Privacy Policy

Last updated: June 2025

In accordance with Quebec's Law 25, we have designated a person responsible for the protection of personal information within our organization. If you are located in Quebec and have questions or concerns regarding the way your personal data is collected, used, or stored, you may contact our Privacy Officer directly.

Name: Annie Drouin
Email: hr@simbol.ca
Address: 616 Rue Auguste-Mondoux, Gatineau, QC, Canada

Under Law 25, Quebec residents have enhanced rights to:

• Access, rectify, or delete personal information held about them
• Be informed of how their data is collected and used
• Withdraw consent for the use of their personal data
• Request that their personal information cease to be disseminated or be de-indexed

If your personal information is used to make decisions based on automated processing, you have the right to request explanations and contest those decisions.

We retain personal information only as long as necessary to fulfill the purposes for which it was collected. When no longer required, data is securely destroyed or anonymized in accordance with our internal retention policy.

Our organization applies appropriate technological and organizational security measures, such as encryption, access controls, and audit trails, to protect personal information from unauthorized access or disclosure.

If a confidentiality incident occurs that presents a risk of serious injury, we will notify the Commission d'accès à l'information (CAI) and affected individuals as required by law.

Please note that some data may be processed or stored outside Quebec, including in jurisdictions such as the United States. In such cases, we ensure adequate protection measures and contractual safeguards are in place.

If you wish to exercise your rights under Law 25, please complete our request form at https://simbol.ca/form/contact-us-g3.html.

This section outlines additional rights and information for residents of jurisdictions with specific data protection laws beyond Canada and Quebec.

United States (CCPA/CPRA – California Residents):

• Right to know what personal data we collect, disclose, or sell
• Right to request deletion of your personal data
• Right to opt-out of the sale or sharing of your personal data
• Right to non-discrimination for exercising these rights

To make a request, please email hr@simbol.ca.

Brazil (LGPD): You have the right to access, correct, delete, or restrict the use of your personal data. You may also withdraw consent at any time.

European Union & United Kingdom (GDPR/UK GDPR): Rights include data portability, the right to object to processing, and the right to lodge a complaint with a supervisory authority.

Australia (Privacy Act): We adhere to the Australian Privacy Principles (APPs), including disclosure of overseas data storage and ensuring consent before marketing.

South Africa (POPIA): We collect and use personal data lawfully and transparently and provide access to your data upon request.

China (PIPL): We only process personal data of Chinese residents with express consent, and data is stored in accordance with cross-border requirements.

If you are a resident in any of these regions and want to exercise your data protection rights, contact us at hr@simbol.ca.

This privacy notice for Simbol Test Systems Inc. (doing business as AssetRelay, PhotonCom) ("we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Visit our website at https://simbol.ca, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hr@simbol.ca.

Summary of Key Points

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by visiting https://simbol.ca/form/contact-us-g3.html, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• company
• shipping addresses
• products or services purchased

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://simbol.ca/content/9-cookie-policy.

The information we collect includes:

• Log and Usage Data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
• Device Data. Information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. Information about your device's location, which can be either precise or imprecise depending on the type and settings of the device you use.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries / offer support to users. We may process your information to respond to your inquiries and solve any issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any offerings that allow communication with another user.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On to Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. We may rely on the following legal bases:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when necessary to fulfill our contractual obligations to you.
• Legal Obligations. We may process your information where necessary for compliance with our legal obligations.
• Vital Interests. We may process your information where necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for investigations, fraud prevention, business transactions, legal compliance, and other circumstances permitted by law.

4. When and With Whom Do We Share Your Personal Information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work.

• Website Hosting Service Providers
• Ad Networks
• Payment Processors

We may also share or transfer your information in connection with business transfers such as a merger, sale of company assets, financing, or acquisition.

When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out, visit https://tools.google.com/dlpage/gaoptout. For more information, visit the Google Privacy & Terms page.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://simbol.ca/content/9-cookie-policy.

6. Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Canada. If you are accessing our Services from outside Canada, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by third parties with whom we may share your personal information, including in the United States and other countries.

If you are a resident in the EEA, UK, or Switzerland, these countries may not necessarily have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or securely store and isolate it until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission or storage technology can be guaranteed to be 100% secure.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

10. What Are Your Privacy Rights?

In Short: In some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

Depending on your region, these rights may include access, correction, deletion, restriction, portability, objection to processing, and not being subject to automated decision-making. You can make such a request by using the contact details provided below.

Withdrawing your consent: If we are relying on your consent, you have the right to withdraw it at any time by contacting us.

Cookies and similar technologies: Most browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies. For further information, please see our Cookie Notice: https://simbol.ca/content/9-cookie-policy.

If you have questions or comments about your privacy rights, you may email us at hr@simbol.ca.

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to them.

12. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or as long as required for legitimate business and legal purposes.

We may also collect other personal information outside of these categories in the context of customer support, surveys or contests, and service delivery or inquiries.

How do we use and share your personal information? Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through targeting cookies / marketing cookies.

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.

We may use your personal information for our own business purposes, such as internal research for technological development and demonstration. This is not considered "selling" of your personal information.

The categories of third parties to whom we disclosed or shared personal information can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

The categories of third parties to whom we shared personal information may include:

• Ad Networks
• Data Analytics Services

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request information about categories of personal information disclosed to third parties for direct marketing purposes in the immediately preceding calendar year.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you may request removal of unwanted data that you publicly post on the Services.

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have specific privacy rights.

Those rights may include the right to request deletion, the right to know, and the right to non-discrimination for exercising privacy rights.

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information, subject to certain legal exceptions.

Right to be informed — Request to know

Depending on the circumstances, you may have a right to know whether we collect and use your personal information, the categories we collect, the purposes for use, whether we sell or share it, and the categories of third parties involved.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant.
• You can designate an authorized agent to make a request under the CCPA on your behalf.

You can opt out from the selling or sharing of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage.

To exercise these rights, you can contact us by visiting https://simbol.ca/form/contact-us-g3.html, by email at hr@simbol.ca, or by referring to the contact details at the bottom of this document.

Colorado Residents

Under the Colorado Privacy Act (CPA), Colorado residents may have rights including access, correction, deletion, data portability, and opt-out rights for targeted advertising, sale of personal data, or profiling.

Connecticut Residents

Under the Connecticut Data Privacy Act (CTDPA), Connecticut residents may have rights including access, correction, deletion, portability, and opt-out rights for targeted advertising, sale of personal data, or profiling.

Utah Residents

Under the Utah Consumer Privacy Act (UCPA), Utah residents may have rights including access, deletion, portability, and opt-out rights for targeted advertising or sale of personal data.

Virginia Residents

Under the Virginia Consumer Data Protection Act (VCDPA), Virginia residents may have rights including access, correction, deletion, portability, and opt-out rights for targeted advertising, sale of personal data, or profiling.

You can opt out of the selling of your personal data, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings or by contacting us at hr@simbol.ca.

13. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020.

At any time, you have the right to request access to or correction of your personal information. You can make such a request by using the contact details provided below.

If you believe we are unlawfully processing your personal information, you may submit a complaint to the relevant regulator, including the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with how we address your complaint, you may contact the Information Regulator (South Africa).

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints: PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

14. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and will be effective as soon as it is accessible.

15. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at hr@simbol.ca or contact us by post at:

Simbol Test Systems Inc.
616 Rue Auguste Mondoux
Gatineau, Quebec J9J3K3
Canada

16. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: https://simbol.ca/form/contact-us-g3.html.

Questions About This Privacy Notice?

If you have questions or comments about this notice or our privacy practices, please contact our Privacy Officer.

Annie Drouin serves as our Privacy Officer and can be reached at hr@simbol.ca.