PRIVACY POLICY OF

PLATFORM SOLIDMIND

Last updated on April 20th, 2026.

Capitalized terms are defined in the Solidmind Terms of Use ("Solidmind" or "we"). Please read them carefully in conjunction with this Policy.

To help you navigate this document, here is the table of contents for Solidmind’s privacy policy (the "Policy"). You can access any relevant section by clicking on it:

  1. SCOPE OF THE POLICY
  2. PERSONAL INFORMATION PROTECTION OFFICER
  3. ROLES AND RESPONSIBILITIES OF SOLIDMIND STAFF
  4. DEFINITION OF "PERSONAL INFORMATION"
  5. WHAT PERSONAL INFORMATION DO WE COLLECT?
  6. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
  7. FROM WHOM DO WE COLLECT YOUR PERSONAL INFORMATION?
  8. HOW DO WE USE COOKIES?
  9. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
  10. [OTHER PURPOSES].
  11. WHAT HAPPENS IF YOU DO NOT CONSENT TO THE COLLECTION OF YOUR PERSONAL INFORMATION?
  12. WHO, OTHER THAN SOLIDMIND, MAY HAVE ACCESS TO YOUR PERSONAL INFORMATION AND HOW DO WE SHARE IT?
  13. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
  14. IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE QUEBEC?
  15. HOW DO WE PROTECT AND STORE YOUR PERSONAL INFORMATION?
  16. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
  17. WHAT TO DO IF THE POLICY IS AVAILABLE IN MULTIPLE LANGUAGES?
  18. MODIFICATION OF THIS POLICY
  19. WHO SHOULD I CONTACT IF I HAVE QUESTIONS ABOUT THE PROTECTION OF MY PERSONAL INFORMATION?

SCOPE OF THE POLICY

a. Objectives of this Policy

Given the challenges associated with protecting the security of Personal Information (as defined below) in the digital environment, it is necessary to pay particular attention to privacy protection. That is why, at Solidmind, we take the protection of your Personal Information seriously and are committed to respecting the confidentiality of the information we collect.

Solidmind undertakes to comply, in accordance with this Policy and applicable federal and provincial laws in force in the province of Quebec, with the obligations relating to the collection and processing of your Personal and Confidential Information obtained in the course of its business operations, so that everyone can benefit from and safeguard their privacy.

In doing so, Solidmind wishes to ensure the accuracy, security, and confidentiality of your Personal Information, and will not collect, use, or disclose your Personal Information except in accordance with this Policy and applicable laws.

We collect your Personal Information as part of our Services designed to support Canadian electricians in their daily practice, including by providing them with reference tools, calculators, and a virtual assistant via our Application. We may also collect your Personal Information in order to suggest or provide you with recommendations, services, and/or additional products tailored to your needs and reflecting the above-mentioned mission, subject to your prior consent.

This Policy complies with privacy laws regarding the protection of personal information in the province of Quebec, including Canada's Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5), the Quebec Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1), and the Act to modernize legislative provisions as regards the protection of personal information (Bill 25) (the "Privacy Laws").

b. Application of this Policy

By browsing the Platform or subscribing to our email publications, you, as a user (the "User" or "you"), agree to the terms and conditions of the Policy.

CONSENT: By using our Services and the Platform, you, as a User, consent to the collection, use, and disclosure of your Personal Information in accordance with this Policy for the following purposes, which are determined, explicit, and legitimate:

The provision of the Services;

The management of Solidmind’s activities;

Authorized communications;

Sharing with Third-Party Providers (defined in section 1 c) below) necessary for the provision of the Services;

Other uses specifically described in this Policy.

You agree that your Personal Information collected when creating your Account on the Web Application, using the Web Application, submitting information, and/or requesting to be contacted, may be transmitted to the competent and authorized personnel of Solidmind and, where applicable, to its Third-Party Service Providers (defined in section 1 c) below) in accordance with this Policy.

By using our Services, you acknowledge that you have read this Policy. Your express, free, and informed consent will be obtained prior to the collection of your Personal Information, except in cases where the law allows collection without consent, in particular when collection is necessary for the conclusion or performance of a contract to which you are a party, or when it is clearly in your interest and it is impossible or disproportionate to obtain your consent. Any additional notices will be provided to you and your consent will be required where applicable.

