Privacy Policy

This Policy applies to information collected in connection with:

• visiting the Closer Canada website;
• creating and using an account;
• purchasing prospect lists;
• purchasing or using a subscription;
• using artificial intelligence agents;
• using automation tools;
• information requests;
• communications with Closer Canada;
• customer support;
• payment processing;
• and general use of the platform.

This Policy should be read together with the Closer Canada Terms of Use.

Closer Canada operates throughout Canada.

Depending on the circumstances, different federal, provincial or territorial privacy laws may apply.

Closer Canada is committed to handling personal information in accordance with the laws applicable to its activities and the individuals concerned.

Where more than one legal regime may apply, mandatory rights provided under applicable law remain fully applicable.

Closer Canada has designated a function responsible for personal information protection and privacy-related matters.

Person Responsible for the Protection of Personal Information

Closer Canada / I3 Agence Web Marketing inc.

Email: info@i3webmarketing.com

Website: www.closercanada.com

Questions, access requests, correction requests or privacy complaints may be submitted using this email address.

When you create an account, make a purchase, contact us or use certain services, we may collect information such as:

• first and last name;
• company name;
• professional title or position;
• email address;
• telephone number;
• billing address;
• province or territory;
• account information;
• language preferences;
• communications with our team;
• support requests;
• information submitted through forms;
• and other information you choose to provide.

We seek to limit collection to information reasonably necessary for the purposes for which it is collected.

When you make a purchase, we may receive or retain certain transaction information, including:

• product or service purchased;
• amount;
• currency;
• taxes;
• transaction date;
• payment status;
• subscription status;
• refund information;
• and transaction identifiers.

Electronic payments are processed using Stripe.

Stripe may directly collect and process certain information required to process payments in accordance with its own policies and terms.

Closer Canada does not necessarily receive or retain your complete payment card number.

When you use the website or platform, certain technical information may be collected automatically depending on the technologies actually in use.

This information may include:

• IP address;
• device type;
• operating system;
• browser type and version;
• pages viewed;
• date and time of access;
• interactions with the platform;
• referral source;
• technical identifiers;
• and information required for platform security and operation.

This information may be used to operate, secure, analyze and improve Closer Canada.

Closer Canada may use cookies and similar technologies to support certain website and platform functions.

Depending on the technologies used, cookies may be used to:

• maintain sessions;
• authenticate users;
• remember preferences;
• provide security;
• prevent fraud;
• understand platform usage;
• measure performance;
• and improve the user experience.

Where applicable law requires specific consent for certain technologies, Closer Canada will take appropriate steps to obtain such consent.

Users may also manage certain cookies through their browser settings or consent management tools made available to them, where applicable.

Closer Canada offers prospect lists and commercial data intended for B2B activities.

Depending on the products available, this information may include:

• company name;
• industry;
• business address;
• city, province or territory;
• website;
• name of an executive, manager or representative;
• professional title or position;
• business email address;
• business telephone number;
• approximate company size;
• and other relevant professional or commercial information.

Professional and commercial information offered by Closer Canada may come from different lawfully accessible sources or commercial data and service providers.

Depending on the circumstances, sources may include:

• publicly accessible sources;
• company websites;
• professional directories;
• commercial databases;
• data providers;
• partners or service providers;
• or information obtained or validated through Closer Canada's activities.

Closer Canada may combine, organize, structure, verify or update information from multiple sources in preparing its products and services.

Certain professional information may also constitute personal information under some Canadian privacy laws depending on its nature, use and the applicable jurisdiction.

Closer Canada handles such information in accordance with its applicable legal obligations.

The fact that information is publicly available or used in a professional context does not necessarily mean that it may be used without restriction.

An individual who believes that information about them held by Closer Canada is inaccurate or incomplete may contact us.

Where a request is applicable and sufficiently specific, Closer Canada may verify the information and make appropriate corrections in accordance with applicable law.

Requests may be submitted to:

info@i3webmarketing.com

Closer Canada may use collected information to:

• create and administer accounts;
• provide purchased products and services;
• prepare and deliver lists;
• manage subscriptions;
• process transactions;
• provide artificial intelligence agents;
• provide automation tools;
• provide customer support;
• respond to inquiries;
• communicate with users;
• manage business relationships;
• prevent fraud and abuse;
• protect platform security;
• diagnose technical issues;
• analyze and improve the platform;
• develop new features;
• administer our business;
• comply with legal obligations;
• and protect our rights and those of our users.

Where permitted by applicable law, Closer Canada may communicate with customers, prospects or users regarding:

• products;
• services;
• new features;
• subscriptions;
• offers;
• or other relevant commercial communications.

Where required, these communications will include a mechanism allowing recipients to unsubscribe.

A person may request to stop receiving certain commercial communications, subject to communications necessary to administer an account, transaction or service.

Certain Closer Canada services use or may use artificial intelligence technologies.

Depending on the agent and the client's instructions, certain information may be processed to:

• research or prepare prospects;
• analyze business information;
• qualify opportunities;
• prepare content;
• generate suggestions;
• automate certain tasks;
• or provide functionality requested by the client.

The client is responsible for information it chooses to provide to artificial intelligence agents and tools.

Users should avoid unnecessarily providing:

• highly sensitive information;
• medical information;
• confidential financial information;
• passwords;
• government identification numbers;
• or other information that is not necessary for the requested service.

