Cookie Policy

1. COMPANY INFORMATION

This Cookie Policy (“Policy”) is provided by The Rajma Company Inc., a corporation incorporated under the laws of Ontario, Canada, with its principal place of business at 20 Bruyeres Mews, Suite 2712, Toronto, Ontario, M5V 0G8 (“Company,” “we,” “us,” or “our”).

This Policy applies to the website located at Psyfiapp.com and all associated subdomains (collectively, the “Website”).

2. INTRODUCTION AND SCOPE

2.1 Purpose of This Policy

This Cookie Policy explains how The Rajma Company Inc., as a provider of fintech services focused on spend tracking and financial wellness tools, uses cookies and similar technologies to recognize, track, and analyze your online activities when you visit our Website. This Policy should be read in conjunction with our Privacy Policy, which provides more detailed information about how we collect, use, and protect your personal information.

2.2 What Are Cookies?

Cookies are small text files that are placed on your computer, smartphone, tablet, or other device when you visit a website. They allow the website to recognize your device and remember certain information about your visit, such as your preferences and actions on the site. Cookies are widely used to make websites work more efficiently and provide valuable information to website owners.

2.3 Application of Canadian Privacy Laws

Our use of cookies is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5, and other applicable Canadian privacy laws. Under PIPEDA, information collected through cookies, including IP addresses, device identifiers, browsing patterns, and other online identifiers, may constitute personal information when it can be linked to an identifiable individual.

2.4 Scope of This Policy

This Policy covers all pages on our Website and applies to all users who access our Website, regardless of location. However, users accessing our Website from outside Canada may be subject to additional or different privacy laws in their jurisdiction.

3. DEFINITIONS

For the purposes of this Cookie Policy, the following terms shall have the meanings set forth below:

3.1 “Cookie”

A small text file placed on a user’s device that contains information that can be retrieved by the website that placed it or by third parties. Cookies are subject to regulation under Canada’s Anti-Spam Law (CASL), S.C. 2010, c. 23, which governs the installation of computer programs, including cookies, on users’ devices.

3.2 “First-Party Cookies”

Cookies that are set by our Website domain (psyfiapp.com) directly.

3.3 “Third-Party Cookies”

Cookies that are set by domains other than our Website domain, such as those belonging to our analytics providers, advertising partners, or social media platforms.

3.4 “Session Cookies”

Temporary cookies that are deleted when you close your browser.

3.5 “Persistent Cookies”

Cookies that remain on your device for a specified period or until you delete them manually.

3.6 “Essential Cookies”

Cookies that are necessary for the basic functionality of our Website, such as those that enable you to log in, use a shopping cart, or make use of e-billing services.

3.7 “Preference Cookies”

Cookies that remember your choices and preferences on our Website, such as language preferences or region selection.

3.8 “Analytics Cookies”

Cookies that collect information about how you use our Website, such as which pages you visit most often and if you receive error messages.

3.9 “Marketing/Advertising Cookies”

Cookies that track your browsing habits and are used to deliver targeted advertising that is relevant to your interests.

3.10 “Web Beacons”

Small transparent image files used to track your movements on websites, also known as “pixels” or “clear gifs.”

3.11 “Local Storage Objects”

Technologies such as HTML5 local storage and Flash cookies that store information on your device in a manner similar to cookies but can store more information and can be persistent.

3.12 “Device Fingerprinting”

The process of collecting and analyzing information about your device, such as your browser type, operating system, installed plugins, and other settings, to create a unique profile that can be used to identify you.

4. TYPES OF COOKIES WE USE

In accordance with the Office of the Privacy Commissioner of Canada’s guidance that information about cookies should not be “buried in a privacy policy,” we provide detailed information below about the specific types of cookies we use on our Website:

4.1 Essential Cookies

These cookies are strictly necessary for the operation of our Website and enable core functionality such as security, network management, user authentication, and account access. You cannot opt out of these cookies as the Website cannot function properly without them.

4.2 Preference Cookies

These cookies remember your settings and preferences to enhance your experience on our Website and allow us to provide personalized features.

