Security and Privacy: Terms of Use and Privacy Policy

TERMS OF USE AND PRIVACY POLICY

Effective Date: October 27, 2025
Last Updated: October 27, 2025

INTRODUCTION

These Terms of Use and Privacy Policy govern your use of SynergiMAX International / 9212-6093 QUEBEC INC. (hereinafter “SynergiMAX International / 9212-6093 QUEBEC INC.,” “we,” “us,” or “our”) psychometric assessment services and your access to the results derived from these assessments.

By using our services, you agree to our Terms of Use and Privacy Policy, adhering to GDPR and Law 25.

If you do not agree with any part of these terms, you must not use our services.

1. TERMS OF USE

1.1 Services Description

SynergiMAX International / 9212-6093 QUEBEC INC. offers psychometric assessments to evaluate psychological traits, skills, and abilities for personal and professional growth.

Disclaimer: Results are for informational and developmental purposes only and are not clinical diagnoses. For clinical services, consult a licensed mental health professional.

1.2 User Obligations

By using our services, you agree to:

• Provide accurate, truthful, and complete information when creating an account and completing assessments
• Respond honestly to assessment questions to ensure valid and reliable results
• Maintain the confidentiality and security of your account credentials
• Please notify us immediately of any unauthorized use of your account
• Not misuse our services or results for unlawful, fraudulent, discriminatory, or harmful purposes
• Do not attempt to reverse-engineer, copy, modify, or extract the underlying algorithms or assessment methodologies
• Do not share, sell, or distribute assessment content or results without proper authorization

1.3 Age Requirements

Our services are intended for individuals aged 16 years and older. If you are between 16 and 18 years old (or the age of majority in your jurisdiction), you must have parental or guardian consent to use our services. We do not knowingly collect personal data from children under 16 without verifiable parental consent.

1.4 Intellectual Property Rights

All content provided through our services—such as assessments, reports, graphics, logos, and software are the exclusive property of SynergiMAX International / 9212-6093 QUEBEC INC. and protected by law. You have a limited license to use the content for personal or internal purposes only. Unauthorized use, reproduction, or distribution is strictly prohibited and may lead to legal action.

1.5 Account Termination and Suspension

We reserve the right to suspend or terminate your access to our services at any time, with or without notice, if we reasonably believe you have violated these Terms of Use or engaged in fraudulent or illegal activity.

Upon termination:

• Your right to access and use the services immediately ceases
• You may request a copy of your personal data in accordance with Section 3.8 (Data Portability)
• We may retain specific data as required by law or legitimate business interests (see Section 2.7)

1.6 Limitation of Liability

To the maximum extent permitted by applicable law:

SynergiMAX International / 9212-6093 QUEBEC INC. is not liable for any direct, indirect, incidental, special, consequential, or punitive damages arising from:

• Your use of or inability to use our services
• Any errors, inaccuracies, or omissions in assessment results
• Decisions made based on assessment results
• Unauthorized access to or alteration of your data
• Any other matter relating to our services

The assessment results are for informational and developmental purposes only and should not serve as the only basis for important personal, professional, or organizational decisions. We strongly advise using our assessments alongside other evaluation methods and professional judgment.

In jurisdictions that do not allow the exclusion or limitation of certain types of liability, our liability is limited to the maximum extent permitted by law.

1.7 Indemnification

You agree to indemnify, defend, and hold harmless SynergiMAX International / 9212-6093 QUEBEC INC., its officers, directors, employees, agents, and partners from any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising from:

• Your violation of these Terms of Use
• Your misuse of our services or assessment results
• Your violation of any third-party rights
• Any breach of your representations and warranties

1.8 Changes to Terms of Use

SynergiMAX International / 9212-6093 QUEBEC INC. may change these Terms of Use at any time. We will notify users via email, website notice, or in-app alert. Changes take effect 30 days after notification, and continued use implies agreement. If you disagree, stop using our services and may request account deletion.

1.9 Governing Law and Dispute Resolution

These Terms of Use shall be governed by and construed in accordance with the laws of the Province of Quebec, Canada, without regard to its conflict of law provisions.

