Moxy Technologies inc.
Privacy policy

Effective Date: April 2025

Welcome to the Privacy Policy of Moxy Technologies inc.

This Privacy Policy explains how we collect, use, store, protect, and share your personal information when you interact with our websites, applications, and services (the ''Services''). It applies to all of our offerings, including but not limited to MoxyDraw, MoxyDrawLite, MoxyMailPro, TranslateMyWebsitePro, and MoxyFiles.

We are committed to protecting your personal data and ensuring that your privacy is respected at all times. We encourage you to read this Privacy Policy carefully to fully understand:

• What personal data we collect;
• How and why we use your personal data;
• How long we retain your personal data;
• Your rights regarding your personal data;
• The security measures we implement to protect your personal data;
• How you can control the use and sharing of your personal data.

By accessing or using our Services, you agree to the terms described in this Privacy Policy.

For information about the terms governing your general use of the Services, please refer to our [Terms and Conditions].

If you have any questions or concerns about this Privacy Policy, please contact us using the details provided below.

1. Who we are

Moxy Technologies inc. (''we'', ''us'', ''our'') is a company incorporated under the laws of Québec, Canada (Business Corporations Act, chapter S-31.1), with its principal place of business located at:

Moxy Technologies inc. 13 des Noyers, Granby, Québec, Canada

If you have any questions regarding this Privacy Policy or the way we process your personal data, you may contact us at:
info@moxytechnologies.com

For inquiries related to personal data protection, privacy, or security matters, you may also reach us through the same contact address.

2. What personal data do we collect?

Personal data refers to any information that relates to an identified or identifiable individual. It includes information that, alone or combined with other data, can be used to identify you.

You may visit our websites and explore our Services anonymously without providing any personal data.

We only collect personal data when you choose to interact with us, such as when you purchase a product or service. Specifically:

• When purchasing a product or subscription, we collect your name, address, and email address through our online purchase form.
• Additional technical information may be collected when necessary for licensing, security, or operational purposes. Such information may include, but is not limited to: Media Access Control (MAC) addresses, International Mobile Equipment Identity (IMEI), Unique Device Identifier (UDID), Central Processing Unit ID (CPUID), Windows computer name, Internet Protocol (IP) address or Browser type and system information.
• We do not collect personal data when you use our free products or free versions of our services, except where an email address may be requested for registration, communication, or service access purposes.

Please note that credit card numbers and payment information are collected and processed securely by a third-party payment provider. We do not store or process credit card information on our servers.

Processing of personal data includes activities such as collection, organization, structuring, storage, use, disclosure, or any other handling of the data.

3. What do we use your personal data for?

We use your personal data solely for the purposes for which it was collected, including:

• Billing and payment processing, when you purchase a product or subscription;
• Account management, including providing access to purchased products, free services, or subscriptions;
• Notifying you about changes to the Services or to this Privacy Policy;
• Responding to inquiries, support requests, or important service-related issues
• Licensing and security verification, to ensure proper functioning of licensing systems and to protect against unauthorized access or use.

We do not use your personal data for marketing purposes unless you have explicitly provided consent.

Technical information, mentioned in section 2, may be used to:

• Maintain and improve the security, performance, and reliability of our Services;
• Ensure that the licensing system works properly.
• Detect, prevent, and investigate fraud or other misuse.

We will never sell, rent, or trade your personal data to third parties.

4. How do we protect your personal data?

Moxy Technologies inc. implements technical, physical, and organizational measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure, or access, and against all other unlawful forms of processing.

We apply the following security principles:

Availability
Moxy Technologies inc. uses a distributed infrastructure to provide the highest possible level of service availability. However, services are provided on an ''as is'' basis, and Moxy Technologies inc. cannot be held responsible for any damage resulting from service interruptions.

Confidentiality
All personnel with access to personal data are subject to strict confidentiality obligations. Subcontractors and subprocessors are required to sign confidentiality agreements unless full confidentiality is included in their primary service contracts. Access to personal data is restricted to authorized personnel only, through a private network over encrypted connections and from a limited set of IP addresses. All access attempts are logged. We do not store personal information outside of secured private servers, even temporarily.

Transparency
Moxy Technologies inc. will inform you of material changes to our data protection practices and policies. Upon request, we will provide information on where and how your data is stored, secured, and used. If applicable, we will also provide summaries of any independent audits conducted on our Services.

Isolation
Access to personal data is blocked by default under a zero-privileges policy. Only individually authorized personnel are granted access rights, and such access is granted solely on a strict need-to-know basis.

The ability to intervene
We enable your rights of access, rectification, erasure, blocking, and objection by providing built-in functionalities within the Services. You will also be informed and given the opportunity to object whenever we plan material changes to relevant data handling practices and policies.

Monitoring
Moxy Technologies inc. monitors system performance, availability, and access patterns through internal and external monitoring systems. Administrative operations, including system access and modifications, are logged to ensure auditability and to proactively identify and mitigate potential security threats.

Personal Data breach notification
In the event of a personal data breach, Moxy Technologies inc. will notify affected individuals and the relevant supervisory authorities within 72 hours of becoming aware of the breach. Notifications will include the extent of the breach, the data involved, potential impacts, and corrective actions being taken.

5. Do we disclose any information to outside parties?

Moxy Technologies inc. does not sell, trade, rent, or otherwise transfer your personal data to outside parties.

We may only share your personal data under the following limited circumstances:

Legally required disclosure
Moxy Technologies inc. will not disclose your personal data to law enforcement agencies or other government authorities unless:

• You explicitly instruct us to do so; or
• We are legally compelled to comply with a valid and binding request under applicable law.