4.3 Analytics Cookies

These cookies collect information about how you use our Website, helping us understand visitor behavior patterns, identify popular content, and analyze traffic patterns. This information allows us to improve our Website and your experience.

4.4 Marketing/Advertising Cookies

These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share information with other organizations or advertisers.

4.5 Social Media Cookies

These cookies are set by social media services that we have added to the site to enable you to share our content with your friends and networks. They can track your browser across other sites and build a profile of your interests.

5. PURPOSES FOR COOKIE COLLECTION AND USE

In accordance with PIPEDA requirements for purpose identification, we provide detailed explanations below for why we use each category of cookies:

5.1 Essential Cookies - Purposes

Our essential cookies serve the following specific purposes:

1. User Authentication and Account Security: To verify your identity when you log in to your account, maintain your logged-in status as you navigate through the Website, and protect against unauthorized access to your account.
2. Fraud Prevention and Security: To detect and prevent fraudulent activities, unauthorized transactions, and security breaches by monitoring for suspicious patterns and activities.
3. Website Functionality: To enable basic functions such as page navigation, accessing secure areas, and properly displaying content based on your device type.
4. Load Balancing and Technical Stability: To distribute traffic evenly across our servers, prevent overloads, and ensure the Website remains operational during high-traffic periods.
5. Session Management: To remember information you have entered on forms when navigating to different pages during a browser session.
6. Regulatory Compliance: To fulfill our obligations under financial regulations, including Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements applicable to our fintech services.

5.2 Preference Cookies - Purposes

Our preference cookies serve the following specific purposes:

1. Personalized User Experience: To remember your settings and preferences, such as language, region, currency, and display preferences, enhancing your experience and making your interactions more efficient.
2. Customized Dashboard Configuration: To save your preferred layout, widget arrangements, and visualization preferences for financial data and spending analytics.
3. Notification Management: To store your preferences regarding what types of alerts and notifications you wish to receive about your financial activities.
4. Accessibility Features: To maintain your accessibility settings, such as contrast levels, text size, or screen reader compatibility.
5. Content Relevance: To tailor the content displayed based on your previous interactions and stated preferences, making our financial tools more relevant to your needs.

5.3 Analytics Cookies - Purposes

Our analytics cookies serve the following specific purposes:

1. Website Performance Optimization: To identify slow-loading pages, technical errors, and usability issues that may impact your experience with our financial tools.
2. User Behavior Analysis: To understand how users interact with our financial services, including which features are most valuable and which may need improvement.
3. Conversion Path Analysis: To analyze the steps users take before completing important actions, such as signing up for an account or using specific financial tracking features.
4. Content Effectiveness Measurement: To evaluate which financial education content, tools, and resources are most helpful to users.
5. Aggregate Statistical Analysis: To compile anonymous, aggregate statistics that allow us to understand how users use our Website and to improve its structure and content.
6. A/B Testing and Product Development: To test different versions of our Website or specific features to determine which ones perform better and improve our financial wellness tools.

5.4 Marketing/Advertising Cookies - Purposes

Our marketing/advertising cookies serve the following specific purposes:

1. Personalized Advertising: To display advertisements that are more relevant to your interests and financial needs, both on our Website and on third-party websites.
2. Retargeting: To show you targeted advertisements on other websites based on your previous interactions with our Website and the specific financial services you’ve shown interest in.
3. Campaign Effectiveness: To measure the performance of our marketing campaigns and optimize our marketing spend.
4. Market Research and Analytics: To gather insights about our user base and market segments to better understand financial needs and preferences.
5. Cross-Device Tracking: To recognize you across different devices and provide a consistent experience as you switch between devices.
6. Frequency Capping: To limit the number of times you see a particular advertisement, preventing ad fatigue.
7. Affiliate Marketing Tracking: To track referrals from our affiliate partners and properly attribute conversions.

6. CONSENT MECHANISM AND USER CHOICE

6.1 Consent Approach

We obtain your consent for the use of cookies through implied consent mechanisms. By continuing to use our Website after being presented with a clear and prominent cookie notice, you are deemed to have consented to our use of cookies as described in this Policy. However, we recognize that for certain types of cookies, particularly those used for marketing and advertising purposes, implied consent may not always be sufficient under PIPEDA and the Office of the Privacy Commissioner of Canada’s guidelines on meaningful consent.

