At Pacebits Studio, we are committed to providing our clients, customers, members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, members, protecting their personal information is one of our highest priorities.

While we have always respected our clients', customers',members' privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia's Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients, customers, members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients', customers',members' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients', customers',members' personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.

Definitions

Personal Information - means information about an identifiable individual [E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).

Contact information - means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer - means the individual designated responsibility for ensuring that Pacebits Studio complies with this policy and PIPA.

Policy 1 - Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client, customer, member information that is necessary to fulfill the following purposes:

To deliver requests and services of composing gift messages, we may collect gift recipients' names that customers provide, and only use them in writing prompts and generating gift messages using language models.

1.3 Like many businesses, we also collect information through cookies and similar technologies. We automatically collect some information — such as customers' Internet Protocol (IP) address and/or browser, device characteristics, browser profile, and user activities (such as: clicks, mouse position, scroll or keystroke logging) when customers use our service or visit our website. This information does not reveal customers' specific identity (like customers' name or contact information) but may include device and usage information, such as customers' IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when customers use our website and other technical information. This information is primarily needed to maintain the security and operation of our service and website, and for our internal analytics and reporting purposes.

Policy 2 - Consent

2.1 We will obtain client, customer, member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided or it can be implied where the purpose for collecting or disclosing the personal information would be considered obvious and the client, customer, member voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client, customer, member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer, member does not opt-out.

2.4 We may collect, use or disclose personal information without the customer's knowledge or consent in the following limited circumstances:

- When the collection, use or disclosure of personal information is permitted or required by law;

- In an emergency that threatens an individual's life, health, or personal security;

- When the personal information is available from a public source (e.g., a telephone directory);

- When we require legal advice from a lawyer;

- For the purposes of collecting a debt;

- To protect ourselves from fraud or service abuse;

- To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 - Using and Disclosing Personal Information

3.1 We will only use or disclose client, customer, member personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

- To create prompt for AI language model to generate gift notes;

- To troubleshoot on our end to fix any issue or to improve our services.

3.2 We will not use or disclose client, customer, member personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client, customer, member lists or personal information to other parties.

Policy 4 - Retaining Personal Information

4.1 If we use client, customer, member personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client, customer, member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 - Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client, customer, member personal information is accurate and complete where it may be used to make a decision about the client, customer, member or disclosed to another organization.

Policy 6 - Securing Personal Information

6.1 We are committed to ensuring the security of client, customer, member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client, customer, member personal information is appropriately protected:

We have implemented suitable technical and organizational security measures aimed at safeguarding the confidentiality of any personal information we handle. Nevertheless, despite our precautions and diligent efforts to ensure the security of client, customer, member data, it is important to note that no electronic transmission over the Internet or information storage system can provide an absolute guarantee of 100% security. Therefore, we cannot assure or guarantee that malicious actors such as hackers, cybercriminals, or unauthorized third parties will be unable to breach our security measures and illicitly collect, gain access to, steal, or modify customers' information. While we are committed to the utmost protection of customers' personal information, the transmission of such data to and from our website carries inherent risks. It is advisable to access our website only within a secure environment.

6.3 We will use appropriate security measures when destroying client's, customer's, member's personal information such as deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 - Providing Clients, Customers, Members Access to Personal Information

7.1 Clients, Customers, Members have a right to access their personal information, subject to limited exceptions.

- Solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns

7.2 A request to access personal information must be made in writing to dev@pacebits.com and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell clients, customers, members how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, customer, member of the cost and request further direction from the client, customer, member on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client, customer, member in writing, providing the reasons for refusal and the recourse available to the client, customer, member.

Policy 8 - Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer is responsible for ensuring Pacebits Studio's compliance with this policy and the Personal Information Protection Act.

8.2 Clients, Customers, Members should direct any complaints, concerns or questions regarding Pacebits Studio's compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, member may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Pacebits Studio's Privacy Officer: dev@pacebits.com