We only collect Personal Information that is reasonably necessary for the provision and management of our Services and operations. We collect your Personal Information in various ways. For example, we collect it directly from you, or when you visit our Platform.

The Policy applies to you in all situations where you interact with Solidmind and where we collect Personal Information about you, including when you visit our Platform, use our Services, or communicate with us by any means, including social media.

The Policy describes the Personal Information that Solidmind may collect from its Users in the course of its activities.

The Policy also describes, among other things, how Solidmind processes, stores, and/or destroys your Personal Information, the purposes for which it is collected, how it is used, and the circumstances under which it may be disclosed to third parties. The Policy details your rights regarding the collection, transfer, use, retention, and disclosure of your Personal Information.

In addition, the Policy describes the procedures by which you can access, update, or correct your Personal Information, as well as the options available to you regarding the protection of your Personal Information.

c. Third-Party Service Providers

Solidmind maintains and updates an internal register listing all of its suppliers and subcontractors, including, but not limited to, Vercel, Supabase, Upstash, Stripe, Sentry, Tavily, Resend, and Google Cloud (AI). This register is continuously updated to accurately reflect any changes relating to suppliers and subcontractors involved in the provision of Services or the processing of data on behalf of Solidmind. Solidmind will only disclose to third parties whose participation is strictly necessary for the provision of the Services and/or the maintenance of our business relationship with you, as the case may be, the information necessary for these purposes (the aforementioned third parties are hereinafter collectively referred to as "Third-Party Service Providers").

In some cases, at the time of collecting your Personal Information, we may provide you with additional information regarding the processing of your Personal Information. We may also, in some cases, obtain specific consent from you regarding the use or disclosure of your Personal Information.

By providing Solidmind with your Personal Information, you authorize Solidmind to use and disclose your Personal Information to third-party Service Providers, where applicable, in connection with the provision of the Services, the management of our contractual relationships, our business relationships with you, and in accordance with this Policy and as authorized or required by law, as well as implicitly, if circumstances permit.

d. Additional Consents and Withdrawal

Solidmind will ask for your consent before using your Personal Information for purposes other than those covered by your initial consent under the Policy.

In addition, you may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Please note, however, that without your consent, Solidmind may not be able to provide or continue to provide you with certain Services or information that may be useful to you.

If you provide Solidmind or its Third-Party Providers with Personal Information about another individual or entity, you acknowledge that you have the necessary authorization to do so and/or that you have obtained all necessary consents from that third party to allow us to collect, use, and disclose their Personal Information for the purposes set out in this Policy.

YOU ACKNOWLEDGE AND AGREE, WITHOUT RESERVATION, THAT YOU ARE SOLELY AND ENTIRELY RESPONSIBLE FOR COMPLIANCE WITH THE PROVISIONS OF THIS SECTION, AND THAT SOLIDMIND CAN IN NO WAY BE HELD RESPONSIBLE FOR YOUR FAILURE TO OBTAIN PRIOR AUTHORIZATION AND/OR CONSENT FROM SAID THIRD PARTY.

To withdraw your consent or stop receiving our communications, please contact the Personal Information Protection Officer at the contact details provided in Section 2 of this Policy.

PERSONAL INFORMATION PROTECTION OFFICER

Please feel free to contact Solidmind's Personal Information Protection Officer (the "Personal Information Protection Officer") with any questions, comments, or concerns regarding the Policy, how we process your Personal Information, or to exercise your rights with respect to your Personal Information.

Contact: By email: info@ solidmind.ca ; or

By mail: 204-290, rue de Regina, Montréal, Québec, Canada.

The terms and conditions for processing your requests, including applicable deadlines, are detailed in Section 17 h) of this Policy.

ROLES AND RESPONSIBILITIES OF SOLIDMIND STAFF

At Solidmind, we have assigned the following roles and responsibilities:

The Personal Information Protection Officer is responsible for:

implementing policies and procedures relating to the protection of privacy and Personal Information within Solidmind;

maintaining and updating an internal register listing all suppliers and subcontractors involved in the provision of Services or the processing of data on behalf of Solidmind;

training our staff on policies and obligations relating to the protection of Personal Information;

keeping a register of incidents relating to the confidentiality of Personal Information;

assess the possible consequences of an incident related to the protection of Personal Information;

notify the Commission d'accès à l'information du Québec and, where applicable, the individuals concerned, without delay in the event of a confidentiality incident presenting a risk of serious harm; and

participate in the detection of confidentiality risks and notify the persons responsible in the event of a confidentiality incident.

