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PRIVACY AND

CONFIDENTIALITY POLICY

1. PROTECTION OF YOUR PERSONAL INFORMATION

This Privacy and Confidentiality Policy (“Policy”) explains the types of personal information that is collected through the use of the Shortkut website (“Shortkut”) (“Site”), the use of such personal information, and the circumstances under which personal information may be disclosed. Shortkut understands the importance of protecting the personal information of its Users and is committed to respecting their right to protect their personal information. For the purposes herein, the term “User” refers to any person who is sixteen (16) years of age or older and who uses the Site for their own account or on behalf of a legal entity, its subsidiaries, and other affiliated companies. If you do not have the required authority or decline the provisions of this Policy, please refrain from using the Site. Please note that Shortkut may modify this Policy at its sole discretion and without prior notice. It is your responsibility to consult the terms and conditions of the Policy to take note of any changes made from time to time. The collection, use, and disclosure of your personal information will be subject to the version of the Policy in effect at the time, which corresponds to the version posted on the site and available at all times through the use of the Site on a given date. Be advised that the Site is intended for Users whose place of residence is located within the geographical limits of Quebec.

2. DEFINITION OF PERSONAL INFORMATION

Personal information is any factual or subjective information about an individual that allows that individual to be identified (e.g., first name, last name, telephone number, or email address). However, personal information does not include business contact information, if such contact information is used to communicate with an individual in connection with their employment, occupation, or profession.

3. CONSENT

Subject to certain exceptions, Shortkut must obtain the User’s consent for the collection, use, and disclosure of their personal information. Consent may be express or implied. It must also be valid, meaning that the User must understand the nature, purpose, and consequences of the collection, use, or disclosure of the personal information to which they consent. It may be provided by the User in writing or electronically. Express consent is generally given when the User completes and signs a request or membership form and submits it to Shortkut, such as the newsletter subscription form. Implied consent occurs when Shortkut can reasonably infer that the User has consented, as a result of an action or inaction on their part, or due to the circumstances.

4. COLLECTION OF INFORMATION

Shortkut limits the collection of personal information to that which is necessary for the stated purposes. It is not safe to transmit your personal information in spaces intended for discussions and exchanges between Users. To protect personal information, the User should only transmit it through the forms provided for this purpose by Shortkut. Despite all the efforts made by Shortkut to implement the necessary measures to protect the User’s collected personal information, Shortkut cannot guarantee that the User’s personal information is safe from any malicious act of computer hacking. Consequently, any information, personal or otherwise, shared, published, or transmitted on the Site by the User is at their own risk.

5. USE OF INFORMATION

Essentially, the personal information collected allows Shortkut to identify the User, communicate with them, and personalize their service. Shortkut reserves the right to use the personal information obtained to conduct market studies in order to adequately meet the needs of its customers and improve its Site and service offerings. If you have consented to add your email address to Shortkut’s mailing list, you may, at any time, choose to no longer receive marketing communications or newsletters sent by email by unsubscribing through the hyperlink included in these communications.
Shortkut does not sell the personal information of its Users to third parties and does not use or disclose such personal information for purposes other than those for which it is collected. Applicable laws and regulations provide certain exceptions to this Policy and the use of your personal information. These exceptions may affect privacy practices. For example, Shortkut may collect, use, or disclose the personal information of its Users, in particular in the following situations:
a) if the collection of information is clearly for your benefit and your consent cannot be obtained in a timely way;
b) if, by law, the information is deemed to be in the public domain;
c) if the information is disclosed to government agencies under anti-money laundering and anti-terrorism financing laws; or
d) in connection with tax filings to the competent authorities or other disclosures required by law.

6. PROTECTION OF INFORMATION

Shortkut implements physical, organizational, and technological security measures to protect the User’s personal information against unauthorized access, disclosure, copying, use, or modification, as well as against loss or theft. Shortkut’s computer systems, including those of its subcontractors and hosting partners from whom it obtains hardware, software, networks, storage space, and related technologies to ensure the operation and maintenance of the Site, are protected by passwords and are configured in such a way that only those persons who are required to access your personal information for the purposes of their functions within Shortkut are authorized to access the secure systems and databases.

7. COOKIES, SOCIAL MEDIA, AND BLOG

In order to properly manage the Site and provide a personalized online experience, Shortkut automatically collects certain information of a non-personal nature, the usual Internet log file data, including the User’s IP address, browser type and language, access frequency, and referring website addresses, including through the use of various types of cookies and conversion tags. Shortkut does not profile your computer and does not extract any information from your hard drive. Most browsers are configured by default to accept cookies, but the User can change the configuration to refuse or limit their use. In addition, the Site includes certain functions related to social media. These functions may collect your IP address and leave a cookie in order to perform the function. The social media features and widgets are hosted by a third party. The User’s interactions with these features are governed by the privacy and confidentiality policy of the company providing them. Shortkut in no way endorses or supports the opinions expressed in the comments posted by Users on its blog and does not verify the accuracy of such comments. Shortkut reserves the right to modify or delete any message, question, or comment that is disrespectful, offensive, insulting or discriminatory, at its sole discretion.

8. 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 Shortkut. To do so, or if you have any questions or concerns regarding the protection of your personal information, please contact Shortkut’s customer service by email at: info@shortkut.ca.

9. APPLICABLE LAW

This Policy and the relationship between the User and Shortkut under this Policy are governed and interpreted under the laws of the province of Quebec, Canada, without regard to conflict of laws provisions.
By accepting this Policy, the User expressly submits to the exclusive jurisdiction of the courts of the province of Quebec (judicial district of Montreal) for the resolution of disputes related to this Policy. Notwithstanding the foregoing, the User agrees that Shortkut remains authorized to initiate any injunction proceedings (or any other equivalent emergency measure) with any competent authority. If a court of competent jurisdiction determines