6.2 Cookie Notice

When you first visit our Website, you will be presented with a cookie notice that:

1. Informs you that we use cookies;
2. Provides a summary of the categories of cookies we use;
3. Explains the purposes for which we use cookies;
4. Directs you to this Cookie Policy for more detailed information; and
5. Provides you with options to accept, decline, or customize your cookie preferences.

6.3 Cookie Preference Center

While we primarily rely on implied consent, we provide a Cookie Preference Center accessible through our Privacy Policy and website footer that allows you to:

1. View detailed information about the cookies we use;
2. Select which categories of non-essential cookies you wish to allow;
3. Change your cookie preferences at any time; and
4. Withdraw previously given consent for non-essential cookies.

6.4 Essential Cookies Exception

Please note that essential cookies are necessary for the proper functioning of our Website and cannot be disabled through our Cookie Preference Center. However, you may be able to block or delete these cookies through your browser settings, though doing so may impact your ability to use our Website and access our financial services.

6.5 Age Verification

Our financial services are not directed at individuals under the age of 16. We implement age verification mechanisms to ensure that users are of appropriate age before collecting cookie data. If we become aware that we have collected personal information from an individual under the age of 16 without parental consent, we will take steps to delete that information.

6.6 Comprehensive Consent Records

We maintain a comprehensive consent logging system that records:

1. When consent was provided or updated;
2. What information was presented to the user at the time consent was obtained;
3. The specific cookie preferences selected by the user;
4. Any changes made to cookie preferences over time; and
5. Timestamps for all consent actions.

These records are maintained to demonstrate compliance with PIPEDA requirements and to respect user choices regarding cookie usage.

7. DATA RETENTION PERIODS

7.1 Cookie Retention Periods

We retain cookie data for different periods depending on the type of cookie:

1. Session Cookies: These cookies are temporary and are deleted when you close your browser.
2. Analytics Cookies: Data collected through analytics cookies is retained for 30 days, after which it is either deleted or anonymized in a manner that prevents identification of individual users.
3. Preference Cookies: Information stored in preference cookies is retained for 1 year to maintain your personalized settings and preferences.
4. Marketing/Advertising Cookies: Data collected through marketing and advertising cookies is retained for 2 years to enable personalized advertising and campaign effectiveness measurement.

7.2 Data Minimization

We follow data minimization principles and only collect and retain cookie data that is necessary for the purposes specified in this Policy. We regularly review our cookie data retention practices to ensure we are not retaining data longer than necessary.

7.3 Financial Services Record Keeping Requirements

As a provider of financial services, we are subject to certain record-keeping requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), S.C. 2000, c. 17. Where cookie data forms part of records that we are required to maintain under this legislation, we may retain such data for the period prescribed by law, which may be longer than the retention periods specified above.

7.4 Anonymization and Aggregation

After the applicable retention period expires, we may continue to use cookie data in an anonymized or aggregated form that no longer permits identification of individual users for analytical, statistical, and research purposes.

7.5 User-Initiated Deletion

You have the right to request deletion of your cookie data before the expiration of the retention period. Instructions for exercising this right are provided in Section 10 (User Rights and Access) of this Policy.

8. THIRD-PARTY DATA SHARING

8.1 Third-Party Recipients

In accordance with PIPEDA requirements to provide information about third-party data sharing at or before the time of collection, we disclose that we share cookie data with the following categories of third parties:

1. Analytics Providers:

• Google Analytics
• Adobe Analytics

2. Advertising Networks and Marketing Platforms:

• Google Ads
• Facebook Pixel
• LinkedIn
• Reddit

3. Social Media Platforms:

• Facebook
• Twitter
• LinkedIn

4. Service Providers:

• Cloud hosting providers
• Customer relationship management (CRM) systems
• Email marketing services
• User authentication services
• Payment processors

8.2 Purposes of Third-Party Sharing

We share cookie data with third parties for the following purposes:

1. Analytics and Website Improvement: To analyze user behavior, improve website performance, and enhance user experience.
2. Targeted Advertising: To deliver personalized advertisements based on your interests and online behavior.
3. Social Media Integration: To enable social sharing functionality and social login options.
4. Service Provision: To provide essential services such as payment processing, user authentication, and customer support.
5. Fraud Prevention: To detect and prevent fraudulent activities and security breaches.

