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Privacy

Privacy Policy

Last modified:

Introduction

Shirah Technologies Inc. (“Shirah”, “we”, “our”, and “us”) recognizes the importance of protecting the privacy and the rights of individuals in relation to their personal information. The purpose of this privacy policy (“Privacy Policy”) is to inform you about our privacy practices, including how we collect, use and disclose your Personal Information.

This Privacy Policy applies to all of our operations in Canada or operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service or activity.

Shirah is a mobility technology company. We build and operate software products that support people who move for work or study, and the employers and institutions that receive them.

This Privacy Policy describes:

  • How we collect, use, disclose and protect the personal information of individuals (the “user”, “you”, or “your”) who access our corporate website, available at https://shirah.co/ (the “Website”);
  • The types of information we may collect from you or that you may provide when you use the Website; and
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy governs the Website only. Our products each operate on their own websites and platforms and are governed by their own privacy policies. Please see “Our Products and Their Separate Privacy Policies” below.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law.

Our Products and Their Separate Privacy Policies

Shirah builds and operates separate software products, each with its own website or platform, its own users and its own privacy practices. These currently include MployNow, Portify and Studendly.

This Privacy Policy does not govern those products. If you register for, log in to, or use any Shirah product, the privacy policy published on that product’s website or platform governs the personal information you provide there, and you should read it before you provide any information.

Visiting the Website does not create an account with Shirah or with any Shirah product, and does not by itself result in your personal information being shared with any product.

Privacy Policy Updates

This Privacy Policy is current as of the “last modified” date which appears at the top of this page. We may make changes to this Privacy Policy from time to time, which will become immediately effective when published in a revised Privacy Policy posted on our website unless otherwise noted. You are responsible for checking if any amendments have been made to this Privacy Policy. Your continued use of our Website will constitute your consent to collection, use, and disclosure of your personal information as described in the amended Privacy Policy.

Please review this Privacy Policy carefully. By submitting your personal information (“Personal Information”) to us, by using our Website, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Policy, as revised from time to time.

What is Personal Information?

Personal Information means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, your name, e-mail address and telephone number. Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work e-mail address.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of that Personal Information as outlined in this Privacy Policy.

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us using the information in the ‘Contact Information’ section below. In some cases, withdrawal of your consent may mean that we will no longer be able to respond to you or provide certain information.

Information We Collect About You

If you access or use our Website, Shirah may collect and process the following types of information from and about you, including:

Personal Information: We collect your personal information primarily to respond to you, communicate with you effectively, and support the operation and management of our business. This includes:

  • name;
  • email address;
  • telephone number; and
  • any other information you choose to include when you contact us, subscribe to a mailing list, or otherwise

write to us, including details of your preferences in receiving marketing information and your communication preferences. Technical Information: We automatically collect technical data such as your IP address, browser type, operating system, and device information to help ensure the security, performance, and optimal functionality of our Website.

Usage Information: This includes information about how you interact with our Website, such as the pages you visit, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page. We use this data to enhance your user experience.

The Website does not require you to create an account and does not process payments. We do not collect usernames, passwords or payment card details through the Website.

How Do We Collect Your Personal Information?

We use different methods to collect your information, including through:

Information you provide to us. This information may include:

  • when you make an inquiry about our company or our products;
  • during communications between you and our representatives;
  • when you interact with us via social media; or
  • when you ask to be placed on one of our mailing lists. Information collected through automated technologies or interactions. As you navigate through and use our Website, we may automatically collect through cookies, and other tracking technologies the following types of data: usage details, traffic data, location data and information about your computer and internet connection, including your IP address, operating system, and browser type. Please see ‘Automatic data collection technologies’ below for more information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, in the following ways:

  • Responding to you: to answer inquiries and provide timely, accurate assistance.
  • Website optimization: to analyze usage data and improve the Website for a better user experience.
  • Marketing outreach: to send updates and promotional content based on your preferences, with the option to

opt out at any time.

  • Regulatory compliance: to meet legal and audit requirements, including data integrity and accounting

obligations.

  • Strategic planning: to use aggregated and anonymized data for business planning and resource allocation.
  • Security monitoring: to conduct audits and risk assessments that protect your data from unauthorized access

or breaches.

