Cloud telephony services to meet your expectations

This privacy policy (the "Policy") describes how The Croo Group Inc. ("Croo", "we", "us", or "our") collects, uses and discloses your personal information, and the steps we take to protect it. If you have any questions about our privacy practices, please contact us.

For the purposes of this Policy, any reference to Croo shall be deemed to include its related companies (including any subsidiaries), divisions and other affiliates, suppliers or licensors, and their respective employees, officers, directors, shareholders, agents, subcontractors and other representatives.

This Policy applies to our websites, including https://www.croo.io (the "Websites"), as well as the cloud-based communications platform operated by Croo, its related solutions and any other products or services that Croo makes available to you (together with the Websites, the "Services" and each a "Service"). Croo and its affiliates may share information with each other and use it in a manner consistent with this Policy.

In addition to this Policy, your use of the Services is subject to any other terms of use that may be communicated to you from time to time by Croo.

If you do not agree to the terms regarding our collection, use, disclosure, sharing and management of personal information as set forth in this Policy, please do not use our Services and terminate your visit.

Personal information is generally defined by applicable privacy legislation as information about an identifiable individual. An identifiable person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or by one or more factors specific to that person's physical, physiological, genetic, mental, economic, cultural or social identity.

You may choose to provide us with personal information when you use our Services or access certain features of a Service. This information may include your name, telephone number, e-mail address, mailing address, company name, billing and shipping information, date of birth and other relevant information about you or your company.

Other personal information is automatically collected when you use our websites, including your IP address, the domain name and host from which you access the Internet, the pages of a website you visit, your browsing history, your browser software or operating system and your browser's country setting.

We use the personal information described above for the legitimate purposes detailed in the next section.

We collect personal information that you provide when you use or access certain features of our Services, including when you engage in the following activities:

* Viewing content on our websites.

* Order or purchase our Services.

* Register, provide and administer the Services.

* Provide technical support.

* Subscribe to our mailing lists, newsletters and e-mail communications, including news and updates.

Communication with us to ask a question, submit a comment or make a complaint (customer service).

* Database management and customer relationship management (CRM).

* Promotions or contests.

* Croo job applications.

In general, the personal information collected is used to administer and deliver the Services. To give you a better understanding of how your personal information is used, we explain below in more detail how your personal information is used in connection with specific activities.

Consulting the content of our Websites.
Our Websites offer the possibility to consult and request information on the products and services offered by Croo. When you consult information on our Websites, we collect and store information about your use of the Websites, including (i) the pages visited (ii) the information consulted and (iii) the date and time of access.

Order or purchase our Services.
When you order a Service or request a quote by contacting us through a form on our Websites, by e-mail or by any other means, we use the personal information that is collected to process your request, to complete your transaction using the payment services offered by our preferred payment service provider-partner and, where applicable, to provide any information you may request regarding the Service.

To register, provide and administer the Services.
In some cases, you may be required to register and create a user account that will be used to verify your identity when you access a Service. We also use your personal information to inform you about the administration of your user account and to enable the use of features of a Service that are reserved for certain account holders. In addition, we collect information about your use of the Services to enable the operation of certain features, to improve the user experience, to generally improve and develop our Services, to inform our customers about the overall use of the Services, to provide training and technical support services, to send technical notices, updates and security alerts.

Technical support.
If you require technical support for a Service, we collect your name, company name, title, telephone number and business address. This information is used to enable us to contact you and provide technical support.

Subscription to our mailing lists, newsletters and e-mail communications.
From time to time, we may collect certain personal information in order to send you e-mails regarding our news, products, services or promotions, as well as those of third parties with whom we have a relationship. You may remove your e-mail address from the distribution list at any time by following the instructions provided in each of our e-mails. You may also remove your e-mail address from our distribution list by contacting us as indicated in the "Contact Us" section below. Your request will be processed within the time limits prescribed by law.

Contacting us to ask a question, submit a comment or make a complaint (customer service).
If you choose to send us an electronic feedback form or e-mail us with your comments, questions or feedback, we will collect some of your personal information along with your comments, suggestions or feedback. This personal information will be used to respond to your comments, questions or feedback. In addition, we may retain this information to assist you in the future. We may also use your comments, suggestions or feedback to monitor and/or improve our product and service offerings and our Services.

Customer Relationship Management (CRM) Databases.
When you participate in any of the activities described above, we collect the personal information provided in connection with those activities to complete and update our CRM databases. In this context, the personal information collected is used to manage customer relationships, generate mailing lists, follow up with potential customers or produce reports for internal use on Croo's relationships with its customers in order to monitor and/or improve our Services.

Promotions or contests.
When you participate in an online campaign, referral promotion or contest, prize giveaway, promotion or special offer, we collect personal information about you in order to administer the campaign, promotion, contest or special offer. We use the personal information we collect to contact you or inform you about the campaign, promotion, contest or special offer, to award prizes and generally to administer your participation.

Applying for a job at Croo.
When you apply for a job at Croo, online or otherwise, we collect personal information about you that is included in your application. We use this personal information to evaluate and process your application and your interest in employment with us, to communicate with you about your application and to manage our recruitment needs.

Consult the content of our Web Sites.
When you use our Web Sites, certain information about your user behavior is collected through "cookies" and other technological means, as described below. This personal information is used to personalize the content displayed on our Services and to improve certain recommendations made to you.

IP Addresses and Browsing History.
We collect the Internet Protocol ("IP") addresses of all visitors to our Websites and their browsing history, as well as other information such as the pages visited immediately before or after our Websites, the pages requested, browser type, operating system, your Internet service provider, the number of times you have visited our Websites and the date and average time you spend on our Websites. We use this information to administer, monitor and improve our Web Sites and to analyze trends and usage patterns.