For users in the European Union, you retain the benefits of your country’s mandatory consumer protection laws.

Any disputes arising from these Terms of Use or your use of our services shall be resolved through:

1. Good faith negotiations between the parties
2. If talks fail, mediation under the rules of a mutually agreed mediator
3. If mediation fails, litigation in the competent courts of Quebec, Canada (or your local jurisdiction if you are an EU consumer)

2. PRIVACY POLICY

2.1 Data Controller Information

Data Controller:
SynergiMAX International / 9212-6093 QUEBEC INC.
Email: privacy@synergimax-international.com

EU Representative (if applicable):
Patrick Duperré (privacy@synergimax-international.com)

Data Protection Officer (DPO):
Email: privacy@synergimax-international.com

2.2 Scope and Applicability

This Privacy Policy applies to all personal data collected, processed, and stored by SynergiMAX International / 9212-6093 QUEBEC INC. through:

• Our website (synergimax-international.com)
• Our psychometric assessment platform
• Email communications
• Customer support interactions
• Any other services we provide

This policy explains what personal data we collect, why we collect it, how we use it, who we share it with, how long we retain it, and your rights regarding your personal data.

2.3 Personal Data We Collect

We collect and process the following categories of personal data:

2.3.1 Identity and Contact Information

• Full name
• Email address
• Phone number (if provided)
• Job title and organization (for B2B clients)
• Postal address (if applicable)
• Country of residence (if applicable)

2.3.2 Account and Authentication Data

• Username and password (encrypted)
• Account preferences and settings
• Security questions and answers (if applicable)
• Two-factor authentication data

2.3.3 Assessment Data

• Responses to psychometric assessment questions
• Assessment completion dates and times
• Assessment results, scores, and reports
• Behavioural and psychological trait data derived from assessments

2.3.4 Technical and Usage Data

• IP address
• Browser type and version
• Device type and operating system
• Cookies and similar tracking technologies (see Section 2.15)
• Pages visited, features used, and time spent on the platform
• Referral source and navigation paths
• Error logs and diagnostic data

2.3.5 Communication Data

• Records of correspondence with our support team
• Feedback and survey responses
• Marketing communication preferences

2.3.6 Payment Information (if applicable)

• Payment method details (processed securely through third-party payment processors)
• Billing address
• Transaction history

Special Categories of Personal Data:
Psychometric assessment data may be considered sensitive personal data under the GDPR (for revealing aspects of personality, cognitive abilities, or psychological traits) and Law 25. We process this data only with your explicit consent and implement additional security measures.

2.4 Legal Basis for Processing (GDPR)

We process your personal data based on the following legal grounds:

2.4.1 Consent (Article 6(1)(a) and 9(2)(a) GDPR)

• Processing of psychometric assessment data
• Marketing communications
• Non-essential cookies and analytics

You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

2.4.2 Contract Performance (Article 6(1)(b) GDPR)

• Creating and managing your account
• Delivering psychometric assessments and results
• Processing payments
• Providing customer support

2.4.3 Legal Obligation (Article 6(1)(c) GDPR)

• Compliance with tax and accounting requirements
• Responding to lawful requests from authorities
• Maintaining records as required by law

2.4.4 Legitimate Interests (Article 6(1)(f) GDPR)

• Improving our services and user experience
• Ensuring platform security and preventing fraud
• Conducting business analytics
• Enforcing our Terms of Use

When we rely on legitimate interests, we have conducted a balancing test to ensure that our interests do not override your fundamental rights and freedoms.

