Ingenious IM (“We”) are committed to protecting and respecting your privacy.

This policy (together with our website terms and conditions that apply to your use of our website) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Ingenious IM of 200-3970 Saint-Christophe, Montreal, Quebec, H2L 3X8, Canada.

Information We May Collect from You

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site ingeniousim.com (the Website). This includes information provided at the time of corresponding with us via our contact form.

• If you contact us, we may keep a record of that correspondence.

• Details of your visits to our site including, but not limited to, traffic data, location data and other communication data and the resources that you access when you access Ingenious IM.

• ingeniousim.com uses cookies to store and collect information about your usage of the site in order to enhance your online experience and to help us improve the quality of our services.

• When you access ingeniousim.com, your computer automatically sends us information such as the URL on our site you have visited, your IP address, your browser type and language, and the date and time of your request.

Where We Store Your Personal Data

The data that we collect from you may be transferred to, and stored at, a destination outside North America. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Disclosure of Your Information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

• If ingeniousim.com or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website terms and conditions and other agreements; or to protect the rights, property, or safety of ingeniousim.com, our customers, or others.

Your Rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.

The Website may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to Information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of $10 to meet our costs in providing you with details of the information we hold about you.

Changes to Our Data Protection and Privacy Policy

Any changes we may make to our data protection and privacy policy in the future will be posted on this page.

Contact

Questions, comments and requests regarding this data protection and privacy policy are welcomed and should be addressed here.