Gecko Alliance, a Canadian corporation, (“Gecko“, “we”, “us”, “our“) takes your privacy and the protection of your Personal Information (as defined below) seriously. This Privacy Policy (the “Policy“) describes our privacy practices, the types of Personal Information we may receive or collect from you and how we use, disclose, store and secure it, so that you can make informed choices.

This Policy applies to our website, our mobile application (the “Application”) and other interactions that you may have with us (e.g., inquiries, support service, etc.) (taken together, our “Platforms“). In addition, a separate agreement governs the access, and use of the Applications we offer, (the “EULA”), including the processing of any data submitted through the Application.

However, we wish to draw your attention to the fact that the rights and obligations described in this Policy do not cover third-party websites that may be linked to or mentioned on our Platforms. These third-party websites have their own privacy policies, and we encourage you to read them carefully.

We ask that you read this Policy carefully to understand our policies and practices regarding the collection, processing and storage of Personal Information, or any other information in order to give us your informed consent where appropriate. If you do not consent to this Policy, then you may not use the Platforms.

Furthermore, in order to protect your Personal Information, we have put in place policies, practices and procedures relating to the management of the Personal Information we hold.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of personal information, as well as complaint handling, information security and data governance at Gecko. They also provide the framework for the implementation of Privacy Impact Assessments (as defined in applicable laws), where required, as well as the prevention of and response to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer (as defined below).

For the Purposes (as defined below) of this Policy, “Personal Information” means any information about an identifiable individual, including information that can be used alone or in combination with other information to identify, contact or locate a single individual.

While this Policy specifically provides information about Personal Information that we collect, process or store, Gecko also wants to point out that we collect, process and store information through the Platforms that are not considered Personal Information according to applicable laws. For example, this can include mechanical information about your spa, its working condition, brand and model number of your spa, integrated components or other similar information that not related to an identifiable individual. This data belongs to Gecko and can be used to provide you with better assistance and support or to improve our products and services or develop new ones. If you have any questions do not hesitate to contact us.

The Personal Information we collect may include, but is not limited to:

• – Any data that users of the Application or our website may submit when using them.
• – Your contact details such as your first and last name, postal address, an email address, phone number, password, domain and/or similar account details to create or manage an account or to identify you, or to correspond with you.
• – Information related to your use of the Application, such as the date of your registration, the time and date of login, your username, your password, your IP address, information concerning your browser, or the device used.
• – Technical information about your use of the Platforms, such as your login details, dates of use of the Platforms, web browser type and version, time zone settings, system used, as well as information about your internet connection, equipment used to access the Platforms, content submitted and certain details about your usage.
• – Technical information that may help Gecko approximate your location. For example, Gecko may use an IP address received from your device to approximate your location. Gecko may also collect location information from devices in accordance with the consent process provided by your device.
• – Technical information about your interactions with the Platforms such as pages visited, clickstreams to, through and from the Platforms, times of your interactions, content searched for, page response times, Platforms errors, duration of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), methods used to leave the page.
• – Any Personal information provided during your interaction with us, including with our sale team, customer support or other team member to provide you with information or assist you with your use of the Platforms.
• – You can connect third-party services to your instance of the Application. Typically, such third-party services are software services that integrate with our Application, and you can enable and disable these integrations. Once enabled, the provider of a third-party service may share certain information with Gecko (e.g., if a single sign-on service is used, Gecko could receive the username and email address of a user, along with additional information that the application has elected to make available to Gecko to facilitate the integration). You should check the privacy settings and notices in these third-party services to understand what data may be disclosed to us. When a third-party service is enabled, Gecko is authorized to connect and access other information made available to Gecko in accordance with any permission(s) granted by you.
• – Gecko may receive Personal Information when submitted to our websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by Gecko or a vendor, request support, interact with our social media accounts or otherwise communicate with us.
• – Any other Personal Information you have provided to us.

Gecko needs to collect and process some of your Personal Information in order for you to use our Platforms.

When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill one of our purposes, which has been previously disclosed to you, for example, in this Policy. We use Personal Information in accordance with the privacy laws applicable to our business.

