1. Introduction

Groupe Mésosapiens Inc., operating the RefinancePro.club platform ("we", "our" or "RefinancePro"), is committed to protecting the privacy and personal information of its users. This Privacy Policy describes our practices regarding the collection, use, disclosure and protection of personal information in accordance with Quebec's Act respecting the protection of personal information in the private sector (APPIPS), as amended by Law 25, and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).

By using the Platform, you agree to the practices described in this policy. This policy should be read in conjunction with our Terms of Use, which include the Data Processing Agreement (DPA).

2. Privacy Officer

In accordance with section 3.1 of the APPIPS, RefinancePro has designated a Privacy Officer. Any questions, access or rectification requests, or complaints relating to the protection of personal information may be addressed to:

3. Personal Information Collected

3.1 Information Provided Directly

When using the Platform, we may collect the following personal information:

• First and last name
• Email address
• Phone number
• Postal address
• Mortgage information (loan amount, interest rate, term, financial institution)
• Professional information (for brokers: AMF certificate number, firm)

3.2 Automatically Collected Data

We also collect usage data, including:

• IP address
• Browser type and version
• Pages visited and time spent
• Unique device identifiers
• Diagnostic data

4. Purposes of Processing

RefinancePro uses your personal information only for the following purposes:

1. Provide mortgage penalty calculation and analysis services
2. Identify refinancing and renewal opportunities
3. Enable client file management (for brokers)
4. Send authorized communications (emails, SMS)
5. Generate reports and statistics
6. Provide technical support and maintenance
7. Comply with legal obligations

5. Sub-processors and Transfers

We use the following sub-processors to operate the Platform:

6. Security Measures

RefinancePro implements and maintains appropriate technical and organizational security measures:

• Data encryption: AES-256 at rest and TLS 1.2+ in transit
• Access control: Two-factor authentication (2FA), role-based access management
• Monitoring: Access and modification logging, anomaly monitoring
• Infrastructure: Firewalls, intrusion detection systems, regular updates
• Backups: Encrypted backups with periodic restoration testing
• Training: Staff cybersecurity awareness training

7. Incident Notification

8. Your Rights

In accordance with Law 25 and PIPEDA, you have the following rights:

9. Data Retention

RefinancePro retains your personal information only for as long as necessary for the purposes for which it was collected. Upon termination of your use of the Platform:

• You may request a copy of your data (CSV or JSON format) within 30 days
• Your data will be securely deleted within 60 days
• Some data may be retained longer if required by law

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Ensure proper Platform operation (essential cookies)
• Remember your preferences
• Analyze Platform usage

You can configure your browser to refuse non-essential cookies. Note that some features may not be available if you disable cookies.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or via the Platform with at least thirty (30) days notice. Continued use of the Platform after the effective date of the changes constitutes acceptance of the modified policy.

12. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Quebec and the federal laws of Canada applicable therein. Any dispute arising from this policy shall be submitted to the exclusive jurisdiction of the courts of the judicial district of Montreal. For questions relating to the protection of personal information, you may also contact the Commission d'accès à l'information du Québec (CAI).