This privacy and spam policy (the “Policy”) aims to inform visitors, users and customers (hereinafter “you”) of the Keenoa application (hereinafter the “Platform”) available on the Web, on the App Store and on Google Play and operated by Les Solutions Keenoa Inc. (hereinafter “we” or “Keenoa”) about the way personal information is handled by Keenoa and to inform you of your rights. Your use of the Platform is also governed by our Terms of Use. We invite you to review them carefully.

Consent

The handling of personal information by organizations is governed by laws and regulations and we need to obtain your consent in order to collect, use and disclose your personal information. By using the Platform, you agree to this privacy Policy and you give your consent to the collection, use, disclosure, storage and deletion of your personal information in accordance with the terms of this Policy. IF YOU PREFER NOT TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY, , YOU MAY BROWSE THE WEBSITE BUT USE OF IT WILL BE LIMITED.

Personal Information We Collect

Information Collected from You

We store all collected information described above in accordance with this privacy policy. We collect information you voluntarily share with us either through the Platform interface (e.g. by filling out a form) or otherwise. Such information may include: • Your full name; • Gender; • Date of birth; • Preferred language; • Email address; • Country of residence; • Any document you upload to the Platform including photos, videos, content; • Information you communicate to us through the Platform or by email; • Information transmitted by social networking sites or applications (e.g. Facebook, LinkedIn, Twitter, Google+, etc.) in any case where you interact with profiles held or controlled by Keenoa on such social networking platforms. These sites or platforms could be governed by other policies regarding personal information which may also be applicable. Information Collected Automatically Some information is collected automatically while you use the Platform. This information may include: • Your IP address; • Your browser settings and operating mobile system; • Your mobile device settings if you are accessing the Platform from a mobile device; • Pages visited, items viewed and clickstream data; Crash Events, we use https://sentry.io/ to collect anonymous crash reports. No user information (not even an ID) is tied to errors collected. We use this to identify and fix bugs/issues happening in production ensuring our users a bug free experience. Usage Events, we use https://amplitude.com/ to collect anonymous user events. No user information (not even an ID) is tied to events collected. We use this information to continually improve the application’s features. For example, we use these events to know how much time is needed to track a meal or the percentage of entries added using the barcode scanner. Server logs, we use https://www.datadoghq.com/ to process server logs. Server logs are automatically generated records of activities that occur on our servers when you access or interact with our Service. These logs may include various types of data, such as your IP address, browser type, device information, referring/exit pages, date/time stamps, and clicks. It is important to note that server logs do not contain personally identifiable information (PII) such as your name, email address, or physical address. We do not collect personal information from individuals under the age of 14 without verified parental or guardian consent.

Information Collected through Cookies

We use cookies to improve the performance of the Platform and your experience. Cookies are small files saved on your computer by the Platform’s server or third-party servers which allow your computer to be recognized and content to be personalized. Some cookies will be automatically erased when you shut down your browser (session cookies) whereas others are stored indefinitely (permanent cookies). Unless you voluntarily provided us with information about yourself, cookies are not associated with your identity. Automatically collected information could, however, be associated with your identity if you provide such information. You may disable the logging of some or all cookies on your computer, but that could result in your inability to use some Platform features.

Financial Information

Sensitive financial information with respect to payments made through the Platform is stored by Stripe and is not available to Keenoa. We recommend that you check Stripe's Privacy Policy applicable to your financial information.

How We Use Collected Personal Information

We use collected information to: • Contact you about our products and services; • Send automated emails to confirm email addresses or our receipt of a request from you; • Process your transactions; • Put you in touch with dietitians and nutritionists (the “Professionals”); • Respond to your inquiries about our products and services; • Perform analyses about our customers; • Build databases from information on our actual and potential customers; • Personalise your experience of the Platform, including by storing your preferences and selected or favorite items; We use the information collected automatically, on an anonymous basis, in order to, inter alia: • Monitor Platform traffic; • Improve Platform performance, including by assessing which pages or features are most seen or used by visitors; and/or • Perform analysis about traffic to the Platform.

Storage, Destruction and Anonymization of Personal Information

We keep collected personal information until concerned individuals request that it be deleted or until such time where it is not required by our activities since the purposes for which it was collected have been fulfilled. We then proceed to securely destroy or anonymize your personal information in accordance with the law. However, except as required by applicable laws and regulations, we do not commit to keep any information for a determined length of time. Collected personal information is stored in electronic format on servers at various physical locations, which are subject to change and may be outside of Quebec and Canada. Collected information is protected by commercially reasonable security measures considering the sensitivity of the information.

