Policy

Privacy Policy

5C Respects Your Privacy

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‍Last Updated: September 23, 2025

5C AI Group Inc. or its subsidiaries or affiliated companies (collectively “5C”, “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This privacy policy (“Privacy Policy”) will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Notice at Collection: At or before the time of collection, California residents have a right to receive notice of our practices, including the categories of personal data to be collected, the purposes for which such information is collected or used, their rights with respect to such information, whether such information is sold or shared, and how long such information is retained. You can find those details in this statement by clicking on the foregoing links.

1. Important Information and Who We Are

a. Purpose of This Policy. This Privacy Policy aims to give you information on how 5C collects and processes your personal data. Notably how we collect, use, disclose, retain, and destroy, in compliance with applicable privacy laws, any data you may provide through our websites, when you sign up to our newsletter, apply for employment and/or work at 5C or purchase a product or a service or when you otherwise interact with us (collectively, the “Services”).

Our businesses and websites are not intended for children and we do not knowingly process data relating to children.

In providing our Services, 5C may collect personal data on behalf and as a service provider for third parties. This Policy does not govern any information we collect on behalf of third parties, and you should consult such third parties’ privacy policies to become familiar with their data collection and usage practices.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

b. Definitions. The following definitions shall apply to this Privacy Policy:

“Personal data” means any information classifies as personal data, personal data, personally identifiable information, or similar terms under applicable data privacy and information security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as aggregated, anonymized, or deidentified data. For avoidance of doubt, nothing in this Privacy Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to 5C generally or in any specific context.
“Processing” means any operation or set of operations which are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“You” or “Your” means an identified or identifiable individual on whom 5C processes personal data. It includes, but is not limited to, clients of 5C, employees of clients, past, present or future members of the 5C team, visitors to 5C’s internet site, suppliers, contractors and sub-contractors. It does not include data where the identity has been removed (anonymous data).

c. Controller of Personal Data. 5C is the controller and responsible for your personal data.

d. Data Privacy Officer. 5C currently has one Privacy Officer. Contact details are as follows:

Email: privacy@5c.ai
Postal Address: 9300 TransCanada Hwy, Saint-Laurent, Quebec Canada H4S 1K5

Please contact the Privacy Officer with any questions about the application of this Privacy Policy or if you have any concerns that this Privacy Policy is not being or has not been complied with. Your Duty to Inform Us of Changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

f. Third Party Content and Privacy Statements. Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their content or privacy statements and assume no responsibility for any personal data collected, stored, or used by any third party as a result of you visiting third-party websites. We encourage you to read the privacy policy or notice of every website you visit or service you use.

2. The Personal Data We Collect About You

We may process different kinds of personal data about you which we have grouped together as follows:

a. Identity Data, which includes first name, last name, username or similar identifier;

b. Contact Data, which includes billing address, delivery address, residential address, email address and telephone numbers;

c. Financial Data, which includes bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;

d. Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us;

e. Technical Data, which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites;

f. Profile Data, which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

g. Usage Data, which includes information about how you use our websites, products and services, including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse-overs); and

h. Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also process aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data (described above) with that of other users to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be processed in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

3. If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

a. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

purchase our products or services;
create an account on our websites;
apply for, or accept employment at 5C;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.

b. Third Parties or Publicly Available Sources. We may receive personal data about you from third parties, notably analytics providers.

c. “Cookies” and Other Automated Technologies. Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. Cookies have many different functions, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience or providing us information about how users navigate through our Services. We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.

To learn more about the cookies we utilize and their purposes, review our Cookie Policy.

5. How We Process Your Personal Data

a. General Approach and Guidelines. We will only process your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:

Where we need to perform the contract that we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where you have provided us your consent to such processing.
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. When we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time by contacting us.

b. Purposes for Which We Will Process Your Personal Data. We have set out below, in a table format, a description of all the ways we may process your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

In this Privacy Policy, a legitimate interest means our interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Note that where permitted by applicable law, we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of Data	Lawful Basis for Processing Including Basis of Legitimate Interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products/services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To process your application for employment with us	(a) Identity (b) Contact	Your consent and our legitimate interest (to operate our business)

c. Third Party Information Collection. From time to time, you may provide 5C with the personal data of individuals other than yourselves. You agree to obtain, prior to disclosing such information to 5C, the knowledge and consent of each individual to the disclosure, and to subsequent use by 5C, of such personal data, in accordance with this policy, unless otherwise permitted by law.
5C’s internet site may include widgets, such as interactive mini programs that run on 5C’s internet site. These features may collect your IP address, which page you are visiting on 5C’s internet site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on 5C’s internet site. Your interactions with these features are governed by the privacy policy of the company providing such service.

d. Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of Your Personal Data

We may disclose personal data for a variety of business purposes, including for the reasons set forth below.

a. To Business Partners, Affiliates, Advisors, and Related Entities. We may collect personal data from and disclose personal data with our business partners and affiliates; advisors such as legal advisors and financial advisors; related entities, subsidiaries, joint ventures, or other companies under common control; and other third parties. We may combine that personal data with other personal data we collect about you, but we will always use the information as described in this Policy.

b. As Part of Business Transactions or Mergers. We reserve the right to disclose your personal data to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal data in connection with the diligence. If we close a transaction, the third party may transfer personal data, which we would use as described in this Policy.

c. As Required by Law, for Legal Purposes, and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: comply with regulatory, administrative, or law enforcement requests and legal process, such as a court order or subpoena, or the requests of governmental or regulatory agencies (whether domestic or foreign); respond to your requests, requests of others, or will lessen the burden of anticipated or formal legal requests; or protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

d. As Part of Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may disclose your personal data with third parties as part of the sale or reorganization process.

e. To Service Providers. We use service providers to perform various functions on our behalf. We may also receive personal data from service providers.