Directly from you:
As a general rule and as required by applicable privacy laws, we collect the Personal Information we need directly from you, on the basis of your voluntary consent, for example when you fill in the Platforms registration form, when you communicate with us or when you use the Platforms. For more information about the collection of information through cookies, we invite you to read the section “How do we use cookies”?

With your consent:
We generally collect your Personal Information with your consent, unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, when necessary to establish, exercise or defend a legal claim or proceeding).

Other permissible legal basis, such as the performance of our contracts
As permitted by applicable privacy laws, Gecko may collect Personal Information without your express consent, for example, to comply with obligations under applicable laws, to provide you with the Application or to fulfill our agreements.

Refusing and withdrawing your consent
You have the right, if you wish, to refuse the collection, processing or storing of your Personal Information. You may also, at any time, and subject to reasonable notice and any applicable legal or contractual restrictions, withdraw your consent (if any) to the processing of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information or refuse that we process it, this may prevent you, for example, from using the Platforms, as some of this information is essential to such use. You can contact us as indicated in the “How to contact us” section for any questions relating to this subject.

For specific and limited purposes

Gecko generally collects your Personal Information for the purposes listed below (collectively, the “Purposes”).

a) To provide you with the Platforms

We collect and use your Personal Information to enable you to access the Platforms, including the information and recommendations made available in the Application. Specifically, we use your Personal Information to:

– To provide, update, maintain and protect our Platforms and business. This includes use to prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at a user’s request;
– To determine your eligibility to the Platforms, log in and authenticate yourself;
– To process and classify information about you;
– To provide you with relevant information and help you navigate the Platforms;
– To personalize your use and experience of the Platforms;
– To create and administer your user account once you have registered on our Platforms;
– To communicate with you regarding your registration to the Platforms and your account, including your subscriptions; and
– To respond to your inquiries about the Platforms or our products and services in general.

b) For the administration of our business

We may use your Personal Information for purposes relating to our business and the proper management of our administration. As a general principle, we use Personal Information based on our legitimate interests in operating our Platforms, and business. Specifically, we may use your Personal Information as follows:

– To carry out our obligations and enforce our rights under any contract we may have with you, including rights under the EULA, including billing and collection, or to comply with legal requirements;
– To meet our business objectives, such as developing new products and services, improving or modifying our products and services, either existing products or services or develop new products or services;
– To send you administrative information, for example, information about our services and changes to our terms, conditions and policies,
– For audit, surveillance and fraud prevention purposes, and;
– To ensure the security of the Platforms.

c) To give you the support you need

We may use your Personal Information to respond to your requests for assistance, support or information in connection with the Platforms or our services. Specifically, we may use your Personal Information as follows:

– To respond to your requests for information, assistance and support;
– To answer your questions, queries, comments or complaints, and;
– To provide you with personalized assistance based on your previous requests.

d) For study, research, marketing and statistical purposes

We may use your Personal Information for study, research, marketing and statistical purposes, including to improve the Platforms, our products or services, our marketing or our customer relationships and experiences. Specifically, we may use your Personal Information as follows:

– To keep you informed of our new offers;
– To send you communications that we think may be of interest to you, such as newsletters, event, one-time promotional e-mails, direct mailings, business contacts or newsletters;
– To create statistics to demonstrate the usefulness of the Platforms;
– For data analysis purposes, including the identification of usage trends, and to determine the effectiveness of our promotional campaigns and commercial activities,
– Through the use of aggregated and anonymized data, to improve the Platforms and our services and train artificial intelligence models integrated or to be integrated in the Platforms; and;
– To conduct research to determine how to improve the Platforms, certain services or develop new ones.

e) To comply with or act under any applicable law or regulation

We may use your Personal Information as required by applicable law, legal process, or regulation or to ensure that we can comply with any legal requests under applicable law or regulation, which includes, but is not limited to:

– Respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;
– To protect our operations and legitimate interests or those of our subsidiaries; and
– To enable us to pursue available remedies or limit the damages we may suffer.

