PRIVACY POLICY

Last updated March 10, 2026

This Privacy Notice for Technologies Bernli Inc. (“we,” “us,” or “our”), describes how and why we access, collect, store, use, disclose, and otherwise process (“process”) your personal information when you use our website, mobile or web application, AI-powered personal-finance tools, and related services in Canada (collectively, the “Services”), including when you:

• Visit our website at https://www.bernli.ca or any website of ours that links to this Privacy Notice

• Use Bernli. Bernli is a personal-finance tool that uses AI to help you understand and manage financial information you choose to connect, upload, or enter.

• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices under Canadian privacy laws, including Quebec’s Law 25 and PIPEDA where applicable. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the Table of Contents below to find the section you are looking for.

• What personal information do we process? Depending on how you interact with the Services, we may process account information, contact information, device and usage information, payment and subscription data, financial account and transaction data received through Plaid or similar connections, uploaded documents, and AI inputs and outputs. See “WHAT INFORMATION DO WE COLLECT?” below.

• Do we process any sensitive personal information? Financial account information, account credentials, precise location information, and account-access data may be considered sensitive under Canadian and Quebec privacy laws. We process sensitive personal information only as needed to provide the Services, with your consent where required, or as otherwise permitted by applicable law. See “WHAT INFORMATION DO WE COLLECT?” below.

• Do we collect any information from third parties? Yes. When you connect your bank accounts, we receive financial data (account details, transaction history, balances) from Plaid, Inc. We also receive payment and subscription data from Stripe, Inc. See “WHAT INFORMATION DO WE COLLECT?” and “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” below.

• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. See “HOW DO WE PROCESS YOUR INFORMATION?” below.

• In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. See “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” below.

• How do we keep your information safe? We maintain organizational and technical safeguards designed to protect your personal information, as described in this Privacy Notice. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. See “HOW DO WE KEEP YOUR INFORMATION SAFE?” below.

• What are your rights? If you are in Canada, applicable Canadian and Quebec privacy laws may give you rights regarding your personal information, including rights to access, correction, deletion, consent withdrawal, portability, and information about certain automated decisions. See “WHAT ARE YOUR PRIVACY RIGHTS?” below.

• How do you exercise your rights? You can exercise your rights by visiting https://www.bernli.ca/policies/data-request, emailing [email protected], or contacting our Privacy Officer using the details below. We will verify and respond to requests in accordance with applicable Canadian privacy laws.

Want to learn more about what we do with any information we collect? Review the full Privacy Notice below, including “HOW DO WE PROCESS YOUR INFORMATION?” and “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”.

TABLE OF CONTENTS

• 1. WHAT INFORMATION DO WE COLLECT?

• 2. HOW DO WE PROCESS YOUR INFORMATION?

• 3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

• 4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

• 5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

• 6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

• 7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

• 8. HOW LONG DO WE KEEP YOUR INFORMATION?

• 9. HOW DO WE KEEP YOUR INFORMATION SAFE?

• 10. DO WE COLLECT INFORMATION FROM MINORS?

• 11. WHAT ARE YOUR PRIVACY RIGHTS?

• 12. CONTROLS FOR DO-NOT-TRACK FEATURES

• 13. DO CANADIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

• 14. DO WE MAKE UPDATES TO THIS NOTICE?

• 15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

• 16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

• 17. DATA PORTABILITY

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• phone numbers

• email addresses

• usernames

• passwords

• contact or authentication data

• contact preferences

• financial account details, balances, transaction history, merchant data, budget categories, and other financial information you connect, upload, or enter

• AI prompts, chat messages, generated insights, and feedback you provide

• Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as billing contact details, subscription status, payment method type, invoices, and transaction identifiers. Payment card numbers and security codes are handled by Stripe and are not stored by Bernli. You may find Stripe’s privacy notice here: https://stripe.com/en-ca/privacy.