2.5 How We Use Your Personal Data

We use your personal data for the following purposes:

2.5.1 Service Delivery

• Administering psychometric assessments
• Generating and delivering assessment results and reports
• Managing your account and preferences
• Providing customer support and responding to inquiries

2.5.2 Service Improvement and Development

• Analyzing usage patterns to improve user experience
• Conducting research and development on assessment methodologies
• Testing new features and services
• Quality assurance and validation studies

2.5.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activity
• Ensuring platform security and integrity
• Investigating potential violations of our Terms of Use

2.5.4 Communication

• Sending transactional emails (e.g., account notifications, assessment results)
• Responding to your inquiries and support requests
• Sending marketing communications (with your consent, which may be withdrawn at any time)
• Conducting user satisfaction surveys

2.5.5 Legal Compliance

• Complying with applicable laws and regulations
• Responding to legal processes and government requests
• Enforcing our rights and protecting against legal liability

2.5.6 Anonymized Research and Statistics

• Creating anonymized and aggregated datasets for research purposes
• Publishing statistical analyses and industry benchmarks
• Sharing anonymized data with research partners (see Section 2.6)

Anonymization Process: When we anonymize data, we remove or transform all personally identifiable information so that the data cannot be linked back to you, even with additional information. Anonymized data is not considered personal data under GDPR or Law 25.

2.6 Data Sharing and Disclosure

We respect your privacy and do not sell your personal data to third parties. We share your personal data only in the following circumstances:

2.6.1 Service Providers and Processors

We engage trusted third-party service providers who process personal data on our behalf, including:

• Cloud hosting and data storage providers
• Email communication services
• Payment processors
• Customer support platforms
• Analytics and monitoring tools

All service providers are bound by data processing agreements that comply with GDPR Article 28 and Law 25 requirements, ensuring they:

• Process data only according to our documented instructions
• Implement appropriate security measures
• Maintain confidentiality
• Assist with fulfilling data subject rights
• Delete or return data upon termination of services

Current Key Service Providers:

• Email Services: Google & HubSpot
• Payment Processing: PayPal & Stripe

2.6.2 Corporate Clients (B2B Services)

If you access our services through your employer or organization, we may share your assessment results with designated representatives of that organization as per the contractual agreement. In such cases:

• Your organization is considered a joint controller or separate controller
• We provide you with specific notice about data sharing
• Your organization must have its own legal basis for processing your data
• You should review your organization’s privacy policy

2.6.3 Research Partners

We may share anonymized and aggregated data with academic institutions or research partners for:

• Validation studies
• Psychometric research
• Industry benchmarking

Anonymized data cannot be traced back to you and is not considered personal data.

2.6.4 Legal Requirements and Protection of Rights

We may disclose personal data when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with legal obligations, court orders, or governmental requests
• Enforce our Terms of Use or other agreements
• Protect the rights, property, or safety of SynergiMAX, our users, or the public
• Detect, prevent, or investigate fraud, security issues, or illegal activity

2.6.5 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal data may be transferred to the successor entity. We will notify you of such transfer and any choices you may have regarding your data.

2.6.6 With Your Consent

We may share your personal data with third parties when you have provided explicit consent for such sharing.

We do not share your personal data for third-party marketing purposes without your explicit opt-in consent.

2.7 Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law.

2.7.1 Retention Periods

Account and Identity Data:
Retained for the duration of your active account plus 12 months after account closure (unless earlier deletion is requested).

Assessment Data and Results:

• Active users: Retained for the duration of your account usage
• After account closure or deletion request: Retained for 30 days to allow recovery, then permanently deleted
• Anonymized assessment data: Retained indefinitely for research purposes (no longer linked to you)

Communication Records:
Retained for 24 months for customer service quality and legal purposes.

Technical and Usage Data:
Retained for 18 months for security, analytics, and service improvement.

Payment and Transaction Data:
Retained for 7 years to comply with tax and accounting legal requirements.

Legal Hold:
If your data is subject to legal proceedings, investigations, or regulatory requirements, we may retain it beyond the standard retention periods until the matter is resolved.

2.7.2 Deletion Procedures

Upon expiration of the retention period, we will:

• Permanently delete personal data from our active systems
• Remove personal data from backups during the next scheduled backup rotation (within 90 days)
• Anonymize data that will be retained for research purposes

You may request early deletion of your data by exercising your Right to Erasure (see Section 2.9.3).

2.8 International Data Transfers

SynergiMAX International / 9212-6093 QUEBEC INC. is located in Canada. If you are accessing our services from the European Union, European Economic Area, United Kingdom, or other jurisdictions with data protection laws, please be aware that your personal data may be transferred to, stored, and processed in Canada and other countries.