Disclosure of Personal Information

Unless specifically stated in this Privacy Policy, we will not sell, lease or disclose your personal information without your prior consent, except as disclosed on the Platform, including connecting you to Professionals. Collected personal information may only be accessed by our personnel as required to use such information in compliance with this Privacy Policy to which they must adhere. Collected information may also be accessed by our agents, suppliers or subcontractors in the case where such information is required to perform their duties. These persons or organizations will undertake to keep personal information confidential and to use such information only to the extent necessary to carry out their responsibilities. We may disclose lists of names, telephone numbers and physical or technological addresses to third parties for commercial or philanthropic prospection purposes. You may request that your personal information be removed from such lists at any time in writing at the following address: privacy@keenoa.com. We will remove your personal information from all such lists within a reasonable delay of the receipt of your written request. In the event where the sale or restructuring of the enterprise carried out by Keenoa is contemplated (a “Transaction”), we reserve the right to disclose collected information, including personal information, to persons and organizations involved both before and after the Transaction, whether or not it is actually completed. Such persons or organizations shall commit to keep personal information confidential and to use same only to the extent required to assess the opportunity of the Transaction or in compliance with this Policy. We may also disclose personal information to third parties if compelled by competent authorities or if expressly permitted by law.

Access and Rectification Rights

You may access your personal information or ask that erroneous information be corrected. You must make a written request to that effect at the following address: privacy@keenoa.com. We will respond to your written request at the latest within 30 days of receipt and will give you access to your personal information within what is permitted by applicable law. Reasonable fees could apply in certain cases for transcribing, reproducing or transmitting this information. We will inform you of the approximate amount in advance. Under the terms and conditions provided for by law, you may request that we cease broadcasting or de-index a hyperlink containing your personal information. We may verify the identity of individuals seeking to access personal information. Any information provided for identification purposes will not be recorded nor used for any other purpose.

Rights to Withdraw Consent

You may withdraw your consent to the disclosure or use of the information collected at any time. You understand that certain functionalities of the Platform may no longer be accessible or may be restricted following the withdrawal of your consent to this Policy.

Junk Mail

We abide by the laws and regulations governing unwanted electronic communications. If you no longer wish to receive electronic communications from Keenoa, you may so advise us at any time in writing at the following address: privacy@keenoa.com. We will continue to have the right to contact you about your orders, requests for information or in connection with the handling of your personal information.

Changes to this Policy

We may modify this Privacy Policy in order to reflect changes in our business and our handling of personal information. Where a modification is made, a new Privacy Policy will be posted on the Platform and should you continue to use the Platform, you will be bound by the new Privacy Policy.

Governing Law

The handling of personal information is governed by laws and regulations which may vary from jurisdiction to jurisdiction. This Privacy Policy as well as any associated operation is governed by the laws of the Province of Quebec applicable therein and shall be interpreted accordingly. Any claim, dispute or complaint with respect to the subject matter of this Policy shall be brought before the competent authority of the Province of Quebec, sitting in the judicial district of Montreal, hereby excluding any other forum or jurisdiction.

Additional Information or Complaint

If you would like further information about how we handle personal information, or if you have a complaint about, for example, the unjustified use of your personal information, you can contact our Privacy Officer at: privacy@keenoa.com. We investigate all privacy complaints and take appropriate steps to resolve them, including amending our practices where necessary.

PREVIOUS UPDATE: NOV 2017

This privacy and spam policy aims to inform visitors, users and customers (hereinafter “you”) of the Keenoa application (hereinafter the “Platform”) available on the Web, on the App Store and on Google Play and operated by Les Solutions Keenoa Inc. (hereinafter “we” or “Keenoa”) about the way personal information is handled by Keenoa.

Your use of the Platform is also governed by our Terms of Use. We invite you to review them carefully.

The handling of personal information by organizations is governed by laws and regulations and we need to obtain your consent in order to collect, use and disclose your personal information. By using the Platform, you agree to this privacy policy and you give your consent to the collection, use, disclosure, storage and deletion of your personal information in accordance with the terms of this policy.

IF YOU PREFER NOT TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY, PLEASE STOP BROWSING ON OR USING THE WEBSITE IMMEDIATELY.

Information We Collect

Information Collected from You

We store all collected information described above in accordance with this privacy policy.

Some collected information may not fall under the definition of personal information and may not be subject to all obligations contained herein or set forth by applicable laws and regulations.

We collect information you voluntarily share with us either through the Platform interface (e.g. by filling out a form) or otherwise. Such information may include:

• Your full name;
• Gender, height and weight
• Email address;
• Information you communicate to us through the Platform or by email;
• Information transmitted by social networking sites or applications (e.g. Facebook, LinkedIn, Twitter, Google+, etc.) in any case where you interact with profiles held or controlled by Keenoa on such social networking platforms. These sites or platforms could be governed by other policies regarding personal information which may also be applicable.

