Privacy Policy

At Corum Digital Corporation (“Corum Digital”), we are committed to safeguarding the privacy of our customers. This Privacy Policy applies to all of the products, services, and websites offered by Corum Digital or its subsidiaries or affiliated companies (collectively, Corum Digital's “services”).

For any questions or concerns regarding this Privacy Policy or Corum Digital's treatment of personal information, please contact us using the information found in the “How To Contact Us” section below.

EFFECTIVE DATE This policy is effective as of January 1, 2025.

DEFINITIONS Following terms used in this Privacy Policy are defined as follows:

• Personal Data: Any information (including opinions and intentions) which relates to an Individual Person.
• Individual Person: Anyone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier.
• Data Controller: A natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
• Data Provider: The identified or Individual Person to which the Personal Data refers.
• Data Protection: The process of safeguarding Personal Data from unauthorized or unlawful disclosure, access, alteration, Processing, transfer, or destruction.
• Third Party: An external organization with which Corum Digital conducts business and is also authorized to, under the direct authority of Corum Digital, Process the Personal Data of a Corum Digital customer, whether past, current, or prospective.
• Process(ed)(ing): Any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means. Operations performed may include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• Consent: Any freely given, specific, informed, and unambiguous indication of the Data Provider's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him or her.

INFORMATION WE COLLECT In order to provide our range of services, we may collect one or more of the following types of information:

• Account Information: When you sign up for a Corum Digital Account or other Corum Digital service or promotion that requires registration, you will be asked to provide your personal information (such as your name, email address, and an account password). For certain services, we may also request credit card or other payment account information.
• Cookies: When you visit Corum Digital or one of its associated websites, we send one or more cookies, which is a small file containing a string of characters, to your computer that uniquely identifies your browser. We use cookies to improve the quality of our service by storing user preferences and tracking user trends.
• Log Information: When you access Corum Digital services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.
• Individual Communications: When you send email or other communications to Corum Digital, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.
• Information Collected for SMS Communications: When you voluntarily provide your phone number through our website or other registration methods, we collect this information to facilitate SMS communications. This includes sending appointment reminders, service updates, troubleshooting instructions, system downtime notifications, and, with explicit consent, marketing messages.

Explicit Consent Consent is explicitly obtained at the time you provide your phone number, such as through online forms, service agreements, or subscription confirmation texts. By opting in, you acknowledge that you understand and agree to receive SMS communications in accordance with this Privacy Policy.

We use phone numbers solely for the purposes described and in accordance with applicable laws and regulations. You can opt out of receiving SMS communications at any time by replying "STOP" to any SMS message.

DATA SOURCES We collect Personal Data only from the Data Provider unless the nature of the business purpose necessitates collection of the Personal Data from other persons or bodies. For example, registry of a group of users for access to our systems.

HOW WE USE THE COLLECTED INFORMATION Corum Digital only processes personal information for the purposes described in this Privacy Policy, which includes maintaining general business operation and administration of Corum Digital entities, providing services to Corum Digital customers, providing ongoing administration and management of customer services, and developing and improving Corum Digital products and services.

We Process Personal Data in accordance with all applicable laws and contractual obligations. More specifically, we will only Process Personal Data for at least one of the following requirements:

• The Data Provider has given Consent to the Processing of their Personal Data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the Data Provider is a party, or in order to take steps at the request of the Data Provider prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
• Processing is necessary in order to protect the vital interests of the Data Provider or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a Third Party (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Provider, in particular where the Data Provider is a child).

There may be some circumstances in which Personal Data may be further processed for purposes that go beyond the original purpose for which the Personal Data was collected. In these circumstances, we will determine the fairness and transparency of any Processing beyond the original purpose by considering the relationship between the purpose for which the Personal Data was collected and the reasons for intended further Processing, as well as the context in which the Personal Data has been collected, in particular regarding the relationship between Data Provider and the Data Controller, and finally the existence of appropriate safeguards pertaining to further Processing, which may include encryption, anonymization, or pseudonymization.

Standard Messaging Disclaimers for SMS Communications For SMS communications, you will receive up to 4 messages per month depending on the type of communication. Standard message and data rates may apply as determined by your mobile carrier. These rates are your responsibility, and Corum Digital is not liable for any additional charges incurred.

We strive to ensure that SMS communications are clear, concise, and limited to the purposes you have consented to, such as appointment reminders, service updates, troubleshooting, and marketing messages where consent has been explicitly provided.