8.3 Data Protection Safeguards

When sharing cookie data with third parties, we implement appropriate safeguards to protect your personal information:

1. We enter into data processing agreements with third-party service providers that require them to:

• Process data only for specified purposes
• Implement appropriate security measures
• Not disclose data to other parties without our consent
• Return or delete data when the service ends

2. We regularly review the privacy practices of our third-party partners to ensure they maintain appropriate data protection standards.
3. We only share the minimum amount of data necessary for the intended purpose.

8.4 Third-Party Privacy Policies

Each third party has its own privacy policy governing how it uses the data we share. We encourage you to review the privacy policies of these third parties, which can be accessed through the following links:

• Google (Analytics and Ads): https://policies.google.com/privacy
• Facebook: https://www.facebook.com/policy.php
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Adobe: https://www.adobe.com/privacy/policy.html
• Reddit: https://www.reddit.com/policies/privacy-policy

8.5 Opt-Out Options

You can opt out of third-party data sharing for non-essential purposes through our Cookie Preference Center. Additionally, many third parties provide their own opt-out mechanisms:

1. Google Analytics: Install the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout
2. Facebook: Adjust your ad preferences at https://www.facebook.com/ads/preferences
3. LinkedIn: Manage your advertising preferences at https://www.linkedin.com/psettings/guest-controls
4. Adobe Analytics: Opt out at https://www.adobe.com/privacy/opt-out.html
5. Digital Advertising Alliance of Canada: Visit https://youradchoices.ca/ to opt out of interest-based advertising from participating companies

9. CROSS-BORDER DATA TRANSFERS

9.1 International Data Transfers

We disclose that cookie data collected through our Website may be transferred to, stored in, or processed in countries outside of Canada, including:

1. United States of America (USA)
2. European Union (EU) member states
3. United Kingdom (UK)

9.2 Legal Basis for Transfers

When transferring personal information across borders, we ensure that appropriate safeguards are in place in accordance with PIPEDA requirements:

1. Adequacy Decisions: Where applicable, we rely on adequacy decisions made by the Canadian government or other relevant authorities regarding the adequacy of data protection in the recipient country.
2. Standard Contractual Clauses: We implement standard contractual clauses approved by relevant data protection authorities to ensure that your personal information receives an adequate level of protection.
3. Data Processing Agreements: We enter into data processing agreements with recipients that require them to protect your personal information in accordance with standards at least as stringent as those required under Canadian privacy laws.
4. Consent: Where required and appropriate, we obtain your explicit consent for cross-border transfers of your personal information.

9.3 Risks of Cross-Border Transfers

We inform you that when your personal information is transferred to countries outside of Canada, it may be subject to the laws of those countries, which may provide different levels of data protection than Canada. This means that:

1. Foreign courts, law enforcement agencies, or regulatory bodies may have access to your personal information under the laws of those countries.
2. You may have fewer legal rights in relation to your personal information in those countries compared to Canada.
3. It may be more difficult to enforce your privacy rights in those countries.

9.4 Safeguards and Risk Mitigation

To mitigate the risks associated with cross-border transfers, we implement the following additional safeguards:

1. Data minimization to ensure only necessary information is transferred.
2. Encryption of data during transfer and storage.
3. Regular assessment of the privacy practices and compliance of our international partners.
4. Contractual requirements for prompt notification of data breaches or unauthorized access.
5. Mechanisms to facilitate the exercise of your rights regardless of where your data is processed.

9.5 EU-Specific Provisions

For transfers to the European Union, we comply with the requirements of the General Data Protection Regulation (GDPR) where applicable, providing an additional layer of protection for your personal information.

