Privacy Policy

Cocendo Social Engine Inc. Effective Date: January 2026

Cocendo is committed to protecting the privacy of individuals who use its Services and to handling personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws.

This Privacy Policy explains how Cocendo collects, uses, discloses, and protects personal information.

1. Scope

This Policy applies to:

• Visitors to Cocendo websites

• Users of Cocendo platforms, apps, and loyalty services

• Merchants, brands, institutions, and partners who provide personal information

This Policy does not apply to third‑party websites or services not controlled by Cocendo.

2. Definitions

Personal Information

Information about an identifiable individual (e.g., name, email, transaction data linked to a user account).

Usage Data

Technical information about how you access and use the Services (e.g., IP address, device type).

Program Data

Information related to participation in the loyalty ecosystem (e.g., points earned, redemptions, merchant IDs).

3. What We Collect

Identification & Contact Information

• Name, email, phone number

• Account credentials (username, hashed password)

Program Participation Data

• Transaction details (date, merchant, approximate amount, discount applied)

• Points earned, redeemed, transferred, or expired

• Gift card issuance and redemption data

Merchant & Brand Data

• Business contact information

• Campaign settings, product listings, performance metrics

Technical & Usage Data

• IP address, device type, browser version

• Pages visited, referral URLs, error logs

Communication & Support Data

• Messages, support requests, feedback, survey responses

Cocendo will seek explicit consent before collecting sensitive information or using information for new purposes.

4. How We Collect Information

Cocendo collects information:

• Directly from you (account creation, support interactions)

• Automatically (cookies, analytics tools)

• From merchants, brands, and institutions reporting eligible transactions

• From third‑party processors, where you have consented

You may disable certain tracking tools, but this may affect functionality.

5. How We Use Personal Information

Provide & Operate the Services

• Manage accounts

• Track points, discounts, gift cards

Administer Loyalty Programs

• Verify transactions

• Manage Charity Bank conversions

Communicate With You

• Service notifications

• Support responses

Improve the Services

• Analyze usage trends

• Develop new features

Legal Compliance

• Maintain required records

• Respond to lawful requests

Marketing (Optional)

With consent, Cocendo may send promotional updates. You may opt out at any time.

Cocendo does not sell personal information.

6. Legal Bases for Processing (Where Applicable)

Cocendo may rely on:

• Consent

• Contract performance

• Legitimate interests

• Legal obligations

7. Sharing & Disclosure

Cocendo may share information with:

Service Providers

Payment processors, hosting providers, analytics tools.

Merchants, Brands & Institutions

Aggregated or de‑identified data; identified data only when required for program administration or by law.

Diewert.org

Aggregated or de‑identified data for impact reporting; identified donor information when required for tax receipting.

Legal Authorities

When required by law or to protect Cocendo’s rights.

Business Transfers

In mergers, acquisitions, or asset sales.

Cocendo anonymizes or aggregates data wherever possible.

8. Cookies & Tracking Technologies

Used to:

• Maintain sessions

• Remember preferences

• Perform analytics

You may manage cookie preferences through browser settings or consent tools.

9. Data Retention

Cocendo retains personal information only as long as necessary to:

• Provide Services

• Meet legal obligations

• Resolve disputes

Data is securely deleted or anonymized when no longer required.

10. Security

Cocendo uses administrative, technical, and physical safeguards, including:

• Encryption in transit

• Access controls

• System monitoring

No system is perfectly secure, but Cocendo takes reasonable steps to minimize risks.

11. Your Rights & Choices

Depending on your jurisdiction, you may request:

• Access to your personal information

• Correction of inaccuracies

• Deletion (subject to legal limits)

• Withdrawal of consent

• Filing a complaint with a privacy regulator

Requests may require identity verification.

12. International Transfers

Personal information may be processed outside your region. Cocendo ensures appropriate safeguards for international transfers.

13. Children’s Privacy

Cocendo does not knowingly collect personal information from children without appropriate consent. If such information is discovered, it will be deleted.

14. Changes to This Privacy Policy

Cocendo may update this Policy periodically. Changes will be posted with an updated effective date. Material changes may include additional notices.

Continued use of the Services constitutes acceptance.

15. Contact Information

Privacy Officer Cocendo Social Engine Inc. Email: contactc@cocendo.com Address: 127 3rd St W, North Vancouver, BC V7M 1E7, Canada

If unresolved, you may contact the Office of the Privacy Commissioner of Canada or your provincial privacy regulator.