• Social Login Data. We may provide you with the option to register with us using your existing Google account or other authentication provider supported in the Services. If you choose to register in this way, we will collect certain profile information from that provider, as described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• financial data

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Location Data. We may infer approximate location from your IP address or device settings to maintain security, comply with legal obligations, and tailor the Services. We do not collect precise GPS location unless a feature expressly requests it and you consent through your device or browser settings. If you disable location-related permissions, certain location-dependent features may not work as intended.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports sometimes called “crash dumps”), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

• In Short: We process your information to provide, improve, and administer our Services, communicate with you, connect financial accounts, generate AI-powered insights, process subscriptions, maintain security and fraud prevention, and comply with law. We process personal information for the purposes listed below and for other purposes with your consent or as otherwise permitted by applicable law.

Google API

Our use of information received from Google APIs will adhere to Google’s applicable API Services User Data Policy, including the Limited Use requirements, where those requirements apply to the Services. For more information, see https://developers.google.com/terms/api-services-user-data-policy.

1. To deliver and facilitate delivery of Services to you. We may process your information to provide the requested Services, including connecting financial accounts through Plaid, displaying balances and transaction history, processing payments through Stripe, and generating AI-powered financial insights.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To deliver and facilitate delivery of Services to you. We may process your information to provide the requested Services, including account registration, connected-account features, payment and subscription administration, and AI-powered personal-finance insights subject to our Terms of Service and in-product notices.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences and applicable law. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• In Short: We process your personal information only when permitted under applicable Canadian privacy laws. Depending on the processing activity, this may include your express or implied consent, processing necessary to provide the Services you request, compliance with law, fraud prevention and security, or other processing permitted without consent by applicable law.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can reasonably be inferred (i.e., implied consent). You can withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Examples include: account and subscription processing to provide the Services; Plaid connections, optional cookies, and certain AI features with your consent where required; security, fraud prevention, service improvement, and troubleshooting where permitted by law; and tax, accounting, regulatory, dispute, and legal-response activities to comply with law or establish, exercise, or defend legal rights.

1. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We process your personal information when we have your express or implied consent, when processing is necessary to provide the Services you request, when we need to comply with law or protect rights and security, or when applicable Canadian privacy laws permit processing without consent.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time as described in “WHAT ARE YOUR PRIVACY RIGHTS?” below.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

1. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows:

• Financial Data Aggregation — Plaid, Inc. — used to connect your bank accounts in read-only mode. Plaid receives your bank login credentials directly, not through Bernli, and provides us with account details, balances, transaction history, and related financial data needed to operate connected-account features. Your use of Plaid is also subject to Plaid’s End User Privacy Policy and applicable Plaid terms presented during account connection.

• Allow Users to Connect to Their Third-Party Accounts — Google account

• Invoice and Billing — Stripe, including payment processing, subscription management, invoicing, tax, fraud-prevention, and chargeback support

• Cloud Computing Services — Google Cloud Platform

• Financial Data Aggregation — Plaid, Inc. — used to connect your bank accounts in read-only mode. Plaid receives your bank login credentials (directly, not through Bernli), and provides us with account details, balances, and transaction history. See Plaid’s End User Privacy Policy: https://plaid.com/legal/\#end-user-privacy-policy.

• Functionality and Infrastructure Optimization — Amazon Web Services and Google Cloud Storage

• Invoice and Billing — Stripe

• User Account Registration and Authentication — Google Sign-In and Google OAuth 2.0

• Website Hosting — Supabase and Cloudflare

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Cross-Border Data Transfers

Technologies Bernli Inc. is based in Gatineau, Quebec, Canada. To provide our Services, your personal information is communicated to and processed in the United States. The following service providers store or process your data in the United States:

Why your data is transferred: These transfers are necessary to provide you with the Services, including hosting the application, processing payments, connecting your bank accounts, and generating AI-powered financial insights. Without these transfers, we would be unable to operate the Services.

How we protect your data during transfer:

• All data is encrypted in transit using TLS 1.2 or higher.