10. USER RIGHTS AND ACCESS

10.1 Your Rights Under PIPEDA

In accordance with PIPEDA, you have the following rights regarding your personal information collected through cookies:

1. Right to Access: You have the right to request access to your personal information that we have collected, including information about how we use and share it.
2. Right to Correction: You have the right to request that we correct inaccurate personal information about you.
3. Right to Withdraw Consent: You have the right to withdraw your consent to the collection, use, and disclosure of your personal information at any time, subject to legal or contractual restrictions.
4. Right to File a Complaint: You have the right to file a complaint with the Office of the Privacy Commissioner of Canada regarding our handling of your personal information.

10.2 How to Exercise Your Rights

To exercise your rights regarding cookie data and other personal information:

1. Access and Correction Requests: Send a written request to [email protected] with the subject line “Personal Information Request.” Please include your name, contact information, and details about the specific information you are seeking or wish to correct.
2. Withdrawing Consent: You can withdraw your consent to non-essential cookies at any time by:

• Accessing our Cookie Preference Center through the link in our website footer
• Adjusting your browser settings to reject cookies
• Clearing cookies from your browser

3. Filing a Complaint: If you are not satisfied with our response to your privacy concerns, you may contact the Office of the Privacy Commissioner of Canada at:

• 30 Victoria Street
• Gatineau, Quebec K1A 1H3
• Toll-free: 1-800-282-1376
• Website: https://www.priv.gc.ca

10.3 Response Timeline

We will respond to your requests regarding your personal information within 30 days, unless an extension is required. If an extension is required, we will notify you within the initial 30-day period and provide an explanation for the extension.

10.4 Verification Process

To protect your privacy and security, we may require verification of your identity before providing access to your personal information or making requested changes. This verification process may include requesting specific identifying information.

10.5 Limitations on Rights

In certain circumstances, we may be unable to provide access to all the personal information we hold about you. These circumstances include where:

1. The information is protected by solicitor-client privilege;
2. Disclosure would reveal confidential commercial information;
3. The information was collected for purposes related to the detection and prevention of fraud;
4. The information was generated in the course of a formal dispute resolution process; or
5. Providing access would reveal personal information about another individual.

If we deny your request for access, we will inform you of the reason for the denial and any recourse you may have.

11. CHILDREN’S PRIVACY PROTECTION

11.1 Age Restrictions

Our Website and financial services are not directed at children under the age of 16. We do not knowingly collect personal information, including through cookies, from individuals under 16 years of age.

11.2 Age Verification Mechanisms

We implement the following age verification mechanisms to prevent the collection of personal information from children:

1. Age Declaration: During the account registration process, users must declare their date of birth, and those under 16 years of age are not permitted to create accounts.
2. Parental Consent: In the event that we need to collect personal information from individuals under 16 for specific legitimate purposes, we will obtain verifiable parental consent before collecting such information.
3. Technical Measures: We employ technical measures designed to identify and restrict access to certain features for users who indicate they are under 16 years of age.

11.3 Discovery of Child Data

If we discover that we have inadvertently collected personal information from a child under 16 without parental consent, we will:

1. Immediately cease processing such information;
2. Promptly delete the information from our records;
3. Implement additional measures to prevent future collection of such information; and
4. Maintain records of the incident and our response as required by applicable law.

11.4 Educational Resources

We provide educational resources for parents and guardians regarding online privacy and the importance of monitoring children’s online activities. These resources can be accessed through the “Privacy Education” section of our Website.

11.5 Financial Education for Youth

While our primary services are restricted to users 16 and older, we may offer age-appropriate financial education content designed for younger audiences. Such educational content:

1. Does not require the creation of user accounts;
2. Does not collect personal information beyond what is strictly necessary;
3. Uses only essential cookies required for basic website functionality; and
4. Is clearly labeled as appropriate for specific age groups.

11.6 Reporting Concerns

If you believe that we have collected personal information from a child under 16 without appropriate consent, please contact us immediately at [email protected] with the subject line “Children’s Privacy Concern.”