Cookies and other technologies.
Some of our Services use a technology called "cookies". A cookie is a small data file that our Services can send to your browser, which may then be stored on your computer's hard drive to allow us to identify you as a valid licensee. The information recorded by cookies is encrypted, and only Croo is able to read the contents of the cookie file in order to recognize its licensed users. You can set your browser to notify you when you receive a cookie, or to refuse certain cookies. However, if you choose to decline cookies, you may not be able to take advantage of all the benefits and features of our Services.

Professional web analytics solutions.
We may also use third parties, such as Google, to:

* redisplay advertisements ("remarketing") to people who have previously visited our Websites via other websites, including via Google Analytics (web analytics solution); in such a case, relevant third parties, including Google, may display our content on sites across the Internet;

* use the following Google Analytics functions: reporting on impressions recorded on the Google Display Network (a solution for placing ads on a range of news, blog and other specialized websites) to attract more potential customers; integration with DoubleClick Campaign Manager (a management tool comprising, among other things, a range of features used for the delivery, targeting, verification and reporting of campaign ads on websites and mobile devices, and Google Analytics reporting on user demographics and interests); and

* collect, analyze and/or aggregate your personal information (such as IP address, gender, age and interests), including through the creation of Google Analytics reports on user demographics and interests, in order to help us understand how visitors interact with our Website and to improve our products and our Websites.

Companies providing remarketing may combine the use of first-level cookies (e.g., the Google Analytics cookie) and third-party cookies (e.g., the DoubleClick cookie) to (i) collect personal information; and (ii) to inform, optimize and serve advertisements based on your previous visits to our Websites, and (iii) to determine the relationship between recorded visits to our Website and ad impressions, other uses of advertising services and interactions with such ad impressions and advertising services. These companies may also use web beacons or web beacons to report certain information about your visits to our Web Sites and to Web sites that link to and advertise on our site, in order to measure the effectiveness of our advertising. By using the https://adssettings.google.com/ page, you can disable ad personalization and choose certain options regarding ads served on Google's advertising network. https://adssettings.google.com/ to set your preferences.

Principle.
Except as expressly set out in this Policy, we do not sell, rent, transfer or disclose your personal information to third parties for undisclosed purposes without your consent. Access to your personal information is restricted to Croo, including members of Croo's staff, management, technical, sales, marketing and human resources teams who need access to your personal information in order to perform their duties for Croo.

Exceptions.
We may transfer your personal information to:

*service providers,
that is, third parties (or otherwise make it available to them) who provide services on our behalf in Canada, the United States or abroad, including Google for the purpose of using the various Google Analytics features described herein. We provide our service providers with the information they need to fulfill their mandate, and we do not authorize them to use or disclose this personal information for their own commercial or other purposes;

* business partners:
We may disclose your information to our business partners in order to support our business operations and to enable us to provide you with our products and services. These business partners include companies whose products and services integrate with services such as Microsoft Cloud Solutions Provider, Amazon AWS Partner Network, Google Suite and Google Cloud, and various SaaS applications. We do not authorize them to use or disclose personal information for their own marketing or other purposes;

* to entities, organizations and authorities forlegal purposes.
In other words, we and our third-party service providers may disclose your personal information in response to a search warrant or other lawful request or order, or to respond to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by law. We may also disclose personal information as necessary for the purpose of asserting or defending legal claims, or for the purpose of preventing actual or alleged loss or injury to persons or damage to property; and/or

* to another entity in the event that we sell all or part of our business, or if we sell or transfer assets or otherwise participate in a merger or transfer of business. In such a case, we may transfer your personal information to a third party as part of the transaction.

Our Services may contain links to other sites that are not owned or operated by Croo. In addition, links to our Services may appear on third-party websites on which we advertise. Except as provided herein, we will not share your personal information with these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement or recommendation of the linked sites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, obtain or otherwise treat your personal information.

We have established and maintain administrative, technical and physical safeguards to protect your personal information in our custody and control from unauthorized access, use, modification or disclosure. While we strive to protect and maintain the privacy of your personal information, we cannot guarantee the security of your personal information against unauthorized disclosure resulting from software or hardware failure or from other activities that may compromise the security of your personal information.

We have implemented procedures regarding the retention of personal information that are designed to retain personal information only as long as necessary for the fulfillment of the purposes described above or as otherwise required by law.

You have the right to access and update your personal information in our custody and control and to correct inaccuracies in that information, subject to certain exceptions provided by law. You may request access to and updating of your personal information in our custody and control, as well as the correction of errors in such information, by contacting us by e-mail or in writing at the address indicated at the end of this Policy. We may request certain personal information to verify your identity when you request access to or correction of your personal information file.

This Policy may be updated from time to time to reflect changes in applicable law or our personal information practices. The updated Policy will be posted on our Web Sites. We will treat your personal information in accordance with the Policy in effect at the time it is collected, or with your consent.

You may withdraw your consent to the collection, use and disclosure of your personal information at any time by contacting us as set out in the "Contact Us" section below. However, if you withdraw your consent, we may not be able to continue to respond to your inquiries, process any requests made to us or otherwise assist you with respect to our Services.

The Services are provided by:
Le Groupe Croo Inc.
A company incorporated under the laws of Quebec, Canada.

If you have any questions or comments regarding how we handle your personal information, or if you wish to request access to the personal information we hold about you, update or correct it, or file a complaint regarding our handling of your personal information, please contact us as outlined below:

Attention: Chief Privacy Officer

Mailing Address: 33 Prince Street, Montreal, Quebec H3C 2M7

Email: legal@croo.io