Privacy Policy

Introduction

17581602 CANADA INC., operating as Sphera Credit ("we", "us", "our"), is committed to protecting the privacy of individuals who visit our website at spheracredit.com, use our calculators, or interact with our platform (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec's Act respecting the protection of personal information in the private sector (Loi 25).

Information we collect

We collect the following categories of personal information:

• Identity information: name, email address, phone number, job title, company name
• Account information: login credentials, account preferences, communication history
• Financial information: information related to lending decisions submitted through our platform by financial institution clients
• Usage data: pages visited, features used, session duration, referring URLs, browser type, device type, operating system, IP address
• Location data: approximate geographic location derived from your IP address
• Cookies and tracking: data collected through cookies, Google Analytics (GA4), Google Tag Manager, and Vercel Analytics
• Communications: messages you send to us through contact forms, email, or support channels

How we collect information

We collect personal information through three methods:

• Directly from you: when you fill out forms, create an account, request a demo, use our calculators, or contact us
• Automatically: through cookies, analytics tools, and server logs when you browse our website
• From third parties: from business partners, financial institution clients, and service providers who integrate with our platform

How we use your information

We use your personal information for the following purposes:

• Providing and operating our Services, including our AI-powered credit underwriting platform and free financial calculators
• Processing and responding to your inquiries and requests
• Improving, personalizing, and developing our products and services
• Analyzing website usage patterns to optimize user experience
• Sending service-related communications and, with your consent, marketing communications
• Detecting, preventing, and addressing security incidents and fraud
• Complying with legal obligations and enforcing our terms of service

Data sharing and disclosure

We may share your personal information with the following categories of recipients:

• Service providers: hosting providers, analytics services (Google Analytics, Vercel), email services, and other vendors who assist in operating our Services
• Financial institution clients: when you interact with our platform through a financial institution that uses our services
• Business partners: companies with whom we collaborate to provide or enhance our Services
• Legal and regulatory authorities: when required by law, regulation, legal process, or enforceable government request
• Corporate transactions: in connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as a business asset

International data transfers

Your personal information may be processed and stored in Canada and, in some cases, in other jurisdictions where our service providers operate. When we transfer data outside of Canada, we ensure appropriate safeguards are in place to protect your information in accordance with PIPEDA requirements.

Data retention

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. Calculator usage data is anonymized and does not identify individual users. Account data is retained for the duration of your account and for a reasonable period thereafter.

Your privacy rights

Under PIPEDA and Quebec's Loi 25, you have the right to:

• Access: request a copy of the personal information we hold about you
• Correction: request that inaccurate or incomplete personal information be corrected
• Withdrawal of consent: withdraw your consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions
• Deletion: request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected
• Data portability: request your personal information in a structured, commonly used, and machine-readable format (effective under Loi 25)
• Complaint: file a complaint with the Office of the Privacy Commissioner of Canada or the Commission d'acces a l'information du Quebec

To exercise any of these rights, contact us at support@spheracredit.com. We will respond within 30 days.

Cookies and tracking technologies

We use cookies and similar tracking technologies to collect usage data and improve our Services. Specifically:

• Google Analytics (GA4): analyzes website traffic and usage patterns
• Google Tag Manager: manages tracking scripts on our website
• Vercel Analytics and Speed Insights: monitors website performance and loading times
• Essential cookies: required for basic website functionality

You can manage cookie preferences through your browser settings. Disabling cookies may affect website functionality.

Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS), access controls, and regular security reviews. No system is completely secure, and we cannot guarantee the absolute security of your information.

Children's privacy

Our Services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete it promptly.

Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website with a revised "Last updated" date. Your continued use of our Services after changes are posted constitutes your acceptance of the revised policy.

Contact us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us at:

17581602 CANADA INC. (operating as Sphera Credit) Toronto, Ontario, Canada Email: support@spheracredit.com