Privacy

01. Introduction

Sivaiah Technologies Inc. ("we", "our", "us", "website") respects the privacy of our users and is committed to protecting it through our compliance with this Privacy Policy. This policy describes:

a) The types of information we may collect from you or that you may provide when you visit the website echorate.ca ("our Website").

b) Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by any third party.
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy.

02. Information Collection

Detailing what personal information your website collects, and how it's collected, is key to transparency and compliance.

03. Personal Information

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline ("personal information").
• That is about you but individually does not identify you.
• About your internet connection, the equipment you use to access our Website, and usage details.

04. Collection Methods

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

05. Use of Information

The information we collect on or through our Website may be used for the following purposes:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

06. Marketing Use

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

07. Information Sharing and Disclosure

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the website's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or our safety, our customers, or others.

08. Cookies and Tracking Technologies

Our Website uses cookies (small files placed on your device) and other tracking technologies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. We use cookies and similar technologies to:

• Understand and save user's preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you disable cookies, some features of our site may not function properly.

09. Data Security

The security of your personal information is important to us. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

10. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

After the end of the retention period, personal data will be deleted or anonymized, so it can no longer be associated with a specific individual. Certain information may be retained for longer periods for specific legal or regulatory obligations or for other legitimate business purposes.

11. Your Rights

As our user, you have certain rights regarding the personal information we hold about you. These may include:

• The right to access your personal information.
• The right to rectify any inaccurate or incomplete personal information.
• The right to delete personal information under certain circumstances.
• The right to restrict processing of your personal information in certain scenarios.
• The right to data portability, allowing you to obtain and reuse your personal data for your own purposes across different services.
• The right to object to the processing of your personal information in certain circumstances, including for marketing purposes.

To exercise any of these rights, please contact us using the contact information provided in the Privacy Policy. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).

12. International Data Transfers

We operate globally, which means personal information we collect may be transferred to, stored, or processed in countries outside of your own. This includes countries outside of the European Economic Area (EEA) for websites that collect information from individuals within the EEA.

We ensure that such international transfers are made subject to appropriate safeguards as required by relevant data protection laws. For transfers of personal information outside the EEA, we implement standard contractual clauses approved by the European Commission, rely on the EU-U.S. Privacy Shield Framework, or take other measures to provide an equivalent level of data protection as is required by law in your jurisdiction.

Whenever we transfer your personal data out of your jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant authorities.
• Where we use certain service providers, we may use specific contracts approved by the relevant authorities which give personal data the same protection it has in your jurisdiction.

By using our Website and providing us with your personal data, you consent to these transfers in accordance with this policy.

13. Children's Privacy

We recognize the importance of protecting the privacy and safety of children. Our Website is not intended for children under the age of 16 years, and we do not knowingly collect personal information from children under this age. If we learn we have collected or received personal information from a child under the applicable age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the applicable age, please contact us at support@echorate.ca.

14. Third-Party Links and Services

Our Website may contain links to websites, applications, and services not operated by us. These links are provided for your convenience only. We have no control over, and are not responsible for, the content, privacy policies, or practices of any third party websites, applications, or services. The inclusion of a link does not imply endorsement by us of the site or any association with its operators.

We encourage you to be aware when you leave our Website and to read the privacy policies of any other site that collects personal information. This Privacy Policy applies solely to information collected by our Website.

15. Social Media and Widgets

Our Website may include social media features, such as the Facebook "Like" button, and widgets, such as the "Share" button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website.

Your interactions with these features are governed by the privacy policy of the company providing it. We encourage you to carefully review the privacy policies and ask questions before disclosing your personal information or any other information on or through them.

16. Behavioral Advertising

Our partners with third-party service providers to display advertising on our Website and manage our advertising on other sites. Our third-party service providers may use technologies such as cookies to gather information about your activities on our Website and other sites in order to provide you advertising based upon your browsing activities and interests.

Your Choices Regarding Behavioral Advertising:

You have the choice to opt out of this type of advertising. For more information about behavioral advertising practices or to opt-out of this type of advertising, you can visit the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA) .

17. Security Breaches

In the unlikely event of a security breach that compromises our security measures and results in unauthorized access to or disclosure of your personal information, we will promptly evaluate the situation and take appropriate steps to address the breach, including notifying affected individuals in accordance with applicable laws and regulations.

We are committed to keeping your personal information safe and have implemented robust security measures designed to prevent such breaches. However, should a breach occur, we will take immediate steps to mitigate any potential harm and will communicate with you regarding what happened, what information was involved, what we are doing in response, and what actions you may consider to protect yourself.

18. Consent

By using the website, you consent to the collection, use, and sharing of your personal information as outlined in this Privacy Policy. We obtain your consent in accordance with the requirements of applicable laws and regulations. Consent is provided by using our Website, registering an account, or explicitly accepting the terms of this policy where prompted.