Closer Canada may establish additional requirements regarding information that may be processed by particular agents.

Certain artificial intelligence functionality may rely on third-party technology providers.

Where information must be provided to a technology provider in order to deliver requested functionality, Closer Canada takes reasonable measures to ensure that information is handled in accordance with applicable obligations and relevant agreements.

Providers used may change as Closer Canada's technologies and services evolve.

Closer Canada may disclose certain information to service providers where necessary to operate the platform or provide services.

These providers may include providers of:

• payment processing;
• hosting;
• IT infrastructure;
• storage;
• cybersecurity;
• artificial intelligence;
• communications;
• email delivery;
• analytics;
• authentication;
• technical support;
• or other services required to operate the platform.

We seek to limit information disclosed to what is reasonably necessary for the relevant services.

Closer Canada uses Stripe to process certain payments.

When you make a transaction, certain information may be provided directly to or collected by Stripe to:

• process payment;
• verify the transaction;
• prevent fraud;
• manage refunds;
• manage disputes;
• and provide payment services.

Stripe's processing is also subject to the policies and terms applicable to its services.

Closer Canada may disclose information where permitted or required by law, including to:

• comply with a court order;
• satisfy a legal obligation;
• respond to a legally valid request from an authority;
• investigate fraud;
• protect Closer Canada's security;
• protect the rights or safety of a person;
• or enforce contractual rights.

In connection with a reorganization, merger, acquisition, financing, sale of a business or other business transaction, certain information may be disclosed where permitted by law and subject to applicable protections.

Information provided by a customer to Closer Canada for account creation, payment processing or customer support is not automatically added to prospect lists sold through the platform.

The commercialization of B2B lists is separate from the management of customer account information.

Certain technology providers used by Closer Canada may process or store information in another province, territory or country.

As a result, certain information may be subject to the laws of the jurisdiction in which it is processed or stored and may be accessible to authorities in that jurisdiction in accordance with applicable law.

Where required by law, Closer Canada takes the necessary steps before disclosing or transferring information outside the relevant jurisdiction.

Closer Canada retains personal information only for as long as reasonably necessary for the purposes for which it was collected and to satisfy applicable legal, tax, accounting, contractual or security requirements.

Retention periods may vary depending on:

• the nature of the information;
• its sensitivity;
• the relevant product or service;
• the duration of the business relationship;
• legal requirements;
• security needs;
• and the need to resolve disputes or enforce agreements.

When information is no longer required, it may be destroyed, deleted or anonymized in accordance with applicable practices.

Closer Canada takes reasonable administrative, organizational and technological measures to protect personal information under its control against:

• loss;
• theft;
• unauthorized access;
• unauthorized use;
• unauthorized disclosure;
• modification;
• and unauthorized destruction.

Security safeguards are adapted to factors including the nature and sensitivity of the information involved.

However, no information system or electronic transmission method can guarantee absolute security.

Access to personal information within Closer Canada is limited to individuals who reasonably require the information to perform their duties.

Closer Canada maintains practices intended to detect, assess and manage privacy incidents.

Where an incident occurs, Closer Canada takes reasonable steps to:

• contain the consequences;
• assess the risks;
• remedy the situation where possible;
• document the incident where required;
• and notify affected individuals or appropriate authorities where required by law.

Subject to exceptions under applicable law, an individual may ask whether Closer Canada holds personal information about them and request access to that information.

Requests may be submitted to:

info@i3webmarketing.com

We may request reasonable information to verify the identity of the person making the request before disclosing personal information.

An individual may request correction of inaccurate, incomplete or ambiguous personal information where applicable law provides that right.

Closer Canada will review the request and make appropriate corrections where required.

Where processing is based on consent and applicable law permits withdrawal, an individual may withdraw their consent subject to applicable legal or contractual restrictions.

Withdrawal may result in Closer Canada being unable to provide certain products or services.

Depending on the province or territory, the nature of the information and applicable law, an individual may have additional rights regarding their personal information.

Closer Canada will handle requests in accordance with rights granted under applicable legislation.

Any person with a question or complaint regarding Closer Canada's handling of personal information may contact the person responsible for privacy.

Email: info@i3webmarketing.com

Closer Canada will review complaints and requests in accordance with applicable requirements.

Individuals may also have the right to contact the appropriate privacy regulator where provided by applicable law.

The platform may contain links to websites or services operated by third parties.

Closer Canada is not responsible for the privacy practices of websites or services that it does not control.

Users are encouraged to review the privacy policies of external services they choose to use.

Closer Canada is a platform primarily intended for businesses and professionals.

It is not designed as a service for children.

We do not knowingly seek to collect personal information from children for the purpose of allowing them to directly use Closer Canada's commercial services.

Closer Canada may modify this Policy to reflect:

• changes to its services;
• new features;
• new technologies;
• new service providers;
• changes to its practices;
• or legislative or regulatory changes.

The date of the most recent update appears at the beginning of this Policy.

Where required by law, appropriate notice will be provided regarding material changes.

For questions regarding this Policy or the handling of personal information:

Person Responsible for the Protection of Personal Information

Closer Canada

Operated by I3 Agence Web Marketing inc.

Quebec, Canada

Email: info@i3webmarketing.com

Website: www.closercanada.com