How We Share Your Personal Information

We rely on third party service providers to perform a variety of services on our behalf, such as data storage (Google Cloud) and email marketing (Mailchimp).

If we provide information to service providers, we require that the service providers keep your Personal Information secure and only handle it for limited purposes. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.

Direct Marketing Communications

We may send you direct marketing communications and information about our company and our products that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax, and email, in accordance with applicable marketing laws, such as Canada’s Anti-Spam Legislation (CASL). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt out of receiving marketing communications from us by contacting us (see ‘Contact Information’ below) or by using the unsubscribe mechanisms provided in our marketing communications.

We do not provide your personal information to other organizations for the purposes of direct marketing.

Security of Your Personal Information

The security of your personal information is very important to us. We may hold your information in either electronic or hard copy form. We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorized access, modification, or disclosure.

Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk. We endeavour to take all reasonable steps to protect the personal information you may transmit to us. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems.

Transferring Your Information

We may transfer personal information that we collect or that you provide as described in this policy to contractors and service providers we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. You are welcome to contact us (see ‘Contact Information’ below) to obtain further information about our policies regarding service providers outside of Canada.

Getting and Withdrawing Your Consent

We only collect information by lawful means. As part of using our Website or interacting with us, we may collect and process some details about you. When we do so, we will collect, use or share your personal information with your consent for the purposes identified or as otherwise permitted or required by law. In compliance with our privacy obligations, we may obtain your permission based on implied consent (including through this privacy policy) or through other means (such as express consent). However, in some situations, the law allows us to collect, use or disclose personal information without your consent.

You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer respond to you or perform certain tasks where the information is required to do so.

You may withdraw your consent to the collection, use or disclosure of your or your child’s personal information at any time by contacting our Privacy Officer (see ‘Contact Information’ below) and, subject to any legal constraints, we will comply with your request.

Data Subject Rights

You may request access to any personal information we hold about you at any time by contacting us (see ‘Contact Information’ below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by emailing it to you).

If you believe that Personal Information we hold about you is incorrect, incomplete, or inaccurate, then you may request us to amend it. We will consider whether the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the Personal Information stating that you disagree with it, together with your requested amendment. If we correct your Personal Information, we will, so far as is reasonably practicable, inform every other person to whom we have disclosed that information of the correction.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or to give effect to other data subject rights you may be entitled to. In certain situations, we may not be able to fulfil your request. If that is the case, we will explain the reasons for our decision when responding to your request. For example, in some cases the information you request access to may contain details about other individuals, or there may be legal, security, or commercial proprietary reasons why information is withheld.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser settings to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may not be accessible or may not function properly. For more information about tracking technologies, see ‘Automatic data collection technologies’ below.

Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish for us to use your contact information to promote our own or third parties’ products or services, you can opt out by clicking “Unsubscribe” at the bottom of the email.

Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form where we collect your data. You can also opt out by contacting us (see ‘Contact Information’ below).

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by contacting us.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioural tracking. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Automatic data collection technologies

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • estimate our audience size and usage patterns;
  • store information about your preferences, allowing us to customize our Website according to your individual

interests;

  • speed up your searches; and
  • recognize you when you return to our Website. The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or your smartphone. You may refuse to accept browser cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see ‘Choices about how we use and disclose your information’.

Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Shirah, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they

may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see ‘Choices about how we use and disclose your information’.

Third Party Websites and Services

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications (collectively, “Third-Party Services”), and to our own product websites. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a Third-Party Service, please note that these third parties have their own privacy policies, and we do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third party websites or products or services.

Use of Services by minors

The Website is not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal information from individuals under 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through the Website without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us through the Website, please contact us using the ‘Contact Information’ below and we will endeavour to delete that information from our systems and databases.

Contact Information

We welcome your questions, comments, complaints and requests regarding this Privacy Policy and our privacy practices. Shirah has designated a Privacy Officer who is accountable for our compliance with this policy and with applicable privacy laws. You may contact our Privacy Officer at:

Privacy Officer Shirah Technologies Inc. enquiries@shirah.co

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. Please note that we may need to confirm your identity or request additional details in order to process your request.

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