2.8.1 Transfers from the EU/EEA to Canada

For data transfers from the EU/EEA to Canada, we rely on the following safeguards:

Adequacy Decision:
The European Commission has recognized Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) as providing adequate protection for specific commercial organizations. SynergiMAX International / 9212-6093 QUEBEC INC. complies with PIPEDA for such transfers.

Standard Contractual Clauses (SCCs):
Where the adequacy decision does not apply, we use the European Commission’s Standard Contractual Clauses (Module 2: Controller to Processor) with our service providers and implement supplementary measures as needed to ensure adequate protection.

Explicit Consent:
In certain circumstances, we may rely on your explicit consent for data transfers.

2.8.2 Transfers to Other Third Countries

If we transfer your personal data to countries outside Canada and the EU/EEA that do not have an adequacy decision, we ensure appropriate safeguards through:

• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules (where applicable)
• Certification schemes such as Privacy Shield successor frameworks (when available)
• Your explicit consent

You have the right to request information about the safeguards we have implemented for international transfers and to obtain a copy of such safeguards (where reasonable and not commercially sensitive).

Data Storage Locations:
Our primary servers are located in: Canada
Backup servers are located in: Canada

2.9 Your Rights Under GDPR

If you are located in the European Union, European Economic Area, or the United Kingdom, you have the following rights regarding your personal data:

2.9.1 Right of Access (Article 15 GDPR)

You have the right to obtain:

• Confirmation of whether we process your personal data
• Access to your personal data
• Information about processing purposes, categories of data, recipients, retention periods, and your rights

How to exercise: Contact us at privacy@synergimax.com. We will respond within 30 days (extendable by 2 months for complex requests).

2.9.2 Right to Rectification (Article 16 GDPR)

You have the right to request correction of inaccurate or incomplete personal data.

How to exercise: You may update most information through your account settings or contact us at privacy@synergimax.com for assistance.

2.9.3 Right to Erasure / “Right to be Forgotten” (Article 17 GDPR)

You have the right to request deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed
• Deletion is required to comply with a legal obligation

Limitations: We may refuse deletion if processing is necessary for:

• Compliance with legal obligations
• Establishment, exercise, or defense of legal claims
• Archiving purposes in the public interest, scientific or historical research (with appropriate safeguards)

How to exercise: Contact us at privacy@synergimax.com. We will process your request within 30 days.

2.9.4 Right to Restriction of Processing (Article 18 GDPR)

You have the right to request that we restrict (but not delete) the processing of your personal data when:

• You contest the accuracy of the data (during verification)
• Processing is unlawful but you prefer restriction over deletion
• We no longer need the data, but you need it for legal claims
• You have objected to processing (pending verification of our legitimate grounds)

How to exercise: Contact us at privacy@synergimax-international.com.

2.9.5 Right to Data Portability (Article 20 GDPR)

You have the right to:

• Receive your personal data in a structured, commonly used, and machine-readable format (e.g., CSV, JSON)
• Transmit this data to another controller without hindrance

This right applies when:

• Processing is based on consent or contract
• Processing is carried out by automated means

How to exercise: Contact us at privacy@synergimax.com. We will provide your data within 30 days.

2.9.6 Right to Object (Article 21 GDPR)

You have the right to object to:

• Processing based on legitimate interests (including profiling)
• Direct marketing (including profiling for marketing purposes)
• Processing for scientific or historical research purposes (unless necessary for public interest tasks)

Direct Marketing: You may object at any time, and we will stop processing your data for such purposes immediately.

Legitimate Interests: We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for legal claims.

How to exercise: Contact us at privacy@synergimax.com or use the “unsubscribe” link in marketing emails.

2.9.7 Rights Related to Automated Decision-Making and Profiling (Article 22 GDPR)

You have the right not to be subject to decisions based solely on automated processing (including profiling) that produce legal effects or similarly significantly affect you.

Our Practice:
While our psychometric assessments use automated scoring algorithms, we do not make solely automated decisions with legal or similarly significant effects. Assessment results are intended as one input among many for decision-making, and we recommend human review and professional judgment.