To send you messages

We may use your Personal Information to communicate with you in several ways (sending newsletters, e-mail messages, chat messages, support tickets, news, updates, written communications, etc.) (collectively, the “Messages“), including:

– To inform you of new product or service releases, new partnerships and other key information about the Platforms;
– To inform you of changes to the Platforms or any products or services we offer or provide through it; and
– To provide you with useful information and other information about trends and best practices in the legal field and other relevant topics in connection with our services and the Platforms.

You may choose not to receive Messages in the manner indicated in the “Contact Us” section or through the unsubscribe link included in Messages. However, Gecko may continue to send you Messages to critical technical issues related to the Platforms, or to provide you with important account information (as applicable).

For any other purpose compatible with the purpose of the Platforms or to which you have consented

With your express consent, we may use your Personal Information for any other purpose consistent with the purpose of the Platforms.

If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law.

From time to time, the Application may be offered under a white-label arrangement, meaning it may display the name, logo, and/or trademarks of another party (“White-Label Partner“). While the Application may appear to be branded as provided by the White-Label Partner, this Privacy Policy remains fully applicable to the collection, use, and storing of your Personal Information.

All Personal Information collected through the Application is managed in accordance with the practices outlined in this Privacy Policy by Gecko. The White-Label Partner does not have independent access to your Personal Information unless expressly stated otherwise in this Policy or pursuant to your specific consent.

If you have any questions regarding the relationship between Gecko and a White-Label Partner or how your Personal Information is handled in such a case, please do not hesitate to contact us.

Your Personal Information will not be sold to third parties.

We share your Personal Information with third parties to (i) fulfill our purposes, (ii) respond to requirements or requests made under applicable laws, (iii) perform tasks contracted to us by our customers, and (iv) in accordance with your consent. Gecko may also share Personal Information with its corporate affiliates, parents, and/or subsidiaries.

With your spa manufacturers

When our products that can be connected to the Platforms are integrated in spas manufactured by third parties (i.e., spa manufacturers), such spas being provided to you directly by manufacturers or under such manufacturer’s brands, we may share some of your Personal Information with the relevant manufacturer of your spa model. This may apply when the Application is provided under the name of your spa manufacturer

These Personal Information may be used by the manufacturers to allow them to assist you efficiently in case you might need some assistance or support with your spa. They might also use the Personal Information to improve their spa models and services.

If you give your specific consent (when registering your account on the Application or at another time) by checking the relevant box , the relevant manufacturer of your spa model may use some of your Personal Information (including name and email address) that you’ve provided us for marketing purposes. This may include (i) sending promotional communications regarding new spa models, promotion offers and special events related to spa products; (ii) conducting survey and gathering feedback about spa experience and your preferences regarding spa products; (iii) preparation and sending of personalized offers and information matching your specific interest based on your spa model; (iv) invitation to exclusive events, webinar, or demonstrations related to spa products and services; and (v) any other specific use you might your consent for.

In any case, spa manufacturers will not be allowed to use the Personal Information we provide beyond the scope of the consent you provided. If a spa manufacturer uses your Personal Information beyond the scope of your consent, please contact us immediately with relevant information. From time to time, we might also require specific additional consent depending on the request made by a manufacturer. You will be required to provide your express agreement.

As mentioned above, while this Policy specifically addresses your Personal Information, we might also collect information that are not considered Personal Information according to applicable laws. While we do not require your consent, we wanted to inform you for transparency that some of this data might be shared with your spa manufacturer.

Sharing without your consent

In any case, most of the time, you have already consented to the sharing of your Personal Information, for example by accepting the consent presented to you when you opened your account.

Sometimes applicable laws also allow us to share your Personal Information with third parties without your consent, in specific cases. Specifically, we may need to share your Personal Information, sometimes without your consent:

With our employees

In the course of their work, our employees may need to access your Personal Information, for example, when you contact us or request assistance. Their access is limited to what is necessary for the performance of their duties.

With service providers and strategic partners

Gecko may share your Personal Information with its service providers and partners to enable the provision of the Platforms, such as hosting service providers, authentication service providers, or cybersecurity service providers or payment partners and merchants.