12. DATA SECURITY MEASURES

12.1 Security Safeguards

In accordance with PIPEDA requirements, we implement appropriate technical, physical, and organizational safeguards to protect cookie data and other personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include:

1. Encryption: We use industry-standard encryption technologies to protect data during transmission and storage.
2. Access Controls: We restrict access to personal information to authorized employees, contractors, and third-party service providers who require access to perform their job functions.
3. Authentication Mechanisms: We implement multi-factor authentication for administrative access to systems containing personal information.
4. Firewalls and Intrusion Detection: We maintain firewalls and intrusion detection systems to prevent unauthorized access to our networks and systems.
5. Regular Security Assessments: We conduct regular security assessments, vulnerability scans, and penetration testing to identify and address potential security weaknesses.
6. Data Minimization: We collect and retain only the personal information necessary for the purposes identified in this Policy.
7. Secure Disposal: We securely dispose of personal information when it is no longer needed for the purposes for which it was collected.

12.2 Employee Training

We provide regular privacy and security training to our employees to ensure they understand their responsibilities regarding the protection of personal information. This training includes:

1. Identification of personal information and sensitive data;
2. Proper handling and protection of personal information;
3. Recognition and reporting of security incidents and data breaches;
4. Compliance with applicable privacy laws and regulations; and
5. Implementation of our privacy and security policies and procedures.

12.3 Incident Response Plan

We maintain an incident response plan to address actual or suspected unauthorized access to or disclosure of personal information. In the event of a data breach involving your personal information, we will:

1. Promptly investigate the incident to determine its scope and impact;
2. Take steps to contain and mitigate the breach;
3. Notify affected individuals and relevant regulatory authorities as required by law;
4. Provide affected individuals with information about steps they can take to protect themselves; and
5. Implement measures to prevent similar incidents in the future.

12.4 Third-Party Security Requirements

We require our third-party service providers who process personal information on our behalf to implement appropriate security measures. These requirements are formalized in our data processing agreements and are regularly reviewed for compliance.

12.5 Limitations

While we implement reasonable security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your personal information. You are responsible for maintaining the confidentiality of any passwords or other account credentials and for notifying us of any unauthorized access to or use of your account.

13. HOW TO MANAGE COOKIE PREFERENCES

13.1 Cookie Preference Center

You can manage your cookie preferences through our Cookie Preference Center, which is accessible through links in our Privacy Policy and website footer. The Cookie Preference Center allows you to:

1. View detailed information about the cookies we use;
2. Select which categories of non-essential cookies you wish to allow;
3. Change your cookie preferences at any time; and
4. Withdraw previously given consent for non-essential cookies.

13.2 Browser Settings

Most web browsers allow you to manage your cookie preferences through their settings. You can:

1. Delete Cookies: Clear all or specific cookies stored on your device.
2. Block Cookies: Set your browser to block all or certain types of cookies.
3. Allow Cookies: Enable cookies from specific websites or for specific purposes.
4. Private Browsing: Use your browser’s “private” or “incognito” mode to browse without storing cookies.

Instructions for managing cookies in common browsers:

• Google Chrome: Menu > Settings > Privacy and security > Cookies and other site data
• Mozilla Firefox: Menu > Options > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Cookies and website data
• Microsoft Edge: Menu > Settings > Cookies and site permissions > Cookies and site data
• Opera: Settings > Advanced > Privacy & security > Cookies

13.3 Opt-Out Tools

In addition to browser settings, you can use the following tools to manage your cookie preferences:

1. Digital Advertising Alliance of Canada (DAAC): Visit https://youradchoices.ca/ to opt out of interest-based advertising from participating companies.
2. Network Advertising Initiative (NAI): Visit https://optout.networkadvertising.org/ to opt out of interest-based advertising from NAI members.
3. Google Analytics Opt-out Browser Add-on: Install the add-on available at https://tools.google.com/dlpage/gaoptout to prevent Google Analytics from collecting data about your visits.