INFORMATION SHARING Corum Digital only shares personal information with other companies or individuals outside of Corum Digital in the following limited circumstances:

• With Your Consent: We may share your personal information when we have your explicit consent to do so.
• With Third-Party Service Providers: We may share personal information with subsidiaries, affiliated companies, or other trusted businesses or persons to process personal information on our behalf. We require these parties to agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
• For Legal Reasons: We may share personal information if we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect against imminent harm to the rights, property, or safety of Corum Digital, its users, or the public as required or permitted by law.
• Opting Into and Out of SMS Communications: By providing your phone number during registration or through other forms, you consent to receive SMS messages from us. You will receive up to 4 messages per month, depending on the services you subscribe to. If you no longer wish to receive these messages, you can opt out at any time by replying "STOP" to any SMS message you receive from us. Alternatively, you can contact us at privacyofficer@corumdigital.com to request removal. As part of the opt-in process, users are provided with a link to this Privacy Policy to ensure they have access to all relevant information about how their data will be used before subscribing to SMS communications.
• Managing SMS Preferences: In addition to replying "STOP" to an SMS message, you may also update your preferences by contacting us directly at 1-800-561-7525 or through our support@corumdigital.com. Our support team will ensure your preferences are updated promptly.

We do not share SMS opt-in data or phone numbers collected for SMS communications with any third parties or affiliate companies for marketing purposes. Phone numbers provided for SMS communications are used solely for the purposes outlined in this Privacy Policy.

If Corum Digital becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred if it becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information. Such information does not identify you individually.

Aggregated and Anonymized Data We may share aggregated or anonymized data, such as statistical data about website usage or service performance, with third parties. This data does not contain information that identifies you as an individual and is used for purposes such as improving our services, conducting research, or analyzing trends.

International Data Transfers Personal data collected may be transferred to, and stored and processed in, countries other than your own. These countries may have data protection laws that differ from those in your jurisdiction. When we transfer personal data across borders, we take steps to ensure it is treated securely and in accordance with this Privacy Policy and applicable laws.

Please contact us using the information in the “How To Contact Us” section below for any additional questions about the management or use of personal data.

OBTAINING INFORMATION ABOUT YOUR PERSONAL DATA You are entitled to obtain, based upon a request made in writing and upon successful verification of your identity, the following information about your Personal Data:

• The purposes of the collection, Processing, use, and storage of your Personal Data;
• The source(s) of the Personal Data, if it was not obtained from the Data Provider;
• The anticipated period of storage for the Personal Data.

Data Providers shall also have the right to require Corum Digital to correct or supplement erroneous, misleading, outdated, or incomplete Personal Data.

To request access to your data or request a correction, please submit your request in writing using the information found in the “How To Contact Us” section below.

Your Rights Related to SMS Communications You have the right to:

• Request access to the data we have collected for SMS communications;
• Request correction or deletion of your phone number from our SMS databases;
• Revoke your consent to receive SMS messages at any time. To do so, reply "STOP" to any SMS message you receive from us or contact us directly at privacyofficer@corumdigital.com.

LAW ENFORCEMENT REQUESTS AND DISCLOSURES If requested by law enforcement agencies or judicial courts, Personal Data may be shared without the knowledge or Consent of a Data Provider. This is the case where the disclosure of the Personal Data is necessary for the prevention or detection of crime, the apprehension or prosecution of offenders, the assessment or collection of a tax or duty, or by the order of a court or by any rule of law.

If we Process Personal Data for one of these purposes, then it may apply an exception to the Processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question.

CHANGES TO THIS PRIVACY POLICY Please note that this Privacy Policy may change from time to time and as such, we will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice. Each version of this Privacy Policy will be identified at the top of the page by its effective date.

If there are significant changes to our SMS communication practices, we will update this privacy policy and notify you where appropriate. Your continued use of our services indicates your acceptance of any changes.

HOW TO CONTACT US

Accessibility We are committed to making our privacy policy accessible to all individuals. If you require this Privacy Policy in an alternative format, please contact us using the details in the “How To Contact Us” section below.

For any questions or concerns regarding this Privacy Policy or Corum Digital's treatment of personal information, please contact us at privacyofficer@corumdigital.com or write to us at:

Corum Digital Corporation 2501 Rutherford Road, Unit #33 Concord, Ontario L4K 2N6 Canada Attn: Privacy Officer.