Our service providers may have access to your Personal Information for a limited time in connection with these activities. Where Gecko uses third parties to process any Personal Information, we implement reasonable contractual and technical safeguards, including Privacy Impact Assessments, to ensure that these third parties keep all Personal Information they process strictly confidential.

Please note that these third parties may be located outside of your geographic location (province, territory or country). In such cases, Gecko takes commercially reasonable steps, as described below in the section “Where is your Personal Information hosted and transferred?”.

Where required by applicable law, to enforce our rights, prevent fraud and for safety

We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with the law; (ii) comply with an order of a competent judicial authority in any jurisdiction; (iii) comply with legal process served on Gecko; (iv) protect and defend the rights or property of Gecko ; (v) enforce or verify your compliance with any agreement you have entered into with Gecko, if any; (vi) prevent fraud or other illegal activity perpetrated through the Platforms; or (vii) act in urgent circumstances to protect the personal safety of users of the Platforms or the general public.

During a commercial transaction

We may need to share your Personal Information without your consent in the event of a merger, acquisition or sale of all or part of the business, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.

For other purposes, with your consent

Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific cases where additional conditions apply and through these, we make it clear that specific third parties are processing your Personal Information. As stated above, we will require your consent before sharing your Personal Information with anyone beyond the scope of your initial consent.

We may sometimes include links on the Platforms to third-party sites or services that we do not control. If you click on one of these links, you will be directed to sites that we do not control. Please read the privacy policies of those sites, applications or Platforms that may collect Personal Information to understand their privacy policies and Personal Information collection practices.

Your Personal Information may be disclosed and stored outside your province, state, territory or country of residence.

Our business partners, service providers or relevant spa manufacturers may be located in Canada, in the United States or elsewhere in the world. Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your Personal Information is handled in accordance with the laws applicable to us. Where required by applicable law or where considered relevant by us to ensure the safety of Personal Information, we conduct Privacy Impact Assessments prior to any transfer of Personal Information to another jurisdiction (e.g., outside Quebec for Quebec residents).

We endeavour to limit access to Personal Information by such third parties to that which is necessary to perform the tasks entrusted to them. Please be aware that we also strive to establish contractual agreements with these agents and service providers to ensure the confidentiality and security of your Personal Information. This may include the implementation of robust and effective security measures.

In addition, Gecko will ensure that your Personal Information is adequately protected by appropriate technical, organizational or other legal means. If you would like more information about these security measures, please contact us as indicated in the section “How to contact us”

Personal Information will be retained only as long as necessary for the fulfillment of the Purposes, in accordance with our internal document retention policies, to comply with applicable legal, tax or regulatory requirements, or until you request us to destroy it (unless Gecko is required to keep a copy under applicable laws). At the end of this period, we will destroy, delete or anonymize such Personal Information securely in accordance with relevant legal, regulatory and contractual requirements.

In determining the appropriate retention period for your Personal Information, we take into account the amount, nature and sensitivity of the Personal Information, the potential risk of harm arising from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and the possibility of achieving those Purposes by other means, as well as applicable legal, regulatory, tax, accounting or other requirements.

If you wish to obtain more information on this subject or otherwise request the deletion of your Personal Information under this Policy, we invite you to contact us.

With necessary and appropriate measures

Security is critical to Gecko’s mission, and we take security of data seriously. Gecko uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure.

As such, Gecko has implemented security measures to protect your Personal Information. The standard security measures we use depend on the type of information collected. However, Gecko uses electronic, physical and procedural safeguards to protect your Personal Information. We encourage you to use caution when using the Internet, including not sharing your login or password.

Your Personal Information is hosted by our service providers who are committed to using industry-standard security measures to preserve the integrity and confidentiality of your Personal Information.

Our employees and suppliers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorized access to Personal Information.

We maintain our Platforms and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your Personal Information. These safeguards vary according to the sensitivity of the data in our possession and are based on the best industry standards. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), or if you believe that an unauthorized account has been created using your name, please contact us as described in the “How to Contact Us” section.