13.4 Mobile Devices

On mobile devices, you can manage cookies and tracking through:

1. iOS Devices: Settings > Privacy > Tracking, and Settings > Safari > Privacy & Security
2. Android Devices: Settings > Privacy > Ads, or through the Chrome browser settings

13.5 Consequences of Declining Cookies

If you choose to decline non-essential cookies, you will still have access to our Website and its core functionality. However, some features may not function optimally, such as:

1. Personalized content and recommendations;
2. Remembered preferences and settings;
3. Certain interactive features; and
4. Tailored advertising.

We are committed to providing full website functionality with only essential cookies for users who decline consent for non-essential cookies.

13.6 Do Not Track Signals

Some browsers transmit “Do Not Track” signals. We currently do not respond to “Do Not Track” browser settings or signals. If we do so in the future, we will describe how in this Cookie Policy.

14. POLICY UPDATES

14.1 Policy Review and Updates

We review this Cookie Policy regularly to ensure it accurately reflects our cookie practices and complies with applicable laws and regulations. We may update this Policy from time to time to:

1. Reflect changes in our cookie practices;
2. Incorporate new types of cookies or technologies;
3. Address changes in applicable laws, regulations, or industry standards;
4. Respond to guidance from regulatory authorities; or
5. Improve clarity and transparency.

14.2 Notification of Changes

When we make material changes to this Policy, we will notify you by:

1. Posting a notice on our Website;
2. Displaying a prominent banner on our Website;
3. Sending an email notification to registered users (for significant changes); and/or
4. Updating the “Last Updated” date at the top of this Policy.

14.3 Consent Refresh

In accordance with PIPEDA requirements for ongoing consent, when we make significant changes to our cookie practices or this Policy, we will:

1. Provide clear information about the changes;
2. Explain how the changes may impact you;
3. Obtain renewed consent where required; and
4. Provide an opportunity to review and adjust your cookie preferences.

14.4 Prior Versions

We maintain archives of previous versions of this Cookie Policy, which are available upon request by contacting [email protected] with the subject line “Cookie Policy Version Request.”

14.5 Continued Use

Your continued use of our Website after we post changes to this Cookie Policy constitutes your acceptance of the updated Policy, subject to any consent requirements for specific types of cookies. If you do not agree with the changes, you should adjust your cookie preferences or discontinue use of our Website.

15. CONTACT INFORMATION FOR PRIVACY INQUIRIES

15.1 Primary Contact

For questions, concerns, or requests regarding this Cookie Policy or our privacy practices, please contact us at:

Email: [email protected]

Phone: +1-775-773-8446

Mail: The Rajma Company Inc.

20 Bruyeres Mews, Suite 2712

Toronto, Ontario, M5V 0G8

Canada

15.2 Data Protection Officer

While not legally required under PIPEDA, we have designated a Data Protection Officer who is responsible for overseeing our privacy compliance efforts. You may contact our Data Protection Officer at:

Email: [email protected]

Mail:
Data Protection Officer
The Rajma Company Inc.
20 Bruyeres Mews, Suite 2712
Toronto, Ontario, M5V 0G8
Canada

15.3 Response Time

We strive to respond to all privacy-related inquiries within 10 business days. For formal access or correction requests under PIPEDA, we will respond within 30 days as required by law, unless an extension is necessary.

15.4 Escalation Process

If you are not satisfied with our response to your privacy concern, you may escalate the matter by:

1. Requesting a review by our senior management team by emailing [email protected];
2. Filing a complaint with the Office of the Privacy Commissioner of Canada at:

• 30 Victoria Street
  Gatineau, Quebec K1A 1H3
• Toll-free: 1-800-282-1376
• Website: https://www.priv.gc.ca

15.5 Additional Resources

For more information about privacy rights and cookie management, you may find the following resources helpful:

1. Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca
2. Digital Advertising Alliance of Canada: https://youradchoices.ca/
3. Network Advertising Initiative: https://www.networkadvertising.org/
4. About Cookies Website: https://www.aboutcookies.org/

16. EFFECTIVE DATE

This Cookie Policy is effective as of 11.26.2025.

By using our Website, you acknowledge that you have read and understood this Cookie Policy and agree to the collection, use, and disclosure of your information as described herein.