The operations manager is responsible for:

ensuring that all employees have signed a confidentiality agreement and that it is stored on the server;

ensuring that the access rights of Solidmind employees (the "Employees") to the server are controlled;

ensuring that all Third-Party Service Providers have a Personal Information Protection Policy that complies with Privacy Laws, that they comply with it, and that written agreements that comply with these laws are in place before any Personal Information is disclosed; and

help identify privacy risks and notify the appropriate individuals in the event of a privacy incident.

Administrative staff are responsible for:

collecting Personal Information from Users;

obtaining free, informed, specific, and purpose-specific consent for the collection, use, and disclosure of Users' Personal Information, in accordance with the provisions of the Privacy Laws;

sign and comply with their confidentiality agreement; and

participate in identifying risks of confidentiality breaches and notify the responsible persons in the event of a confidentiality incident.

Solidmind trains and educates its Employees in the following ways, among others:

explaining the provisions of their confidentiality agreement upon hiring and reminding them annually;

periodically reminding Employees of confidentiality requirements during annual meetings; or

raising awareness about reporting confidentiality-related incidents.

DEFINITION OF "PERSONAL INFORMATION"

"Personal Information" means any information that relates to an individual and allows that individual to be identified directly or indirectly. Information that has been irreversibly depersonalized, such that it is reasonably impossible to directly or indirectly identify the individual concerned, does not constitute Personal Information within the meaning of the law. For example, a person's office mailing address is not Personal Information in itself, unless it is mentioned in conjunction with other information about the person, or if its mere mention reveals Personal Information about the person.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Solidmind collects the following Personal Information from the User for the purposes described in Section 9 of this Policy:

Information about their identity and contact details, such as their name, email address, and the Canadian province or territory where the User provides electrical services, the type of services offered (Residential, Commercial, Institutional, Industrial, Service / Maintenance, Renewable Energy / EV, Agricultural / Farm, Telecom / Low Voltage, Engineering / Design), and their level of experience (apprentice, journeyperson, or master);

Information about the specific Services you have purchased from Solidmind;

Solidmind does not collect any sensitive Personal Information, including health data, financial data, or any other protected information.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Solidmind may collect Personal Information from the User in the following ways:

When you create an Account on the Web Application and choose a password;

When you access and/or use the Platform;

When you contact us by phone, email, or any other means of communication.

FROM WHOM DO WE COLLECT YOUR PERSONAL INFORMATION?

We generally collect Personal Information from the following individuals:

a. From you or an authorized representative

The Web Application is designed to be used by individuals who have reached the age of majority under Quebec law. Solidmind does not knowingly collect Personal Information from minors without the consent of their legal guardian.

The User may provide us with Personal Information directly, for example by email or telephone call.

In certain cases, particularly when the User is under a protective regime within the meaning of the Civil Code of Québec, Personal Information may be provided to us by the guardian, curator, or agent designated under a protection mandate for the User, as applicable.

We collect your Personal Information when you create an Account on the Web Application to access the Services or when you update your Personal Information.

We collect your Personal Information when you contact us.

b. Other sources

We may receive Personal Information about you from other sources. In such cases, we will only do so with your prior and explicit consent, or if expressly required or permitted by law.

When we access certain information about you that is publicly available.

We may also access your Personal Information, with your prior explicit consent, through referral, affiliate, or recommendation programs, or through publicly available sources, including events, trade shows, and social media.

c. From the Platform

Henri Virtual Assistant

The Henri virtual assistant, as described in more detail in the Terms of Use, does not collect or store any protected Personal Information during exchanges, other than the chat history itself which is saved for your convenience. The information communicated during the chat does not constitute data that can be shared or used for purposes other than generating real-time responses. Conversations are securely stored in your Account so you can access your calculation history. They are deleted when you manually clear them using the function provided in the Web Application, or upon Account deletion.