Children’s privacy

To the extent allowed by applicable law, Gecko does not allow use of our Platforms, by anyone younger than 18 years old. If we learn that anyone younger than 18 has unlawfully provided Personal Information, we will take steps to delete such Personal information.

If a parent or guardian discovers that his or her minor child has provided us with Personal Information without having obtained the appropriate consent, such parent or guardian has the right, upon request, to inspect the Personal Information provided by the child and/or to require that it be deleted from our files. In this case, we ask the child’s parent or guardian to contact us at the coordinates indicated in the section “How to contact us“.

A cookie is a small text file that is stored in a dedicated location on your computer, mobile device, tablet or other device when you use your browser to visit an online service. Other tracking technologies, such as web beacons, tracking pixels, or tokens, may be used for similar purposes. In this Policy, all such tracking technologies are collectively referred to as “Cookie(s)”. Any Personal Information collected using Cookies by or on behalf of Gecko (if applicable) is treated with the same level of confidentiality as any other Personal Information held by Gecko.

Essential cookies

These Cookies are necessary for the operation of the Platforms and provide basic functions and may include connecting to our Platforms, maintaining your session and preventing security threats. We cannot disable these Cookies in our systems without affecting the operation of the Platforms. However, if you wish, you can block or delete them by changing your browser settings and forcing all Cookies on the Platforms to be blocked.

Non-essential cookies

Non-essential Cookies provide certain non-essential functionalities on our Platforms, for functional, analytical or advertising purposes. We will ask for your consent before using these Cookies.

• Functionality cookies (also known as “preference cookies”): These Cookies are not essential to the provision of our services. They enable us to personalize and improve the user experience. For example, if you have consented to their use, these Cookies will store your communication preferences or provide the integration of content such as videos.

• Performance cookies (also known as “statistical cookies” or “analytical cookies”): These Cookies are not essential to the provision of our services. If you have consented to their use, we use Performance Cookies to understand how you interact with our Platforms, to produce location reports and to have analytical reports on Platforms errors. Our partners may also use this type of Cookie to analyze your use of our Platforms and provide us with information about it. These Cookies are intended for statistical purposes only.

Deactivation of Cookies to which you have consented

With the exception of strictly necessary Cookies, we will only place Cookies on your device with your consent, and these Cookies will be retained for a maximum period of thirteen (13) months from the time they are installed on your device. At the end of this period, your consent will again be required. You can also manage your Cookies by changing the settings on your browser or device. For details on how to configure your browser, please consult the help center for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera. However, if you choose to refuse Cookies, certain pages or sections of our Platforms may not be displayed correctly or certain functionalities may no longer be available. You may also continue to receive advertising, but it will no longer be as tailored to your needs.

You may review, correct, update, modify or delete the Personal Information you have provided to us using your account. Simply contact us and we will assist you.

You can also exercise your rights listed above by sending a written request to our Privacy Officer. He or she will be happy to assist you in any way he or she can.

For your protection, we will only process requests to exercise your rights from the same e-mail address you use to log in to your account. We may also need to verify your identity before processing your request. Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any. We aim to respond to requests promptly, usually within thirty (30) days.

a) Access to and correction of Personal Information

Depending on your situation, it is important that the Personal Information we hold about you is accurate and up-to-date. Please keep us informed of any changes to your Personal Information. By law, you have the right to request access to and correction of the Personal Information we hold about you.

You may view and modify Personal Information by contacting us. If you wish to consult, verify, correct or withdraw your consent to the use of your Personal Information, you may do so by contacting us as provided in the Policy.