Withdrawal of Consent:

You have the right to withdraw your consent at any time. If you wish to withdraw your consent to our processing of your personal information, please contact us at support@echorate.ca. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal and that we may continue to retain information as required or permitted by law.

19. Automated Decision Making and Profiling

We may use automated decision-making and/or profiling to better understand your preferences and tailor our services accordingly. For example, we may analyze your browsing behavior to offer you personalized product recommendations.

Details about Automated Decision Making and Profiling:

• Automated Decision Making refers to decisions made entirely through automated processes without human intervention.
• Profiling involves automated processing of personal data to evaluate certain personal aspects relating to an individual, particularly to analyze or predict aspects concerning that individual's preferences, interests, or behavior.

We want to inform you that you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except as allowed under applicable laws.

20. Interoperability with Terms of Use

This Privacy Policy is part of the website's Terms of Use, which together with any other documents referred to in it, sets out the terms on which you may make use of our website echorate.ca. The Privacy Policy complements the Terms of Use and is not intended to override them. In case of any conflict between this Privacy Policy and the Terms of Use, the Terms of Use shall prevail to the extent of the conflict.

21. Data Portability

Under certain conditions, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from us, where:

• The processing is based on consent or on a contract.
• The processing is carried out by automated means.

22. Requesting Data Portability

To exercise your right to data portability, please contact us at support@echorate.ca. We will provide your personal data in a usable electronic format and, where technically feasible, can directly transmit your data to another data controller.

23. Impact Assessments

We are committed to protecting the privacy and security of our users. As part of this commitment, we conduct Privacy Impact Assessments (PIAs) for any new projects, technologies, or processes that might significantly impact the privacy of personal data we collect or process. These assessments help us identify potential privacy issues before they arise and design solutions to mitigate any identified risks.

PIAs involve a thorough analysis of how personal data is collected, used, shared, and stored, and evaluate the necessity and proportionality of processing in relation to the purposes. We also assess the risks to individuals' rights and freedoms and implement measures to safeguard against these risks.

24. Updates and Notifications

The privacy landscape is constantly evolving, and as a result, we may update this Privacy Policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. We encourage users to review our Privacy Policy regularly to stay informed about our information practices and the choices available to them.

25. Notification of Changes

If we make significant changes to our Privacy Policy, we will notify users through our Website or via email, specifying the effective date of the new policy. Your continued use of our Website after the effective date of the Privacy Policy constitutes your acceptance of the updated terms.

26. Privacy by Design

We adopt a Privacy by Design approach, integrating data protection principles into our technology platform, business practices, and design processes from the outset. This proactive stance ensures privacy and data protection are foundational elements of our user experience, not afterthoughts.

Our Privacy by Design principles include:

• Minimizing Data Collection: Collecting only the data necessary for the specified purposes.
• Limiting Access and Disclosure: Ensuring that access to personal data is restricted to authorized personnel and for intended purposes only.
• Securing Data: Implementing robust security measures to protect personal data against unauthorized access, disclosure, alteration, and destruction.
• Transparency: Being open with our users about how we collect, use, and share personal data.
• User Empowerment: Providing users with easy-to-use tools and choices about their personal data.

By incorporating these principles, we aim to protect user privacy and build trust, ensuring that personal data is handled in a manner that respects individual privacy rights.

27. Payment Processing

To ensure secure and efficient payment processing, we utilize Stripe, a reputable third-party payment service provider. When you make payments through our platform, your payment information is processed by Stripe in accordance with their privacy policy. We recommend reviewing Stripe's Privacy Policy to understand how your payment data is handled. You can find Stripe's Privacy Policy at https://stripe.com/privacy.

28. Governing Law

This Privacy Policy and any disputes arising out of or related to it or to the use of the website are governed by and construed in accordance with the laws of the province of Ontario, without giving effect to any choice or conflict of law provision or rule. By using the website, you consent to the jurisdiction of and venue in the courts of the jurisdiction of Region of Waterloo for any litigation or dispute that arises out of or relates to this Privacy Policy.

29. Data Protection Officer

To ensure the highest level of data protection and privacy compliance, we have appointed a Data Protection Officer (DPO). The DPO is responsible for overseeing our data protection strategy and its implementation to ensure compliance with GDPR and other data protection laws. If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this website, you can contact our DPO at:

• Name: Sambhav Nath
• Email: support@echorate.ca
• Phone Number: (226) 894-1399

Please reach out to our DPO with any concerns or questions you have about your personal data and privacy rights.

30. Changes to the Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy.

31. Contact Information

For any questions or comments about this Privacy Policy and our privacy practices, contact us at:

• Email: support@echorate.ca
• Phone: (226) 894-1399

Our team is dedicated to addressing any concerns about your privacy and resolving any complaints.