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Tuul Privacy Policy

Last Updated: May 1st, 2025

This Privacy Policy describes how Tuul Technologies Inc. (“tuul”, “we”, “us”, or “our”) handles personal information that we collect through our websites on which a link to this Privacy Policy is displayed, through our marketing initiatives, when you apply for a job with us, and in connection with other interactions with you (collectively, the “Service” or “Services”).

This Privacy Policy does not apply to our handling of personal information that we process on behalf of our customers. Our processing of that personal information is governed by the agreements we have with our customers.

Personal information we collect

Information you provide to us:

Information we obtain from third parties:

Automatic data collection:

We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our website, our communications and other online services, such as:

We use the following tools for automatic data collection:

How we use your personal information

Providing our Services. We use personal information to operate, maintain, and provide you with our Services.

To communicate with you. We use personal information to respond to your requests, provide customer support, and otherwise communicate with you about our Services, including by sending announcements, surveys, updates, security alerts, and support and administrative messages.

To improve, monitor, and personalize our Services. We use personal information to improve our Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We may use this data and disclose it to third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, and updates on news and events. You may opt out of our marketing emails as described in the “Opt out of marketing communications” section below.

For interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our website, our communications, and other online services, and use that information to serve online ads that they think will interest you.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend our company against legal claims or disputes, including to:

How we disclose your personal information

Affiliates We may disclose your personal information to our subsidiaries and affiliates for purposes consistent with this Privacy Policy.

Service providers. We may disclose your personal information to third party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, customer support, hosting, analytics, email delivery, marketing, and database management).

Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Advertising partners. Third party advertising companies, including for the interest-based advertising purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your privacy rights and choices

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions contained in the marketing communication we send you. You may continue to receive service-related and other non-marketing emails.

Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to the personal information we hold about you:

To make a request, please email us as provided in the “How to Contact Us” section below. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other sites, mobile applications and services

Our website may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Retention of personal information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Job applicants

When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information. We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn).

Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.

We use applicants' information to facilitate our recruitment activities, process employment applications and personalize candidate communication, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants' information to administer the employment relationship. We may also use and disclose applicants' information to improve our Services and for the compliance and protection purposes described above.

Children

Our website is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the website from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

How to contact us

Please direct any questions or comments about this Policy or our privacy practices to privacy@tuul.com