We may ask you for specific information to help us confirm your identity and right of access, and to provide you with the Personal Information we hold about you or to make the changes you request. Applicable law may permit or require us to refuse to provide you with access to some or all of the Personal Information we hold about you, or we may have destroyed, erased or made anonymous your Personal Information in accordance with our record-keeping obligations and practices. If we are unable to provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions such as:

– Information protected by solicitor-client privilege.
– Information that is part of a formal dispute resolution process.
– Information about another person that would reveal his or her Personal Information or confidential business information.
– Legal record information: subject to applicable legal limitations, you have the right to access your legal record as it is available to us through the Platforms. If you request a copy of your legal record, it will be provided to you for a reasonable fee. You may request access to your legal record by contacting us. Access to your legal record will also be denied if disclosure is likely to have a material adverse effect on your physical, mental or emotional health in the opinion of a professional, or to reveal personal information about a third party or the existence of such information and disclosure may seriously harm that third party, unless the third party consents or in the event of an emergency threatening the life, health or safety of the person concerned. We use reasonable means to ensure that the information in your legal record is accurate. If you find any inaccuracies, you may request that a note be made on the record indicating the inaccurate information.

We may not accede to a request to amend information if we believe that the amendment would violate a law or legal requirement or would render the information incorrect.

If you are concerned about our response or wish to correct the information provided, you may contact us as provided in this Policy.

b) Withdrawal of consent

Where you have given your consent to the collection, processing and disclosure of your Personal Information, you may have the legal right to withdraw your consent in certain circumstances. To withdraw your consent, if applicable, contact us as set out in this Policy. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service and/or you may no longer be able to access the Platforms. We will explain the consequences at that time to assist you in your decision.

c) Right to de-index

The right to de-index allows you to request that Gecko cease disseminating your Personal Information or de-index any hyperlink attached to your name providing access to Personal Information if such dissemination causes you harm or contravenes the law or a court order.

d) Right to data portability

Depending on applicable laws to you, you may request that Gecko provide you with computerized Personal Information in its possession in the form of an intelligible written transcript in a structured and commonly used technological format. Alternatively, you may simply ask Gecko to confirm the existence of your Personal Information. You may request that such Personal Information be disclosed to any person or organization authorized by law to collect such information.

Gecko will only send you the Personal Information it has collected from you and may exclude certain Personal Information under applicable law (such as Personal Information it has created or inferred about you). Gecko also reserves the right to refuse any such request if it raises serious difficulties under applicable law.

e) Other rights and how to exercise them

Depending on applicable law, you may have other rights with respect to your Personal Information that are not otherwise listed above. This may include:

– Request the deletion of your Personal Information;
– To obtain additional information, for example on the categories of third parties to whom we communicate your Personal Information;
– To withdraw your consent at any time, if we have collected and processed your Personal Information with your consent. Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your Personal Information carried out on the basis of legitimate processing grounds other than consent.
– File a complaint with a privacy control authority, such as a privacy commissioner or the Commission d’accès à l’information

We invite you to write to us with this request and to provide us with the relevant information about that right to enable us to assess its implementation.

To exercise any of your rights (to the extent that they are available), please contact us as indicated in the “How to contact us” section.

You may file a complaint with Privacy Officer of Gecko if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.

You are also entitled by law to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of personal information.

The Personal Information you provide may be used by Gecko for marketing purposes, including, but not limited to, one-time promotional e-mails, direct mailings and business contacts. We offer you several choices regarding our use and disclosure of your Personal Information with respect to marketing, location data, Cookies or online advertising. You may opt-out:

– Our electronic marketing communications: You may opt-out of receiving these emails by sending a deletion request to the email address listed in the “How to contact us” section. You may unsubscribe from our electronic mailing lists at any time. If you so request, we will not use your contact information for future marketing purposes. Please note that we may nevertheless send you messages for administrative purposes or directly related to your use of the Platforms, and you cannot refuse to receive these messages without ceasing to use it.
– Certain location data: You can disable the use of certain location data on your device, for example by disabling our Platforms location services in your browser or mobile privacy settings. We may also retain usage data such as the date and time the application on your device accesses our servers.
– Non-essential cookies: You can deactivate these cookies by following the procedure described in the “How do we use cookies” section.

In certain jurisdictions, applicable laws differentiate between the “controller” and “processor” of Personal Information. In general, Customer is the controller of any Personal Information provided through the Services and Gecko is the processor of such Personal Information. In general, Gecko is the processor and controller of any other Personal Information directly collected through the Platforms.