If we were to engage in solely automated decision-making, we would:

• Obtain your explicit consent
• Implement suitable safeguards, including the right to human intervention
• Provide meaningful information about the logic involved

2.9.8 How to Exercise Your Rights

To exercise any of your GDPR rights:

1. Email: privacy@synergimax.com or dpo@synergimax.com
2. Subject Line: Include “GDPR Rights Request” and specify the right you wish to exercise
3. Information Required: Provide sufficient information to verify your identity (name, email address, account details)
4. Response Time: We will respond within 30 days (extendable by 2 months for complex requests with notification)
5. Free of Charge: Exercising your rights is generally free, unless requests are manifestly unfounded or excessive

Identity Verification: To protect your privacy, we may request additional information to verify your identity before processing your request.

2.10 Your Rights Under Quebec Law 25

If you are a resident of Quebec, you have additional rights under Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25), which include:

2.10.1 Right to Access (Section 27)

You have the right to:

• Access your personal information held by us
• Receive a copy of your personal information
• Obtain information about the use made of your personal information and any third parties to whom it has been disclosed

How to exercise: Contact us at privacy@synergimax-international.com. We will respond within 30 days.

2.10.2 Right to Rectification (Section 28)

You have the right to request correction of inaccurate, incomplete, or outdated personal information.

Our Obligation: We will correct the information and notify any third parties to whom we disclosed the incorrect information (within the previous year), unless you request otherwise.

2.10.3 Right to Withdrawal of Consent (Section 14)

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions.

Consequences: We will inform you of the consequences of withdrawing consent, which may include our inability to provide certain services.

2.10.4 Right to Portability (Section 27.1)

You have the right to:

• Receive your personal information in a structured, commonly used technological format.
• Request that we transmit your information directly to another organization (where technically feasible)

How to exercise: Contact us at privacy@synergimax-international.com.

2.10.5 Right to De-indexing (Section 28.1)

You have the right to request that we cease disseminating your personal information through technological means, allowing it to be located via a search function (e.g., search engines), in certain circumstances.

2.10.6 Rights Regarding Automated Decision-Making (Section 12.1)

You have the right:

• To be informed when a decision about you is made exclusively through automated processing
• To obtain information about the personal information used for the decision
• To obtain information about the reasons and principal factors behind the decision
• To request that a person review the decision

Our Commitment: We will inform you when automated decision-making affects you and provide the above information upon request.

2.10.7 Right to Anonymization or Destruction (upon death)

Your successors or heirs may request that we:

• Anonymize your personal information
• Destroy your personal information
• Limit the communication of your personal information

2.10.8 How to Exercise Your Law 25 Rights

To exercise your Quebec Law 25 rights:

1. Email: privacy@synergimaxinternational.com
2. Subject Line: Include “Law 25 Rights Request” and specify the right you wish to exercise
3. Response Time: We will respond within 30 days or inform you of any extension (maximum 90 days total)
4. Free of Charge: Services are provided free of charge, except in cases of manifestly unfounded or excessive requests

2.11 Consent Management

2.11.1 Explicit Consent for Sensitive Data

Given that psychometric assessment data may be considered sensitive personal information, we obtain your explicit, informed consent before collecting and processing such data.

Your consent includes agreement to:

• Complete psychometric assessments
• Allow us to process your responses and generate results
• Store your assessment data for the purposes outlined in this policy
• Use anonymized data for research and statistical purposes

2.11.2 Consent for Marketing Communications

We will only send you marketing communications if you have provided consent by:

• Opting in during account registration
• Subscribing through our website
• Expressing interest in our services

You may withdraw consent at any time by:

• Clicking “unsubscribe” in any marketing email
• Updating your preferences in your account settings
• Contacting us at privacy@synergimaxinternational.com

2.11.3 Consent for Non-Essential Cookies

We obtain your consent before placing non-essential cookies on your device. You may manage your cookie preferences through our Cookie Consent Manager or browser settings (see Section 2.15).