Cookies

Cookies are files created by a website to record information relating to a device's browsing activity on the website. They enable certain information to be collected during exchanges between a device and a server. In accordance with Privacy Laws, we distinguish between cookies that are strictly necessary for the functioning of the site and non-essential cookies that require your prior, free, informed, specific consent for specific purposes.

We use the information collected in this way to tailor the Website to your preferences, to compile statistics on your browsing and use of our Website and our electronic communications, in order to improve them.

The information collected through Cookies is mainly as follows:

IP address and location;

User analysis, performance, and behavior;

Browser and/or OS type; and

User language(s).

Most cookies do not reveal your identity. They are collected solely due to the technological requirements inherent to browsing the Internet. Most browsers automatically accept Cookies, but it is usually possible to change this behavior. Before obtaining your consent, we will clearly inform you of the consequences of refusing non-essential Cookies on your User experience. If you choose to refuse non-essential Cookies, you will still be able to access the basic features of the Website.

Using this information allows us to improve the Services, personalize your experience, and better track your past usage.

In addition to the methods described above, we may also collect information using Cookies or similar technologies, including when you visit our Website. These methods allow us to collect various types of information, including the pages you visit and your interactions with the Web Application.

This information is also used to:

Identify the User;

Understand how the Website is used by Users without specifically tracking you;

Keep in touch with the User and provide them with personalized service at all times;

Develop new services and offers;

Conduct market and performance studies to evaluate customer service, measure performance, improve the User experience, and the products offered; and

To better support Users and respond to their requests, or those submitted by third-party Partners.

HOW DO WE USE COOKIES?

We use technologies such as Cookies or Pixels to perform various functions on our Website. The Website only uses essential Cookies, which are necessary for its operation, as well as analytical Cookies that are configured to remain completely anonymous. No marketing Cookies are used.

Subject to your prior consent, non-essential cookies may be stored on your electronic devices, allowing Solidmind to customize the Website to provide you with the most appropriate features. Cookies that are strictly necessary for the technical functioning of the Website, in particular for security and basic navigation, are automatically enabled.

The cookies we use include, but are not limited to, the following:

Cookies, which are small text files stored on your computer when you visit a website, so that certain information can be saved between visits, such as your login details or language choice; and

Pixels, which are small image files containing information about you, such as your IP address, that may be downloaded when you visit a website or open an email. This allows us to understand your online behavior and control the sending of our transactional and service-related emails. These tools also allow our third-party tracking tools to collect information, such as your IP address. Some information may be sent to us in the form of anonymous aggregate data that does not directly identify you.

Our infrastructure (such as Vercel and Supabase) securely uses essential cookies and similar technologies to ensure Website functionality, authentication, and localization. This information is not transmitted to us in a form that directly identifies you. We do not use the Google Analytics service or any marketing cookies. However, it is possible that an internal analytics service within the Web Application, configured to remain completely anonymous, may be added at a later date to monitor application performance.

There are several types of Cookies, some of which expire when the User closes their browser and no longer have any effect, while others may be stored. The User may disable non-essential Cookies at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal. Only Cookies strictly necessary for the functioning of the Website are required, the others being optional and requiring your explicit consent.

You can also prevent Cookies from being stored by configuring your Internet browser. However, if you choose this option, you may not be able to take full advantage of the Website.

WHY DO WE COLLECT YOUR PERSONAL INFORMATION?

We use your Personal Information to provide you with our Services, to manage our business, to communicate service-related information to you, to improve your overall customer experience, and for other purposes permitted or required by Privacy Laws.

More specifically, we use your Personal Information for the following purposes:

a. To provide you with our Services

User information is collected as part of the interaction that may occur between the User and the Platform, specifically for the following purposes:

Verify the User's identity on the Web Application;

To provide Services to the User on the Web Application;

To understand the User's use of the Platform;

To improve the Platform, its features, and the Services offered by the Web Application;

Determine whether our products and Services are suitable for you; and

[OTHER PURPOSES].

In addition, Personal Information collected by Solidmind in connection herewith is accessible only to authorized and competent employees, as defined by Solidmind, and only to the extent necessary for the performance of their duties.