7. Your Privacy Rights

a. Your Legal Rights. Under certain international and U.S. state privacy laws, you may be entitled to various privacy rights. Although they may not all apply to us, 5C values your privacy, and we therefore afford privacy rights to all individuals regardless of their residency. The chart below explains these rights, although some exceptions may apply:

CONSUMER RIGHT	EXPLANATION
Right to Know/Access	You may have the right to confirm whether we are processing your personal data, the right to know specific pieces of personal data we have collected about you, to know the categories of personal data we are processing or have processed, and the right to access that data. You also have the right to know the third parties, or categories of third parties, to whom we have disclosed your personal data.
Right of Correction	You may have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
Right of Deletion	You may have the right to delete your personal data provided by you or obtained about you.
Right to Restrict or Object	You may have the right to object to the processing of your personal data that is based on legitimate interests or your consent.
Right of Portability	You may have the right to obtain your personal data in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance.
Right to Withdraw Your Consent	You may have the right to withdraw your consent to our processing of your personal data. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
Right to Opt Out	(1) You may have the right to opt-out of the processing of your personal data for the purposes of: Targeted advertising or sharing; (2) The sale of personal data; and/or (3) Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. At this time, we do not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you.
Right to Lodge a Complaint	You may have a right to lodge a complaint with a competent supervisory authority if you believe our processing of your personal data violates applicable law. Links to webpages for the relevant supervisory Canadian and European supervisory authorities are below: Canada’s Office of the Privacy Commissioner EEA and EU Data Protection Authorities (DPAs) Swiss Federal Data Protection and Information Commissioner (FDPIC) UK Information Commissioner’s Office (ICO) While you have the right to make a complaint at any time to your national supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your national supervisory authority, so please do not hesitate to contact us in the first instance.

‍b. Sensitive Data. We will process sensitive data (as the term or its equivalent is defined by applicable privacy laws) in accordance with any applicable privacy laws. In some instances, that means we will not collect sensitive data without first obtaining your consent or providing you with the right to opt out.

c. Exercising Your Rights. To exercise your rights, to know/access, correction, deletion, restrict, or portability, as applicable, please contact Customer 5C Support. To exercise your right to opt-out of sales or sharing of your personal data for targeted advertising please visit our Your Privacy Choices page. Please note that the use of some pop-up blockers may disable or impede the functionality or visibility of the Your Privacy Choices page, link, or icon.

d. Verification. To ensure the protection of your personal data, we may need to verify that the individual submitting a request is the consumer to whom the request relates prior to processing the request, or an authorized agent. To verify a consumer’s identity, we may request up to three pieces of personal data about you to compare against our records when you make a request.

Making a verifiable consumer request does not require you to create an account with us. However, we may require that you access a previously existing account where necessary to submit the request.

We will only use personal data provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of consumers where we have reason to believe a request is fraudulent.

You may choose a person or business that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.

8. Your Privacy Options and Configurations

Depending on the device(s) you use to access the Services, you may be able to select certain privacy choices or configuration, which are further described below.

a. Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Policy).

b. Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.

c. Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.

d. Cookies and Personalized Advertising. You may stop or restrict the placement of cookies and tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions provided by Android or iOS. You can find out more about cookies and how to manage them by visiting https://ico.org.uk/for-the-public/online/cookies/.

9. Supplemental Provisions for California Residents

This section supplements our Policy and only applies to our processing of personal data that is subject to California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. as amended by the California Privacy Rights Act and implementing regulations (collectively, the “CCPA”).

a. Collection of Personal Data. In the preceding 12 months, we have collected personal data from the following categories identified in Section 2, which are described using the terms identified under the CCPA: identifiers, personal data, commercial information, internet or other similar network activity, professional or employment related information, and inferences.

b. Disclosure of Personal Data. In the preceding 12 months, we have disclosed personal data in the following categories: identifiers, personal data, commercial information, internet or other similar network activity, geolocation data, and inferences with service providers. We disclose content posted on our social media platforms (e.g., if a consumer “comments” on a story) with other consumers. Such posts may include information in the category of personal data and identifiers, but the content depends on the individual posts.

c. Sharing and Sales Personal Data. In the preceding 12 months, we have shared for cross-contextual behavioral advertising personal data in the following categories: personal data, identifiers, commercial information, and internet or similar networking activity.

d. Sales of Personal Data. In the preceding 12 months, we have not sold the personal data of any consumer for monetary consideration. However, our use for cookies and other tracking technologies may be considered a sale of personal data under the CCPA. Categories of personal data that we have sold under the CCPA include the following: identifiers, personal data, commercial information, internet or similar network activities, and inferences. Categories of third parties to whom personal data is sold under the CCPA include data analytics providers and advertising and marketing providers.

e. Sensitive Data. If we process sensitive data as defined by California law, we will only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Restrict request is available.

10. International Transfers (Transferring Data Outside of the EEA)

We share your personal data within the entities comprising 5C AI Group, which are located in the following jurisdictions: Canada and the United States of America. While some of those entities are located outside of the European Economic Area (EEA), this will involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Where necessary by law, we formalize these transfers with the appropriate transfer mechanism.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

11. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. How Long Will You Use My Personal Data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for; including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. Modifications to This Privacy Policy

5C reserves the right to modify or update this Privacy Policy at its entire discretion in order to follow the evolution of our business activities and privacy legislation, by posting changes on our website and a notice will be available on our website home page. If the modifications are material or require your consent, you shall be informed by email or as otherwise permitted by applicable law.