2.11.4 Withdrawal of Consent

You may withdraw your consent at any time by contacting us at privacy@synergimax.com. Withdrawal of consent:

• Does not affect the lawfulness of processing based on consent before withdrawal
• May impact our ability to provide certain services
• Will be processed within 30 days

We will clearly inform you of the consequences of withdrawing consent.

2.12 Security Measures

We implement comprehensive technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, destruction, loss, or misuse.

2.12.1 Technical Security Measures

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Role-based access controls (RBAC) ensure that only authorized personnel can access personal data on a need-to-know basis.
• Authentication: Strong password requirements, optional two-factor authentication (2FA), and secure session management.
• Firewall and Intrusion Detection: Enterprise-grade firewalls and intrusion detection/prevention systems (IDS/IPS) monitor and protect our infrastructure.
• Regular Security Testing: Penetration testing, vulnerability assessments, and security audits are conducted at least annually.
• Secure Development: Security-by-design principles, secure coding practices, and code reviews.
• Data Minimization by Design: Systems designed to collect only necessary data and automatically purge data after retention periods.

2.12.2 Organizational Security Measures

• Employee Training: All employees receive data protection and security training, including GDPR and Law 25 requirements.
• Confidentiality Agreements: All employees and contractors sign confidentiality and non-disclosure agreements.
• Data Protection Policies: Comprehensive internal policies governing data handling, access, and security.
• Incident Response Plan: Documented procedures for detecting, responding to, and recovering from security incidents.
• Vendor Management: Due diligence and security assessments of third-party service providers, with appropriate data processing agreements.
• Regular Audits: Internal and external audits to ensure compliance with security standards and data protection regulations.

2.12.3 Data Breach Notification

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms:

GDPR Requirements (EU/EEA residents):

• We will notify the relevant supervisory authority within 72 hours of becoming aware of the breach
• We will notify affected individuals without undue delay if the breach poses a high risk
• Notification will include the nature of the breach, likely consequences, and measures taken or proposed

Law 25 Requirements (Quebec residents):

• We will notify the Commission d’accès à l’information (CAI) of any incident involving a confidentiality breach that poses a risk of serious injury
• We will notify affected individuals if the breach poses a risk of serious injury
• We will maintain a register of confidentiality incidents

Our Commitment: We will act swiftly and transparently in the event of any security incident affecting your data.

2.13 Children’s Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16 without verifiable parental or guardian consent.

If you are between 16 and 18 years old (or under the age of majority in your jurisdiction), you must obtain consent from your parent or legal guardian before using our services.

If we discover that we have collected personal data from a child under 16 without proper consent, we will take steps to delete that information as quickly as possible.

Parents and Guardians: If you believe your child has provided us with personal data without consent, please contact us immediately at privacy@synergimax.com, and we will delete the information.

2.14 Third-Party Links and Services

Our website or platform may contain links to third-party websites, plugins, or services that are not operated by SynergiMAX International / 9212-6093 QUEBEC INC.

We are not responsible for the privacy practices or content of these third-party sites. When you leave our platform, we encourage you to review the privacy policy of any third-party site you visit.

Third-Party Integrations:
If you choose to connect your SynergiMAX International / 9212-6093 QUEBEC INC. account with third-party services (e.g., single sign-on providers, calendar integrations), those services will have access to certain information as authorized by you. Please review their privacy policies.

2.15 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver personalized content.

2.15.1 Types of Cookies We Use

Strictly Necessary Cookies:
Essential for the operation of our platform (e.g., authentication, security, load balancing). These cookies cannot be disabled.

Functional Cookies:
Remember your preferences and choices (e.g., language, region) to provide enhanced functionality.

Performance and Analytics Cookies:
Collect information about how you use our platform (e.g., pages visited, errors encountered) to help us improve performance and user experience. We use [specify: e.g., Google Analytics, Matomo].

Marketing and Targeting Cookies:
Track your browsing activity to deliver relevant advertisements and measure campaign effectiveness. Used only with your consent.

2.15.2 Managing Cookies

You can control and manage cookies through:

• Cookie Consent Manager: Available on our website when you first visit
• Browser Settings: Most browsers allow you to refuse cookies or delete existing cookies
• Opt-Out Tools: For analytics cookies, you may use browser extensions or opt-out features provided by analytics services

Note: Disabling certain cookies may impact the functionality of our services.