By using Solidmind 's Services, I, as a User, consent to the use of my Personal Information to enable Solidmind to provide me with its Services. I understand that I may withdraw my consent at any time by contacting Solidmind, subject to legal and contractual restrictions, and that such withdrawal may limit or prevent access to the Services. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

b. Managing our activities

We use your Personal Information for several purposes in connection with our business and operations, in particular to:

Manage and/or improve the Platform and facilitate its use;

Monitor and investigate incidents; and

Comply with our legal and regulatory obligations under Privacy Laws.

AS A USER, I CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ENABLE SOLIDMIND TO MANAGE ITS BUSINESS, AND I UNDERSTAND THAT I MAY WITHDRAW MY CONSENT AT ANY TIME BY CONTACTING SOLIDMIND, SUBJECT TO LEGAL AND CONTRACTUAL RESTRICTIONS.

c. To enable us to communicate with you

We use your Personal Information to communicate with you in various ways:

Send transactional and service-related communications.

If you need to manage your communication preferences for service-related updates, you can contact us directly.

I, AS A USER, CONSENT TO THE USE OF MY PERSONAL INFORMATION TO ALLOW SOLIDMIND TO CONTACT ME FOR SERVICE-RELATED COMMUNICATIONS, AND I UNDERSTAND THAT I MAY WITHDRAW MY CONSENT AT ANY TIME BY CONTACTING SOLIDMIND, SUBJECT TO THE FACT THAT CERTAIN COMMUNICATIONS ARE NECESSARY FOR THE PROVISION OF THE SERVICES.

You may refuse the collection of your Personal Information at any time.

Please note, however, that, with the exception of Cookies, which are not necessary for the provision of the Services, we will not be able to provide the Services offered without access to your Personal Information. Refusal to provide certain Personal Information may limit or prevent access to certain features of the Platform.

WHO, OTHER THAN SOLIDMIND, MAY HAVE ACCESS TO YOUR PERSONAL INFORMATION AND HOW DO WE SHARE IT?

Solidmind staff and, with your prior express consent, written or clearly expressed by any other means, our Third-Party Service Providers, may have access to your Personal Information when necessary for the provision of the Services or to comply with our legal obligations.

We may disclose your Personal Information to our Third-Party Service Providers and other third parties—with your prior consent or where permitted or required by Privacy Laws—for the purposes described in this Policy and in accordance with Privacy Laws. We do not sell your Personal Information, except in connection with the sale or transfer of part of our business, in which case you will be notified in advance and given the opportunity to withdraw your consent.

We do not disclose your Personal Information to persons or entities outside of Solidmind, except in the cases described below:

Third-party service providers whose involvement is necessary to provide you with the Services

We may disclose Personal Information to our Third-Party Service Providers. These Third-Party Service Providers help us provide our Services, conduct our business, operate our technology systems, applications, and infrastructure, and implement our internal procedures and advertising and marketing strategy. We may also subcontract certain Services that we provide to our customers, including to the User, to Third-Party Service Providers, in particular for the following features and Services:

An internal privacy impact assessment (PIA) has been conducted for all data transfers outside Quebec. This analysis, kept on file at Solidmind, aims to ensure that reasonable measures are in place to provide a level of protection comparable to that provided by applicable laws in Quebec.

BY USING SOLIDMIND'S SERVICES, I, AS A USER, CONSENT TO MY PERSONAL INFORMATION BEING TRANSFERRED THROUGH THE SYSTEMS OF THIRD-PARTY SERVICE PROVIDERS THAT ENABLE SOLIDMIND TO PROVIDE ITS SERVICES, IT BEING UNDERSTOOD THAT SOLIDMIND ENSURES THAT THESE THIRD-PARTY SERVICE PROVIDERS OFFER SUFFICIENT GUARANTEES REGARDING THE IMPLEMENTATION OF APPROPRIATE SECURITY MEASURES IN ACCORDANCE WITH PRIVACY LAWS.

b. Acquirer of Solidmind in the event of a sale or transfer or in connection with certain other corporate transactions

We may decide to sell or transfer all or part of our business to a third-party purchaser, merge with another entity, secure our assets, or engage in any other strategic corporate financing or transaction (including insolvency or bankruptcy proceedings), restructuring, sale of shares, or other change of control of Solidmind. In such a case, the information transferred as an asset of Solidmind will be subject to the same safeguards as those in this Policy.

You will be notified in advance and will have the opportunity to withdraw your consent to the transfer of Personal Information.