Information Collected Automatically

Some information is collected automatically while you use the Platform. This information may include:

• Your IP address;
• Your browser settings and operating mobile system;
• Your mobile device settings if you are accessing the Platform from a mobile device;
• Location data and geographical coordinates;
• Pages visited, items viewed and clickstream data;

Information Collected through Cookies

We use cookies to improve the performance of the Platform and your experience. Cookies are small files saved on your computer by the Platform’s server or third-party servers which allow your computer to be recognized and content to be personalized. Some cookies will be automatically erased when you shut down your browser (session cookies) whereas others are stored indefinitely (permanent cookies). Unless you voluntarily provided us with information about yourself, cookies are not associated with your identity. Automatically collected information could, however, be associated with your identity if you provide such information. You may disable the logging of some or all cookies on your computer, but that could result in your inability to use some Platform features.

Financial Information

Sensitive financial information with respect to payments made through the Platform is stored by Stripe and is not available to Keenoa.

We store all collected information described above in accordance with this Privacy Policy.

Some collected information may not fall under the definition of personal information and may not be subject to all obligations contained herein or set forth by applicable laws and regulations.

How We Use Collected Information

We use collected information to:

• Contact you about our products and services;
• Send automated emails to confirm email addresses or our receipt of a request from you;
• Process your transactions;
• Put you in touch with dietitians and nutritionists (the “Professionals”);
• Respond to your inquiries about our products and services;
• Perform analyses about our customers;
• Build databases from information on our actual and potential customers;
• Personalise your experience of the Platform, including by storing your preferences and selected or favorite items;

We use the information collected automatically, on an anonymous basis, in order to, inter alia:

• Monitor Platform traffic;
• Improve Platform performance, including by assessing which pages or features are most seen or used by visitors; and/or
• Perform analysis about traffic to the Platform.

Storage of Personal Information

We keep collected personal information until concerned individuals request that it be deleted or until such time where it is not required by our activities. However, except as required by applicable laws and regulations, we do not commit to keep any information for a determined length of time.

Collected personal information is stored in electronic format on servers at various physical locations, which are subject to change and may be outside of Canada.

Collected information is protected by commercially reasonable security measures considering the sensitivity of the information.

Disclosure of Personal Information

Unless specifically stated in this Privacy Policy, we will not sell, lease or disclose your personal information without your prior consent, except as disclosed on the Platform, including connecting you to Professionals.

Collected personal information may only be accessed by our personnel as required to use such information in compliance with this Privacy Policy. Collected information may also be accessed by our agents, suppliers or subcontractors in the case where such information is required to perform their duties. These persons or organizations will undertake to keep personal information confidential and to use such information only to the extent necessary to carry out their responsibilities.

We may disclose lists of names, telephone numbers and physical or technological addresses to third parties for commercial or philanthropic prospection purposes. You may request that your personal information be removed from such lists at any time in writing at the following address: privacy@keenoa.co. We will remove your personal information from all such lists within a reasonable delay of the receipt of your written request.

In the event where the sale or restructuring of the enterprise carried out by Keenoa is contemplated (a “Transaction”), we reserve the right to disclose collected information, including personal information, to persons and organizations involved both before and after the Transaction, whether or not it is actually completed. Such persons or organizations shall commit to keep personal information confidential and to use same only to the extent required to assess the opportunity of the Transaction or in compliance with this Policy.

We may also disclose personal information to third parties if compelled by competent authorities or if expressly permitted by law.

Access Rights

You may access your personal information or ask that erroneous information be corrected. You must make a written request to that effect at the following address: privacy@keenoa.co.

We will respond to your written request at the latest within 30 days of receipt and will give you reasonable access to your personal information within what is permitted by applicable law. Fees could apply in certain cases.

We may verify the identity of individuals seeking to access personal information. Any information provided for identification purposes will not be recorded nor used for any other purpose.

Junk Mail

We abide by the laws and regulations governing unwanted electronic communications. If you no longer wish to receive electronic communications from Keenoa, you may so advise us at any time in writing at the following address: privacy@keenoa.co.

We will continue to have the right to contact you about your orders, requests for information or in connection with the handling of your personal information.

Changes to this Policy

We may modify this Privacy Policy in order to reflect changes in our business and our handling of personal information. Where a modification is made, a new Privacy Policy will be posted on the Platform and should you continue to use the Platform, you will be bound by the new Privacy Policy.

Governing Law

The handling of personal information is governed by laws and regulations which may vary from jurisdiction to jurisdiction. This Privacy Policy as well as any associated operation is governed by the laws of the Province of Quebec and the laws of Canada applicable therein and shall be interpreted accordingly.

Any claim, dispute or complaint with respect to the subject matter of this Policy shall be brought before the competent authority of the Province of Quebec or Canada, sitting in the judicial district of Montreal, hereby excluding any other forum or jurisdiction.

Additional Information

For any additional information about our handling of personal information, please contact us at the following address: privacy@keenoa.co.