Effective Date: January 2026

Cocendo Social Engine Inc. (“Cocendo”) is committed to protecting the privacy of individuals who use its Services. We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws.

This Privacy Policy explains how Cocendo collects, uses, discloses, and protects personal information across our coalition ecosystem.

1. Scope

This Policy applies to:

• Visitors to Cocendo websites

• Users of Cocendo platforms, apps, loyalty programs, and gift cards

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

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

2. Information We Collect

• Identification & Contact Data: Name, email, phone number, account credentials (hashed passwords).

• Program Participation Data: Transaction details, points earned/redeemed, gift card issuance/redemption, merchant IDs.

• Merchant & Brand Data: Business contact info, campaign settings, product listings, performance metrics.

• Technical & Usage Data: IP address, device type, browser version, pages visited, referral URLs, error logs.

• Communication Data: Messages, support requests, feedback, survey responses.

Sensitive information is collected only with explicit consent.

3. How We Collect Information

• Directly from you (account creation, support interactions)

• Automatically (cookies, analytics tools)

• From merchants, brands, and institutions reporting eligible transactions

• From third‑party processors, with your consent

4. How We Use Information

• Provide & Operate Services: Manage accounts, track points, discounts, gift cards, and voucher programs.

• Communicate: Service notifications, support responses.

• Improve Services: Analyze usage trends, develop new features.

• Legal Compliance: Maintain records, respond to lawful requests.

• Marketing (Optional): With consent, Cocendo may send promotional updates. You may opt out anytime.

Cocendo does not sell personal information.

5. Sharing & Disclosure

• Service Providers: Payment processors, hosting, analytics.

• Merchants & Brands: Aggregated or de‑identified data; identified data only when required.

• Diewert.org: Aggregated or de‑identified data for impact reporting; identified donor info only for tax receipting.

• Legal Authorities: When required by law.

• Business Transfers: In mergers, acquisitions, or asset sales.

6. Data Retention & Security

• Retained only as long as necessary to provide services and meet legal obligations.

• Secure deletion or anonymization when no longer required.

• Safeguards include encryption, access controls, and system monitoring.

7. Your Rights

Depending on 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

8. International Transfers

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

9. Children’s Privacy

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

10. Changes to This Policy

Cocendo may update this Policy periodically. Material changes will be communicated with an updated effective date. Continued use of Services constitutes acceptance.

📬 Contact Information

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

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