Privacy Policy

POLICY ON THE COLLECTION AND PROTECTION OF PERSONAL INFORMATION

GENERAL STATEMENT
The protection of your privacy is important to ByTheOwner Inc., doing business under the name of ComFree (“ComFree”). We want to earn your trust and wish to ensure that it is based on a good understanding of what you are agreeing to when you visit the comfree.com website (“our Website”) or deal with ComFree.

We know that your privacy means a lot to you. Your personal information, that is, any information about you as an individual which could identify you (e.g., name, home address, personal e-mail address, home phone number or personal cellphone number) (“personal information”), is valuable. We need to collect this information in order to offer you products and services that appeal to you, to promptly and suitably respond to your needs and, in partnership with you, to continually improve our contribution to the quality of your life.

It is therefore of utmost importance that we inform you of our policy on privacy and the collection, use and communication of the personal information you share with us. By knowing about and regulating the collection, use and communication of the personal information you entrust us with, you will be in a position to make an informed decision.

Although we do not intend to amend the practices described below frequently or substantially, there is a possibility that we will do so to provide you with better service in the future or to keep up with technological advances. This is why we encourage you to review the content on a regular basis.

OUR PRIVACY POLICY

ComFree’s policy is to manage the collection, use and communication of personal information in accordance with the standards of the Personal Information Protection and Electronic Documents Act. Under some circumstances, personal information might be collected, used or communicated without the knowledge or consent of the person involved. These exceptions include, amongst other things, personal information collected for legal or security purposes or to detect and prevent fraud.

A. GENERAL PRINCIPLES
In the framework of collecting and managing personal information, ComFree agrees to respect your privacy and apply the 10 following protection principles, unless otherwise required by law, namely to:

1. Designate and inform you of the individuals in ComFree’s organization who are responsible for overseeing this policy;

2. Receive and process any complaints concerning the application of this policy and the attendant practices;

3. Determine why personal information is collected;

4. Obtain your consent;

5. Limit the collection of personal information;

6. Limit the use and communication of personal information;

7. Assure the accuracy of personal information at the time of its use or communication;

8. Protect your personal information;

9. Facilitate access to details about the existing practices concerning personal information;

10. Give you access to your personal information so you can correct it if necessary.

11. Designate and inform you of the individuals in ComFree’s organization who are responsible for overseeing this policy

All of ComFree’s employees are responsible for ComFree’s policy and practices in connection with the management of personal information. However, it is important to ComFree for you to be able to easily identify who you should contact in this regard, if the need arises. That is why some employees will from time to time be assigned a specific responsibility in this regard. If you send your comments to the address below, we will see to it that they reach the designated individual.

2. Receive and process any complaints concerning the application of this policy and the attendant practices

Requests or complaints regarding the application of this policy can be sent to ComFree at:

E-mail address: privacy@comfree.com

Mailing address: ComFree, 8389, Avenue Sous-le-Vent, Charny (QC) G6X 1K7

3. Determine why personal information is collected
ComFree determines the purposes of the personal information, either before or when it is collected.
Personal information that is collected will only be used for the purposes thus determined, unless otherwise required by law or with your consent to the new use.

4. Obtain your consent
ComFree will obtain your consent to the collection, use and communication of any of your personal information unless otherwise required by law.

5. Limit the collection of personal information
ComFree only collects such personal information as is necessary under the circumstances. ComFree will indicate, where applicable, the mandatory or optional nature of a request for personal information and the consequences of your choice not to communicate any particular item of information.

6. Limit the use and communication of personal information
ComFree only uses or communicates personal information for the purposes for which it was collected, or with your consent or as authorized by law.

7. Assure the accuracy of personal information at the time of its use or communication
ComFree takes reasonable steps to ensure that personal information is up to date and accurate when it is used or communicated. You are invited to make a contribution by promptly informing ComFree of any changes to be made to your records or of any mistakes.

8. Protect your personal information
By taking appropriate security measures based on the circumstances, ComFree protects the personal information it is entrusted with.

9. Facilitate access to details about the existing practices concerning personal information
ComFree makes its policy on privacy and the collection, use and communication of personal information available. The policy can be reviewed on our Website.

10. Give you access to your personal information so you can correct it if necessary
Subject to the conditions and exceptions stipulated at law, ComFree will give you access to the personal information it holds in your regard. Upon request, ComFree will inform you of the existence of personal information concerning you, the use made thereof and the fact that it was communicated to a third party, and will allow you to consult it. You may also contest the accuracy and completeness of the information and make appropriate corrections.

B. DISCLOSURE OF PERSONAL INFORMATION
ComFree will not disclose personal information to a third party. However, there is a possibility that ComFree will use such information for research or statistical purposes. In those circumstances, the transmission of such research or statistics will not reveal your identity or your personal information.

C. COOKIES
Some of our Website pages need to send “cookies”. A cookie is a file installed on your computer’s hard drive containing information that will improve communication between our server and your browser.

Our server will install a permanent cookie on your computer when you first visit our Website and, depending on the applications used, other permanent or temporary cookies that provide technical management for certain options you make may be used.

Be assured that no personal information is stored in the cookies.
You may refuse to accept cookies or you may deactivate them. For that purpose, see your browser’s configuration options. In that case, some of our Website functions will be rendered unavailable.

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