If we are required to disclose your personal data by law, we will:

• Strive to limit the disclosure to only the specific data mandated by the legal demand;
• Promptly notify you of the request and provide you with a copy of the legal demand, unless we are legally prohibited from doing so.

6. Where do we store the information?

All personal data collected by Moxy Technologies inc. is stored securely within databases and file repositories hosted in Canada

Our data storage practices include:

• Primary and Secondary Storage: All data is stored in primary databases and file repositories in Canada, and is automatically replicated in real time to secondary hot failover systems located within Canada for redundancy and continuity.
• Backup and Recovery: Databases are continuously backed up to allow restoration to any point in time within a retention period of 30 days. Backup files are also stored securely on servers located in Canada.
• Moxy Technologies inc. does not store or process any credit card numbers or payment information on our servers. All payment transactions are processed securely through a third-party payment provider (e.g., Stripe), in compliance with applicable security standards.

7. Access, Data Portability, Migration, and Transfer Assistance

You have the right to access your personal data at any time. Upon request, Moxy Technologies inc. will confirm whether personal data concerning you is being processed.

You may also request a complete copy of your personal data in a structured, commonly used, and machine-readable format. This enables you to transmit your data to another data controller if you wish.

When requested, Moxy Technologies inc. will provide the requested data within 10 business days.

We will maintain logical relationships between datasets by preserving unique identifiers where applicable, to ensure the consistency and usability of your data during migration or transfer.

8. Request for rectification, restriction or erasure of the personal data

Rectification
You may request the correction of inaccurate or incomplete personal data concerning you without undue delay. Moxy Technologies inc. will promptly update your information to ensure it is accurate and complete.

Restriction of processing
You may request that the processing of your personal data be restricted under the following circumstances:

• You contest the accuracy of the personal data, for a period enabling us to verify its accuracy;
• The processing is unlawful, and you oppose the erasure of the data and instead request the restriction of its use;
• Moxy Technologies inc. no longer needs the personal data for the original purposes of processing, but you require it for the establishment, exercise, or defense of legal claims.

During the period of restriction, your data will not be processed for any purpose other than storage, unless you provide explicit consent.

Erasure (''Right to Be Forgotten'')
You may request the deletion of your personal data without undue delay where one of the following grounds applies:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• You withdraw your consent, and there is no other legal basis for the processing;
• You object to the processing, particularly where it concerns direct marketing purposes;
• The personal data have been unlawfully processed;
• The erasure is required to comply with a legal obligation under applicable law.

Upon receipt of a valid erasure request, Moxy Technologies inc. will promptly delete your personal data in accordance with legal and regulatory requirements.

9. Data retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law.

Specifically:

• If the processing of personal data is based on your consent, we will retain the data until you revoke your consent, and thereafter for a period required to address any potential legal claims.
• If the processing is based on the performance of a contract, we will retain the data for as long as necessary to fulfill the contractual obligations, and thereafter for a period required to address any potential legal claims.
• If the processing is based on our legitimate interests, we will retain the data until you object to such processing, and thereafter for a period required to address any potential legal claims.

Account Inactivity
We reserve the right to delete user data after a continuous period of 12 months of inactivity. In such cases, all associated personal data will be permanently deleted.

Account Deletion and Data Erasure
When an account is deleted, all account data, configuration data, and login information will be permanently erased within 29 days. Users may also request the immediate deletion of their personal data at any time. Upon such a request, the deletion will be irreversible, and no recovery options will be available.

Retention for Legal Compliance
Certain data may be retained longer where required by applicable laws or regulations. Requests to alter standard retention periods may be considered if necessary to comply with specific sectoral legal obligations.

10. Accountability

Moxy Technologies inc. maintains detailed logs of all system updates, configuration changes, and administrative access events.

These audit trails are designed to detect and investigate any unauthorized or accidental changes to our systems or data.

You have the right to request a data protection audit conducted by an independent third party, subject to the following conditions:

• The independent auditor must be mutually agreed upon by you and Moxy Technologies inc.;
• You are responsible for any fees associated with the audit request, including applicable taxes and related costs;
• The scope and procedures of the audit must be reasonable and not interfere with the normal operations or security of Moxy Technologies inc.'s services.

We are committed to maintaining transparency and accountability in all aspects of our personal data processing activities.

11. Cooperation

Moxy Technologies inc. is committed to cooperating with individuals, customers, and regulatory authorities to ensure full compliance with applicable data protection laws and regulations.

Specifically, we will:

• Assist you in exercising your rights regarding your personal data, including rights of access, rectification, erasure, blocking, and objection.
• Support the management and investigation of any incidents involving personal data, including the provision of forensic analysis in the event of a security breach;
• Respond promptly and transparently to any inquiries or requests related to the processing of your personal data.

We value openness and collaboration as essential principles in maintaining the security, integrity, and lawfulness of our data processing activities.

12. Moxy Technologies inc. Terms and Conditions of Use

This Privacy Policy forms part of the broader agreement governing your use of Moxy Technologies inc.'s Services.

Please also review our [Terms and Conditions], which outline important information regarding your rights, responsibilities, and limitations when using our Services.

13. Changes to This Privacy Policy

Moxy Technologies inc. may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons.

If we make material changes, we will notify you by email (if you have provided one) and/or by posting a prominent notice on our websites.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Changes are effective immediately upon posting unless otherwise specified.

14. If you are not satisfied

If you have any questions, concerns, or complaints regarding this Privacy Policy or our personal data practices, please contact us at:
info@moxytechnologies.com

We are committed to resolving any privacy concerns promptly and respectfully.

Moxy Technologies inc. — Powered by innovation, committed to your privacy.