I, AS A USER, CONSENT TO THE DISCLOSURE OF MY PERSONAL INFORMATION WHEN NECESSARY FOR THE PURPOSES OF SUCH A TRANSACTION.

c. Other third parties, when required or permitted by applicable laws

Privacy Laws permit or require the collection, use, or disclosure of Personal Information without consent in limited circumstances (for example, to investigate or prevent suspected or actual illegal activity, including fraud, or to assist law enforcement authorities or government agencies). These circumstances include specific situations authorized or required by law, as well as situations where it is necessary to do so to protect ourselves, our staff, our customers, or others. In such circumstances, we will only disclose the amount of Personal Information reasonably necessary to achieve the purposes for which it is to be disclosed.

Please note that under applicable federal and provincial laws in the province of Quebec, Solidmind may be required to disclose your Personal Information to authorized persons, including in the following cases:

We may disclose Personal Information we hold to protect an individual or group of individuals when there is reasonable cause to believe that there is a serious risk of death or serious physical harm to the individual or group, such as a disappearance or act of violence, including attempted suicide, and the nature of the threat inspires a sense of urgency. Personal Information may then be disclosed to the person or persons at risk, their representative, or any person who may be able to assist them. Only Personal Information necessary for the purpose of the disclosure will be disclosed; and

We may also disclose Personal Information to the Director of Criminal and Penal Prosecutions or to a person or group responsible for the prevention, detection, or prosecution of crime or legal offenses when such Personal Information is necessary for the purposes of prosecuting an offense under a law applicable in Quebec.

I ACKNOWLEDGE AND UNDERSTAND, AS A USER, THAT MY PERSONAL INFORMATION MAY BE DISCLOSED TO AUTHORIZED THIRD PARTIES WHEN REQUIRED OR PERMITTED BY APPLICABLE LAW, WITHOUT MY CONSENT BEING NECESSARY IN THESE CIRCUMSTANCES PROVIDED FOR BY LAW.

d. Other third parties, with your consent

Unless otherwise specified in this Policy, Personal Information provided by the User will not be transferred to third parties without the User's consent. We may, with your explicit consent (and in certain limited cases, your implied consent where permitted by law), and in compliance with Privacy Laws, communicate or disclose your Personal Information to persons or entities outside of Solidmind, including the following:

Specific third parties, only with your explicit consent and for specific purposes that will have been communicated to you in advance.

We do not allow third parties to collect your Personal Information on our Platform without your consent. Solidmind prohibits the resale or use by third parties of opt-ins obtained through the Platform. If you have given your explicit consent to share your contact details with specific partner organizations and for specific purposes, we will share them with them in accordance with that consent. We do not sell or rent your Personal Information without your consent.

Solidmind may, subject to obtaining your prior consent, republish on its social media channels professional examples or testimonials provided by you, in full compliance with your privacy rights and in accordance with Privacy Laws.

By clicking on an external link on the Platform, you may access External Websites that have their own privacy policies. We therefore advise you to consult them, as you will be subject to them.

I UNDERSTAND, AS A USER, THAT MY EXPLICIT CONSENT (OR IN CERTAIN LIMITED CASES PROVIDED FOR BY LAW, MY IMPLIED CONSENT) ALLOWS SOLIDMIND TO DISCLOSE MY PERSONAL INFORMATION TO AUTHORIZED THIRD PARTIES, AND THAT I MAY WITHDRAW THIS CONSENT AT ANY TIME, SUBJECT TO LEGAL OR CONTRACTUAL RESTRICTIONS, BY CONTACTING THE PERSONAL INFORMATION PROTECTION OFFICER.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We store your Personal Information on our secure computer servers. Unless otherwise required by Privacy Laws, we only retain Personal Information for as long as necessary to fulfill the purposes for which it was collected. The length of time may vary depending on the nature of the Personal Information.

The User's Personal Information will not be retained beyond the purposes for which it was collected. Solidmind complies with retention periods in accordance with Privacy Laws.

The User may request the portability of their Personal Information. This portability is provided manually, in a structured, commonly used, and machine-readable format, within a reasonable time after receipt of the request.

Personal Information is permanently and immediately deleted from our active databases when the User deletes their account. We do not retain your Personal Information after account closure, subject to any applicable legal and regulatory retention obligations.

IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE QUEBEC?

Some of your Personal Information may be transferred outside Quebec. To ensure compliance, we conduct an internal privacy impact assessment (PIA) for our technology providers. This is a one-time assessment performed at the infrastructure level, not for each individual User. The servers of third-party service providers whose involvement is necessary to provide our Services are located in Canada and the United States. We have assessed that these jurisdictions offer an adequate level of protection for Personal Information, and we have implemented appropriate contractual and technical measures to ensure the protection of your Personal Information when it is transferred and processed in these jurisdictions.

Prior to deploying our infrastructure outside of Quebec, Solidmind conducted an internal assessment of the privacy factors specific to these providers in order to identify such factors, apply legislative and regulatory requirements, and provide recommendations to mitigate risks, in accordance with Privacy Laws. Solidmind ensures that the protective measures in place are adequate to protect the Personal Information transferred. More specifically, Solidmind undertakes not to share your Personal Information with third parties located in jurisdictions that do not offer a level of protection of Personal Information equal to or greater than that of Quebec.

HOW DO WE PROTECT AND STORE YOUR PERSONAL INFORMATION?

a. General Commitment

Solidmind is committed to maintaining a high level of security to protect your Personal Information from unauthorized access, use, or disclosure, loss, or theft. We only retain your Personal Information for as long as necessary to provide you with our Services and comply with our legal obligations.

b. Security measures in place

We have adopted appropriate administrative, physical, and technical safeguards, including:

Technical measures:

SSL/TLS (Secure Sockets Layers/Transport Layer Security) protocol for encrypting data in transit;

Encryption of data at rest;

Protected access to servers and computers;

Encrypted and secure electronic communications.

Administrative measures:

Internal policies on personal information protection;

Internal privacy awareness and protocols;

Access rights control (access limited to authorized personnel and contractors only);

Confidentiality agreements signed by all employees and contractors.

Physical measures:

Physical security of premises and equipment;

Server access control;

Regular updating of security measures.

c. Limitations and shared responsibilities

Although we implement all reasonable security measures required by law, we cannot guarantee 100% absolute security given the risks inherent in computer systems.

User responsibility: It is your responsibility to keep your password confidential and to notify us immediately of any suspicious access to your Account.

d. Hosting and storage

Your Personal Information is stored on secure computer servers via our third-party cloud infrastructure providers in compliance with legal requirements.

e. Confidentiality incident management

Solidmind keeps a record of confidentiality incidents and has procedures in place to:

Detect and prevent incidents;

Limit the consequences of an incident;

Notify the authorities: Commission d'accès à l'information du Québec within 72 hours;

Inform you without delay if the incident poses a risk of serious harm.

Reporting: If you suspect an incident, contact our Personal Information Protection Officer immediately (Section 2 ).

f. Retention and destruction

Retention period: As long as necessary for our Services and legal obligations;

Account deletion: Data is permanently and immediately destroyed upon deletion of the Account;

Secure destruction: In accordance with the requirements of Privacy Laws;

Anonymization: When the data is no longer needed to identify you.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

You have the right to obtain confirmation as to whether or not we are processing your Personal Information and, if so, to access the Personal Information in question, as well as certain additional information. This additional information includes details about the purposes of the processing, the categories of Personal Information concerned, and the recipients of the Personal Information. Provided that this does not affect the rights and freedoms of others, we will provide you with a copy of your Personal Information.

Privacy Laws give you various rights with respect to your Personal Information. To exercise any of these rights, please contact our Personal Information Protection Officer at the contact information provided in Section 2 of this Policy. In addition, for more information about the protection of your Personal Information and your related rights, you may contact the Office of the Privacy Commissioner of Canada or the Commission d'accès à l'information du Québec.

Office of the Privacy Commissioner of Canada: www.priv.gc.ca

Commission d'accès à l'information du Québec: www.cai.gouv.qc.ca

Right of access

You have the right to:

Ask if we hold Personal Information about you;

Receive information about the purposes of processing, the categories of Personal Information, and the recipients.

Access is free of charge, but reasonable fees may apply for transcription, reproduction, or transmission. We will inform you of the approximate amount of these fees before proceeding.

