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Legal Notice

WEBSITE PRIVACY POLICY

Tobo Inc. is committed to respecting the privacy concerns of visitors on its website. Tobo Inc. has created this privacy policy (the “Policy”) to establish guidelines that will govern the collection, use, protection and disclosure of the personal and non-personal information of its visitors.

Tobo Inc. collects three kinds of information from this Website: (1) your voluntarily provided personal information; (2) anonymous non-personal information; and (3) “cookie” based information.

(1) Personal Information: Tobo Inc. does not automatically collect personal information, such as name, address, phone number, email address and other personally identifiable information, from its visitors (“Personal Information”). From time to time, Tobo Inc. will collect Personal Information that is voluntarily provided by its visitors, like when subscribing to a newsletter.

Tobo Inc. will only collect and use such Personal Information solely for the purpose(s) disclosed by Tobo Inc. at the time of collection. All Personal Information that may identify a visitor and has been collected with the visitor’s consent by Tobo Inc. is not disclosed in any identifiable form to any other party outside the company except for the fulfillment of the specific purpose identified to the visitor at the time of collection. However Tobo Inc. may disclose such information in anonymous, aggregated and non-personally identifiable form to other parties for marketing, advertising or other purposes and to better understand visitor’s use of the Website.

At any time, a visitor may send an email to info@tobostudio.com to request that Personal Information be changed, removed or updated in Tobo Inc.’s databases. (2) Anonymous Non-Personal Information: When visitors visit the Website, anonymous, non personal information about their visit is automatically collected. Such information may include the length and date of the visit, how the visitor navigated the Website, what pages the visitor viewed, the type of browser being used by the visitor, the type of operating system used by the visitor and the domain name of the visitor’s Internet service provider. Tobo Inc. uses this Anonymous Non-Personal Information to track the success of its Website with its visitors and to better tailor the Website to visitors’ needs and interests. This Anonymous Non-Personal Information may be shared with other parties, such as broadcasters, advertisers, sponsors and partners.

(3) Cookie-based Information: Tobo Inc. may use cookies on its Website. “Cookies” are pieces of information that a website transfers to a visitor’s hard drive for record keeping and identification purposes. Cookies are used to make the visitor’s use of a website easier by saving visitor preferences and passwords and to identify which areas of the Website are popular and which areas need improvement and how to target certain advertising to its visitors. Tobo Inc. does not use cookies to collect personally identifiable information except in connection with a password protected online registration for a contest or newsletter or other service and only with the visitor’s informed consent. Visitors may visit the Website with its cookies turned off to avoid the collection of Cookie- based Information.

Protection of Visitors’ Personal Information: Tobo Inc. protects the Personal Information it collects with appropriate technological, physical and administrative safeguards to protect if from unauthorized disclosure or use. Access to Personal Information collected by Tobo Inc. is limited to authorized individuals and stored on its databases, which are protected by firewalls and are password-secured. Tobo Inc. retains the Personal Information only for as long as is required for the purposes identified at the time of its collection and consented to by the visitor providing it or as otherwise required by law. Once Personal Information is no longer necessary for the purposes consented to by the visitor, it is Tobo Inc.’s practice to delete it from its data bases or systems or make it anonymous.

Linked Websites: This Website may be linked to other websites. These linked website are not under the control of Tobo Inc. and are required to have their own privacy policies. Visitors should ensure that they read and understand how their Personal Information may be collected, used, and disclosed by the linked websites as Tobo Inc. is not responsible for and shall not be held liable for any procedures, policies or activities of any websites linked to the Website.

Visitor’s Consent to Privacy Policy: By visiting and using this website, the visitor agrees to the Privacy Policy and the terms of use (“Terms of Use”) linked to this Privacy Policy. If you do not agree to the Privacy Policy do not use this Website or provide Personal Information to Tobo Inc.. If you wish to amend, update or remove the Personal Information already provided, may send an email to info@tobostudio.com.

Accountability: Tobo Inc. takes its commitment to securing privacy very seriously. From time to time, Tobo Inc. may amend or update this Privacy Policy to comply with visitor concerns, best practices and/or the law. Tobo Inc. has appointed a member of its management team to act as Tobo Inc.’s Privacy Officer and who is responsible for reviewing, approving and administering this Privacy Policy and Tobo Inc.’s commitments hereunder. If you have any questions, concerns or comments, feel free to contact the Privacy Officer at info@tobostudio.com or by telephone at 1-514-730-3029 or in writing at: Privacy Officer, Tobo Inc., 5455, Avenue de Gaspé bureau 200, Montréal, Québec, Canada, H2T 3B3.

DATA CONSERVATION POLICY
*Effective date: 22 September 2023*.

**1. Purpose of the Policy

The purpose of this policy is to define the procedures and retention periods for personal data collected, processed and stored by Tobo and its subsidiary Tobo Media. This policy complies with Quebec’s Law 25.

**2. Types of Data Concerned**

This policy applies to all personal data of customers and/or employees collected, processed or stored by Tobo and its subsidiary Tobo Media.

**3. Data Retention Period

3.1 **Customer Data:** Customer data will be retained for the period necessary to fulfil the purposes for which it was collected, in accordance with applicable legal requirements.

3.2 **Employee Data:** Employee data will be retained for the duration of their employment and in accordance with legal data retention requirements.

3.3 **Former Employee Data:** Former employee data will be retained for four years to facilitate the completion of the mandatory pay equity exercise required by the CNESST.

3.4 **Freelance and Contract Workers‘ Data:** Freelance and Contract Workers’ contract data will be retained for seven years, as required by the Canadian Income Tax Act.

**4. Access to Data**

4.1 **Internal Access:** Only authorised employees who require access to data as part of their job responsibilities will have such access.

4.2 **External Access:** No data will be shared with third parties without the explicit consent of the parties concerned, except as required by law.

**5. Data Security**

Appropriate security measures will be put in place to protect data from unauthorised access, disclosure, alteration or destruction.

**6. Deletion of Data**

6.1 **Deletion Requests:** Individuals have the right to request the deletion of their personal data. Tobo and its subsidiary Tobo Media will deal with such requests in accordance with applicable law.

6.2 **Automatic Deletion:** Data that is no longer required for the purposes for which it was collected will be securely deleted.

**7. Policy Review**

This policy will be reviewed regularly to ensure its continued compliance with current legislation and its effectiveness.

**8. Contact**

If you have any questions or concerns regarding this policy, please contact Judith Beauregard at 514-730-3029 or jbeauregard@tobostudio[dot]com.