This section provides additional details about the Personal Information Gecko collects about California consumers and the rights afforded to them under the California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CCPA.”
For more details about the Personal Information Gecko has collected over the last twelve months, including how this Personal Information was collected, please see the information above. Gecko collects this Personal Information for the business and commercial purposes described above. Gecko shares this Personal Information with the categories of third parties described above. Subject to certain limitations, the CCPA also provides California consumers the right to request to know more details about the categories or specific pieces of Personal Information Gecko collects (including how we use and disclose this information), to delete their personal information, correct their personal information that may be occurring, and to not be discriminated against for exercising these rights. Please also note that Gecko does not collect sensitive Personal Information as defined under the CCPA.
As described above, we may incorporate Cookies from certain third parties into our website. These Cookies allow those third parties to receive information about your activity on our Platforms that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our website or on other websites you visit. Under the CCPA, sharing your data through third party Cookies for online advertising may be considered a “sale” or “share” of information, to which you have the right to opt out. You can opt out of these activities by following the instructions in this section.
We may “sell” or share your Personal Information to the following categories of third parties:

• – Ad Networks
• – Analytics providers
• – Marketing providers

Over the past 12 months, we may have “sold” the following categories of your Personal Information to categories of third parties listed above:

• – Usage Information
• – Cookie Information

We have “sold” or shared the foregoing categories of Personal Information for the following business or commercial purposes:

• – Improving the Platforms, including testing, research, internal analytics and product development.
• – Showing you advertisements, including interest-based or online behavioral advertising.

You have the right to opt-out of the “sale” or sharing of your Personal Information. You can opt-out using the following methods:

• – Accessing your Cookie settings as described above.
• – By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

Once you have submitted an opt-out request, we will not ask you to reauthorize the “sale” of your Personal Information for at least 12 months.
To our knowledge, we do not “sell” the Personal Information of minors under 16 years of age.

Subject to certain limitations, the Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers the right to request to access Personal Information we collect about you, correct inaccuracies in your Personal Information, to request a portable copy of your Personal Information, and to delete your Personal Information. You also have the right opt-out from the processing your Personal Information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, which Gecko does not do. You also have the right to opt out of targeted advertising and selling (as such terms are defined under the VCDPA), however, Gecko does not participate in selling of your personal information. To opt out from targeted advertising, please:

• By accessing your Cookie consent settings as described above
• By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard and that complies with the CCPA. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.

Gecko will honor the exercise rights or appeals of decisions of Virginia residents requested by contacting its Privacy Officer as described in this Policy.

Our senior executives have delegated the management of the privacy program to the Privacy Officer. His/her duties consist of managing and monitoring Gecko’s internal personal information management program. It is the Privacy Officer who approves and implements privacy policies and procedures, ensures their proper functioning and reports to Gecko senior management on the effectiveness of the program.

It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of Personal Information.

If you have any questions about any aspect of this Policy, wish to send a comment, lodge a complaint or exercise any of the rights available to you under applicable law, please do so by contacting our Privacy Officer as follows:

Privacy Officer

450 Des Canetons Street, Québec City, Québec, Canada G2E 5W6

Phone: +1 418.872.4411

E-mail: infodataloi25@geckoal.com

Your request may be granted or denied by Gecko in accordance with applicable laws. Gecko will take prompt corrective action upon becoming aware of any breach of this Policy. Gecko shall not be liable for any indirect, incidental, consequential or punitive damages related to this Policy. You may at any time file a complaint with the appropriate authority if you believe that Gecko is not handling your Personal Information in a manner consistent with this Policy or applicable law.

If you have any questions about your personal file on the Platforms or about matters relating to your contractual working relationship with your employer, such as your name, address, telephone number, please contact your employer directly.

If you have any questions regarding a technical problem with the Platforms or your access to or use of its functions, please contact us at the following address: infodataloi25@geckoal.com

We revise the Policy annually to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice either on our Platforms or by e-mail. However, in all other circumstances, the posting of a new version of the Policy on our Platforms or your continued use of the Platforms will suffice as notice and consent to the Policy changes.