito Coach™ employs physical, organizational and technological

security measures to protect customer personal information from

unauthorized access, disclosure, copying, use or modification, as well as

from loss or theft. Cognito Coach™ uses the Secure Sockets Layer (SSL)

protocol on all pages where personal data is collected. This protocol

encrypts information before it is sent to Cognito Coach™. Cognito

Coach™ computer systems, including those of its subcontractors and

hosting partners from whom Cognito Coach™ obtains hardware,

software, networks, storage space and related technology to operate

and maintain the Service, are password-protected and are configured so

that only those individuals who need access to your personal information

for the purposes of their position with Cognito Coach™ are authorized to

access the secure systems and databases.

8. COOKIES, SOCIAL MEDIA AND BLOGGING

8.1 In order to ensure proper management of the service, Cognito

Coach™ collects the usual data from Internet log files, including your IP

address, browser type and language, access frequency and website

referral addresses, including through the use of various types of cookies

and conversion tags. Cognito Coach™ does not profile your computer or

extract any information from your hard drive. Most browsers are

configured by default to accept cookies, but you can change your

browser settings to refuse or limit their use.

8.2 In addition, the Service includes certain social media features. These

features may, among other things, collect your IP address and leave a

cookie to enable the feature. The social media features and widgets are

hosted by a third party. Your interactions with these features are

governed by the privacy and confidentiality policy of the company that

provides them.

8.4 Cognito Coach™ does not endorse the opinions expressed in the

comments posted by users of its blog and does not verify the accuracy

of such comments. Cognito Coach™ reserves the right to modify or

delete any disrespectful, offensive, abusive or discriminatory message,

question, or comment at its discretion.

9. ACCESS TO INFORMATION AND QUESTIONS

In accordance with the provisions of the law, you have the right to access,

rectify, modify, or delete personal information held by Cognito Coach™.

To do so, or if you have any questions or concerns about the protection

of your personal information, please contact Cognito Coach™' customer

service department by e-mail at the following address:

support@cognitocoach.com.

10. VERSIONS

In the event of a discrepancy between the English and French versions

of this Policy, the French version shall prevail.

Translated from the original language, French.