Right to rectification

You may request the correction of any Personal Information that is incomplete, outdated, or inaccurate. You can modify certain information directly on our Platform or by sending a request to the Personal Information Protection Officer.

Right to withdraw consent

You may withdraw your consent at any time, subject to legal exceptions. Such withdrawal may limit our ability to provide certain Services to you. We will inform you of the foreseeable consequences of such withdrawal before you confirm it.

Right to refuse access

You may request that a particular stakeholder not have access to some of your Personal Information, subject to Solidmind's legal and contractual obligations. We will evaluate each request on a case-by-case basis.

Right to portability

You may request that your Personal Information be communicated or transferred to you in a structured and commonly used technological format.

Right to erasure

You may obtain the deletion of your Personal Information in the following circumstances:

The Personal Information is no longer necessary for the purposes for which it was collected.

You withdraw your consent.

The processing is carried out for direct marketing purposes.

The Personal Information has been processed unlawfully.

However, there are exceptions to the right to erasure. General exceptions include situations where processing is necessary:

For the exercise of the right of freedom of expression and information;

To comply with a legal obligation; or

Establishing, exercising, or defending legal claims.

Right to file a complaint

You may file a complaint with our Personal Information Protection Officer or with the Commission d'accès à l'information du Québec within three (3) years.

How to exercise your rights

Any request relating to the exercise of your rights concerning your Personal Information will be processed as follows:

Acknowledgment of receipt: We will acknowledge receipt of your request within ten (10) days of receiving it.

Standard processing time: We will respond to your request within a maximum of thirty (30) days of receipt.

Extension of the time limit: This time limit may be extended for an additional period of thirty (30) days in the following cases:

The request is complex;

We receive a large number of requests at the same time;

Consultations with third parties are necessary.

Notification of extension: If an extension is necessary, we will notify you in writing before the initial thirty (30) day period expires, specifying:

The reasons for the extension;

The new expected response date;

Your rights of recourse if you are not satisfied with the deadline.

Identity verification: You may be asked to provide sufficient proof of identity before any processing takes place in order to ensure the confidentiality and security of Personal Information.

Written response: A written response will be sent to you in all cases. In the event of total or partial refusal, the reasons for this will be given and the available remedies will be indicated.

Before any processing, you may be asked to provide sufficient proof of identity to ensure the confidentiality and security of Personal Information.

A written response will be sent to you in all cases, whether or not your request is granted. In the event of a total or partial refusal, the reasons for the refusal will be provided, along with the available remedies, including the possibility of filing a complaint with the Commission d'accès à l'information du Québec.

WHAT TO DO IF THE POLICY IS AVAILABLE IN MULTIPLE LANGUAGES?

In the event of any discrepancy between the French and English versions of this Policy, the French version shall prevail.

MODIFICATION OF THIS POLICY

We may amend this Policy from time to time. Any changes to this Policy will take effect when we post the revised Policy on this web page. In the event of significant changes to the Policy, including any changes regarding the purposes for which Personal Information is collected, used, or disclosed, we will notify you in writing at least thirty (30) days before the changes take effect, in accordance with the legal requirements applicable in Quebec.

Your continued use of our Services and/or the Platform after the changes take effect will be considered acceptance of those changes, subject to your legal rights. If you do not agree with the changes to our Policy, you must immediately stop using our Services and Platform. It is your sole responsibility to ensure that you read, understand, and accept the latest version of the Policy. The date of the last update indicated at the top of this Policy is the date of its entry into force.

[However, in the event that the Consumer Protection Act (CQLR, c. P-40.1) applies, Solidmind will notify current Users of the Platform thirty (30) days before the amendment comes into effect. This notification will be sent by email, including details of the changes and their implications, as well as a copy of the new terms and conditions or a link to access them directly from Solidmind. If the User refuses these changes and wishes to terminate their relationship with Solidmind, they will have no later than thirty (30) days after receiving the notice of change to send a notification to Solidmind and terminate, without cost or penalty, their obligations to Solidmind, and must cease all use of the Platform.

WHO SHOULD I CONTACT IF I HAVE QUESTIONS ABOUT THE PROTECTION OF MY PERSONAL INFORMATION?

If you have any questions about how we process your Personal Information, please contact our Personal Information Protection Officer at the contact details provided in Section 2 of this Policy.