• All data is encrypted at rest using AES-256 encryption.

• Your rights regarding cross-border transfers: Under Quebec’s Law 25 and other applicable Canadian privacy laws, you have the right to be informed when your personal information is communicated outside Quebec or Canada, as applicable. You may exercise your rights regarding this data by contacting us at [email protected] or visiting our Data Request page at https://www.bernli.ca/policies/data-request. Because U.S.-based processing is described as necessary for core Services, you may need to stop using the Services or delete your account if you do not want your personal information processed in the United States.

• Each service provider maintains independent security certifications (SOC 2 Type II, PCI-DSS, and/or ISO 27001) that are audited annually by independent third parties.

• Plaid access tokens are additionally encrypted at the application layer using AES-256-GCM before storage.

• Google Cloud AI (Gemini) processes your data as described in our applicable Google Cloud agreement and configuration, including any applicable retention, caching, and model-training restrictions in that agreement.

1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Based on our current practices, we do not use analytics cookies, advertising cookies, tracking pixels, web beacons, or third-party cookies. We do not track your behavior across websites for advertising purposes. If we add non-essential cookies or similar technologies in the future, we will update our Cookie Policy and obtain consent where required under Canadian privacy laws. Where our systems detect a Global Privacy Control (GPC) signal, we treat it as a privacy-preference signal and reject non-essential cookies to the extent technically feasible.

We use cookies to maintain the security of our Services and your account, authenticate your sessions, and save your interface preferences. Our cookies fall into two categories:

• Essential cookies (always active): Authentication session tokens, CSRF protection tokens, trusted device tokens (for multi-factor authentication), and your cookie consent preferences. These are strictly necessary for the Application to function securely.

• Preference cookies (require your consent): Interface settings such as date range selections, time period preferences, sidebar state, column visibility, and language preference. These are only set if you accept them through our cookie consent banner.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to help analyze personal-finance information and provide automated insights. This Privacy Notice explains how personal information is processed for AI Products; your use of the Services and AI Products is also subject to our applicable Terms of Service and in-product notices.

For full details on every cookie we use, including names, durations, and security attributes, please see our Cookie Policy: https://www.bernli.ca/policies/cookie-policy.

1. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

Our AI Products: Our AI Products are designed for the following functions:

AI-powered financial assistant features

Automated financial categorization and insights

Natural-language explanations of connected financial data

Budgeting, spending, and cash-flow trend analysis

• Document and statement analysis where you upload files for that purpose

• How We Process Your Data Using AI: Personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties. AI outputs may be inaccurate, incomplete, or based on limited information and should not be treated as financial, legal, tax, investment, or other professional advice. Where applicable Canadian privacy law gives you rights regarding automated decision-making, you may exercise those rights using the request procedures in this Privacy Notice.

• Our Services may offer you the ability to register and log in using a supported third-party account, such as Google Sign-In. Where you choose to do this, we will receive profile information from the authentication provider, which may include your name, email address, account identifier, profile picture, and other information you authorize the provider to share with us.

1. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a supported third-party account, we may have access to certain information about you from that authentication provider.

Our Services offer you the ability to register and log in using supported third-party account details, such as Google Sign-In. Where you choose to do this, we will receive certain profile information from the authentication provider. The profile information we receive may vary depending on the provider and your settings, but may include your name, email address, account identifier, profile picture, and other information you authorize the provider to share with us.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party authentication provider. We recommend that you review that provider’s privacy notice to understand how it collects, uses, and shares your personal information, and how you can set your privacy preferences in the provider’s services.

1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law. Specific retention periods are listed below.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). The specific retention periods for each category of personal information are as follows:

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Note regarding third-party retention: Third-party service providers may retain personal information, de-identified information, aggregated information, or records independently of Bernli in accordance with their own privacy notices, contractual commitments, and legal obligations.

1. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We implement industry-standard security measures including encryption at rest and in transit (TLS 1.2+), multi-factor authentication, CSRF protection, rate limiting, input validation, and regular security reviews. We use role-based access controls and principle of least privilege for all internal data access. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Data Breach Notification

In the event of a security incident involving your personal information, we will assess the incident under applicable Canadian privacy laws and, where the incident creates a real risk of significant harm or otherwise triggers a notification obligation, notify affected individuals and applicable Canadian regulatory authorities within the timelines required by law. Specifically:

• Quebec residents (Law 25): We will notify the Commission d’accès à l’information du Québec (CAI) and affected individuals promptly, without undue delay.

• Canadian residents (PIPEDA): We will notify the Office of the Privacy Commissioner of Canada (OPC) and affected individuals as soon as feasible after determining a breach has occurred.

Breach notifications will include information required by applicable Canadian privacy laws, which may include the nature of the breach, the categories of personal information affected, the measures we have taken or propose to take to address the breach, and recommendations for steps you can take to protect yourself. For more details, contact our Privacy Officer at [email protected].

1. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age specified by applicable Canadian law.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age specified by applicable Canadian law. By using the Services, you represent that you are at least 18 or the equivalent age specified by applicable Canadian law. If we learn that personal information from users less than 18 years of age or the equivalent age specified by applicable Canadian law has been collected without any required consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age specified by applicable Canadian law, please contact us at [email protected].

1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: If you are in Canada, you have rights under applicable Canadian and provincial privacy laws that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, subject to applicable law and our retention obligations.

Under Canadian privacy laws, including Quebec’s Law 25 and PIPEDA where applicable, your rights may include the right (i) to request access to and obtain a copy of your personal information, (ii) to request correction or deletion, (iii) to withdraw consent, subject to legal or contractual restrictions and reasonable notice, (iv) if applicable, to data portability, and (v) to receive information about automated processing used to make a decision about you. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors and parameters, and offer a simple way to submit observations or request review where required by law. You can make such a request using the contact details provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or through https://www.bernli.ca/policies/data-request.

We will consider and act upon any request in accordance with applicable Canadian privacy laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable Canadian privacy law, you have the right to withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. You can withdraw your consent by contacting our Privacy Officer at [email protected], using https://www.bernli.ca/policies/data-request, or, where available, through the relevant in-product setting.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting our Privacy Officer at [email protected]. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and delete or de-identify personal information from active systems as described in “HOW LONG DO WE KEEP YOUR INFORMATION?” above. However, we may retain some information in our files, backups, or legal records to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and to reject cookies, and you may use our Cookie Preference Settings where available. If you choose to remove or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Policy: https://www.bernli.ca/policies/cookie-policy.

If you have questions or comments about your privacy rights, you may email us at [email protected].

1. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal a privacy preference. At this stage, no uniform Canadian-law technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. This does not limit our treatment of Global Privacy Control signals where described below or required by applicable Canadian privacy law.

Global Privacy Control: We recognize Global Privacy Control (GPC) signals as privacy-preference signals where required by applicable Canadian privacy law and where technically feasible. Because we do not use analytics cookies, advertising cookies, tracking pixels, web beacons, or third-party cookies based on our current practices, a GPC signal is treated as a request to reject non-essential cookies. For more information about GPC and how to enable it, visit https://globalprivacycontrol.org.

1. DO CANADIAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are in Canada, applicable Canadian and provincial privacy laws, including Quebec’s Law 25 and PIPEDA where applicable, may give you the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, request deletion, withdraw consent, request a portable copy of certain personal information, and receive information about certain automated decision-making. These rights may be limited in some circumstances by applicable law. More information is provided below.