2.15.3 Do Not Track Signals

Currently, our platform does not respond to “Do Not Track” (DNT) browser signals, as there is no industry-wide standard for DNT implementation. We will update this policy if standards are adopted.

2.16 California Privacy Rights (CCPA) – If Applicable

While SynergiMAX International / 9212-6093 QUEBEC INC. is based in Canada, if we serve California residents, we comply with the California Consumer Privacy Act (CCPA) where applicable. California residents have rights similar to those under the GDPR, including the right to know, delete, opt out of the sale (note: we do not sell personal information), and not be discriminated against.

For more information on CCPA rights, California residents may contact us at privacy@synergimaxinternational.com.

2.17 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or services.

When we make material changes, we will:

• Update the “Last Updated” date at the top of this policy
• Notify you via email (if you have an account)
• Display a prominent notice on our website or platform
• Request your renewed consent if required by law

Changes become effective 30 days after notification, unless a longer period is required by law. We encourage you to review this policy periodically.

Your continued use of our services after the effective date constitutes acceptance of the updated policy. If you do not agree to the changes, you may close your account and request deletion of your data.

2.18 Supervisory Authorities and Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority:

2.18.1 European Union / EEA Residents

You may lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement.

List of EU Data Protection Authorities:
https://edpb.europa.eu/about-edpb/board/members_en

Example:

• France: Commission nationale de l’Informatique et des libertés (CNIL)
• Germany: Federal Commissioner for Data Protection and Freedom of Information
• Ireland: Data Protection Commission

2.18.2 Quebec Residents

Commission d’accès à l’information du Québec (CAI)
Phone: 1-888-528-7741 (toll-free in Quebec)
Phone: 418-528-7741 (Quebec City area)
Email: acces.information@cai.gouv.qc.ca
Website: https://www.cai.gouv.qc.ca/

Mailing Address:
Commission d’accès à l’information du Québec
525, boul. René-Lévesque Est, bureau 1.20
Québec (Québec) G1R 5S9

2.18.3 Canadian Residents (Outside Quebec)

Office of the Privacy Commissioner of Canada
Phone: 1-800-282-1376 (toll-free in Canada)
Email: info@priv.gc.ca
Website: https://www.priv.gc.ca/

We encourage you to contact us first at privacy@synergimax-international.com so we may address your concerns directly. However, you have the right to complain to a supervisory authority at any time.

3. CONTACT INFORMATION

For any questions, concerns, or requests regarding these Terms of Use or Privacy Policy, or to exercise your data protection rights, please contact us:

SynergiMAX International / 9212-6093 QUEBEC INC.

General Inquiries:
Email: info@synergimax.com
Website: https://synergimax-international.com

Privacy and Data Protection Inquiries:
Email: privacy@synergimax.com

Data Protection Officer:
Email: privacy@synergimax-international.com

Mailing Address:
905 Ste-Croix Avenue, Suite 304
Saint-Laurent, Quebec H4L 5N9
Canada

4. ACKNOWLEDGMENT AND CONSENT

By clicking “I Accept” or “I Agree,” by creating an account, or by using SynergiMAX International / 9212-6093 QUEBEC INC.’s psychometric assessment services, you acknowledge that you have:

1. Read and understood these Terms of Use and Privacy Policy in their entirety
2. Understood how we collect, use, disclose, and protect your personal data
3. Been informed of your rights under GDPR (if applicable) and Quebec Law 25 (if applicable)
4. Understood the purposes for which your data will be processed
5. Provided explicit consent for the processing of sensitive personal data (psychometric assessment responses and results)
6. Agreed to be bound by these terms

For users between 16 and 18 years old: By using our services, you confirm that you have obtained consent from your parent or legal guardian.

You may withdraw your consent or close your account at any time by contacting us at privacy@synergimax-international.com.

Thank you for choosing SynergiMAX International. We are committed to protecting your privacy and providing you with valuable psychometric insights.