Your Canadian Privacy Rights

You have rights under Canadian privacy laws, including Quebec’s Law 25 and PIPEDA where applicable. These rights are not absolute, and in certain cases we may decline or limit a request as permitted or required by law. These rights may include:

• Right to know whether or not we are processing your personal information

• Right to access your personal information

• Right to correct inaccuracies in your personal information

• Right to request deletion of your personal information, subject to legal retention obligations

• Right to obtain a portable copy of certain personal information you previously provided to us, where required by applicable Canadian privacy law

• Right not to be penalized for exercising your rights, subject to limits permitted by law

• Right to withdraw consent where processing is based on consent, subject to legal or contractual restrictions and reasonable notice, and to receive information about automated processing used to make a decision about you where required by law

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting https://www.bernli.ca/policies/data-request, by emailing us at [email protected], or by contacting our Privacy Officer using the contact details at the bottom of this document.

You can manage non-essential cookies through Cookie Preference Settings, enable Global Privacy Control where supported, or contact us using the request methods described above to withdraw consent or object to processing where applicable under Canadian privacy law. If the relevant processing is not cookie-based, disabling cookies alone may not be sufficient, and we will process your request through the applicable request channel.

We will treat a Global Privacy Control (GPC) signal as a privacy-preference signal where required by applicable Canadian privacy law and where technically feasible.

You may designate another person to make a request on your behalf where permitted by applicable Canadian privacy law. We may deny a request from a representative who does not provide proof that they have been validly authorized to act on your behalf.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through a representative, we may need to collect additional information to verify your identity before processing your request and the representative may need to provide written authorization from you to submit the request on your behalf.

Complaints and Escalation

If we decline to take action regarding your request, you may ask us to reconsider by emailing [email protected] or using https://www.bernli.ca/policies/data-request. We will inform you in writing of any action taken or not taken in response, including a written explanation where required by law. If you remain dissatisfied, you may submit a complaint to the applicable Canadian privacy regulator, such as the Commission d’accès à l’information du Québec or the Office of the Privacy Commissioner of Canada, as applicable.

1. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:

Technologies Bernli Inc. 3-396 boulevard de la cité Gatineau, Quebec J8T 8A1 Canada

Privacy Officer

In accordance with Quebec’s Law 25 (Act respecting the protection of personal information in the private sector) and the federal Personal Information Protection and Electronic Documents Act (PIPEDA), Technologies Bernli Inc. has designated a Privacy Officer responsible for overseeing compliance with applicable privacy laws and handling all privacy-related inquiries, complaints, and privacy-rights requests.

Name: Samuel Bernier Title: Privacy Officer, Technologies Bernli Inc. Email: [email protected] Mailing Address: Technologies Bernli Inc. 3-396 boulevard de la cité Gatineau, Quebec J8T 8A1 Canada

You may contact our Privacy Officer at any time to exercise your privacy rights, submit a complaint, or ask questions about how your personal information is collected, used, or disclosed.

1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information, subject to applicable Canadian privacy laws. You may also have the right to withdraw your consent to our processing of your personal information and to request a portable copy of certain personal information, where applicable. These rights may be limited in some circumstances by applicable law. To request to review, update, delete, or export your personal information, please visit: https://www.bernli.ca/policies/data-request.

1. DATA PORTABILITY

In accordance with Quebec’s Law 25 (s. 27) and other applicable Canadian privacy laws, where they apply, you may have the right to receive a copy of certain computerized personal information you have provided to us in a structured, commonly used, and machine-readable format (such as CSV or JSON).

To exercise your right to data portability, please contact our Privacy Officer at [email protected] or submit a request through our data request page at https://www.bernli.ca/policies/data-request. In your request, please specify the data you would like to receive and your preferred format (CSV or JSON).

We will respond to your request within the period required by applicable law, including the 30-day response period under Quebec’s Law 25 where it applies. If we need additional time due to the complexity of your request or another legally permitted reason, we will notify you within the initial response period.

Please note that the right to data portability generally applies to personal information that you have directly provided to us or that is otherwise covered by applicable portability laws (such as profile information, uploaded financial documents, and transaction data). It may not extend to information that has been inferred, derived, or generated by our systems (such as AI-generated insights or dashboard configurations), except where applicable law requires otherwise.

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