A. 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 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:

• Names • Phone numbers • Email addresses • Company • Industry

Sensitive Information

We do not process sensitive information.

Accuracy of Information

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.

B. 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 internal analytics and reporting.

Like many businesses, we also collect information through cookies and similar technologies. You can learn more in our Cookie Notice.

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. This log data may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches, and other actions you take, such as which features you use). It may also include device event information (such as system activity, error reports, 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 data may include 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.

• Location Data

We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use. For example, we may use GPS and similar technologies to collect geolocation data based on your IP address. You can opt out of allowing us to collect this information by refusing access or disabling your device’s location settings. However, if you opt out, you may not be able to use certain aspects of the Services.

C. Information collected from other sources

In short: We may obtain limited data from public databases, marketing partners, and other external sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and other third parties. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

In short: We process your information to provide, improve, and administer our Services, communicate with you, ensure security and fraud prevention, and comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons depending on how you interact with our Services, including (non-exhaustive examples):
• To deliver and facilitate delivery of services to you
• To respond to inquiries and provide support
• To send administrative information to you
• To fulfill and manage service-related activities
• To improve our Services and develop new offerings
• To protect our Services, including fraud monitoring and prevention
• To comply with our legal obligations

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) under applicable law. These reasons may include: your consent; compliance with law; fulfilling or entering into a contract with you; protecting your rights; and/or pursuing our legitimate business interests.

If you are located in Canada, this section applies to you.

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 reasonably inferred (i.e. implied consent). You can withdraw your consent at any time.

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 individuals 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 that seeking consent would compromise the availability or accuracy of the information and the collection is reasonable for investigating a breach of an agreement or a violation 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
• 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 specified by regulation
• We may disclose de-identified information for approved research or statistical projects, subject to ethics oversight and confidentiality commitments

In short: We may share information in specific situations as described in this section and/or with the following categories of 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 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 only for the period we instruct.

The categories of third parties we may share personal information with include:
• Cloud computing services
• Communication and collaboration tools
• Data analytics services
• Sales and marketing tools
• Social networks
• Website hosting service providers

Other situations in which we may share your information:

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.

Affiliates
We may share your information with our affiliates. In that case, we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit certain third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, tailor ads to your interests, or send reminders (depending on your communication preferences). These third parties may use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Services or on other websites.

To the extent these online tracking technologies are considered “selling” or “sharing” of personal information or “targeted advertising” under applicable US state privacy laws, you may opt out as described in the section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

For specific details about how we use such technologies and how you can refuse certain cookies, please refer to our Cookie Notice.

In short: If you choose to register or log in using a social media account, we may receive certain profile information about you from that provider.

Our Services may offer you the ability to register and log in using your third-party social media account details (like your Facebook, LinkedIn or X/Twitter login). Where you choose to do this, we will receive certain profile information about you from your social media provider. The information we receive may vary by provider, but may include your name, email address, friends list, profile picture, and other information you choose to make public.

We will use the information we receive only for the purposes described in this Privacy Notice or that are otherwise made clear to you on the relevant Services.

We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how to set your privacy preferences.

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Canada and/or other jurisdictions. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of third parties with whom we share personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), including facilities in other countries.

If you are a resident of the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, please note that these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

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.

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 (for example, tax, accounting, or other legal requirements).

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

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

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. 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. 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.

In short: We do not knowingly collect data from or market to children under 18 years of age (or the equivalent age specified by law in your jurisdiction).

We do not knowingly collect, solicit data from, or market to children under 18 years of age (or the equivalent age as specified by law in your jurisdiction), nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 (or the relevant age in your jurisdiction), or that you are the parent or guardian of such a minor and consent to such minor’s use of the Services.

If we learn that personal information from users under the age of 18 has been collected, 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, please contact us.

In short: Depending on your state of residence in the US or in certain regions (for example, the EU or Canada), you may have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your location.

In some regions, you have certain rights under applicable data protection laws. These may include the right to:
• Request access and obtain a copy of your personal information
• Request correction or deletion
• Restrict the processing of your personal information
• Data portability
• Not be subject to automated decision-making that produces legal or similarly significant effects

In certain circumstances, you may also have the right to object to the processing of your personal information.

Withdrawing your consent
If we are relying on your consent to process your personal information (which may be express or implied consent, depending on applicable law), you have the right to withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

Please note: This will not affect the lawfulness of processing before its withdrawal, and — where allowed by law — will not affect processing carried out on other legal grounds.

Opting out of marketing and promotional communications
You can unsubscribe from our marketing and promotional emails at any time by clicking the unsubscribe link in the emails we send or by contacting us using the details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We may still send you service-related messages (for example, administrative emails about your account or responses to service requests).

Cookies and similar technologies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to remove or reject cookies. 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 Notice.

If you have questions or comments about your privacy rights, you may email us at marketing@researchoninvestment.com.

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 your privacy preference not to have your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will update this Privacy Notice.

California requires us to let you know how we respond to DNT signals. Since there is currently no standard, we do not respond to DNT signals.

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have 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, get a copy of or delete your personal information, and withdraw consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months and whether we collected or disclosed them. (Note: “YES” means we collect it; “NO” means we do not.)

Category A: Identifiers
Examples: Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifiers, online identifiers, IP address, email address, and account name
Collected: YES

Category B: Personal information as defined in the California Customer Records statute
Examples: Name, contact information, education, employment, employment history, financial information
Collected: YES

Category C: Protected classification characteristics under state or federal law
Examples: Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
Collected: NO

Category D: Commercial information
Examples: Transaction information, purchase history, financial details, and payment information
Collected: NO

Category E: Biometric information
Examples: Fingerprints, voiceprints
Collected: NO

Category F: Internet or other similar network activity
Examples: Browsing history, search history, online behavior, interaction with our and other websites, applications, systems, and advertisements
Collected: YES

Category G: Geolocation data
Examples: Device location
Collected: YES

Category H: Audio, electronic, sensory, or similar information
Examples: Images and audio, video or call recordings created in connection with our business activities
Collected: NO

Category I: Professional or employment-related information
Examples: Business contact details in order to provide you our Services at a business level, or job title, work history, and professional qualifications if you apply for a job with us
Collected: YES

Category J: Education information
Examples: Student records and directory information
Collected: NO

Category K: Inferences drawn from collected personal information
Examples: Inferences drawn to create a profile or summary about an individual’s preferences or characteristics
Collected: NO

Category L: Sensitive personal information
Collected: NO

Retention of Personal Information
We retain personal information as needed to provide the Services or for the following categories:

• Category A (Identifiers): We retain personal identifiers for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including maintaining communication with clients and prospects, or as required by applicable law.
• Category B (Customer Records information): We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law.
• Category F (Internet/network activity): We retain internet activity data only for as long as necessary to analyze website performance, improve our services, and comply with applicable legal obligations.
• Category G (Geolocation data): We retain geolocation data only for as long as necessary to analyze website performance, understand audience trends, and comply with applicable legal obligations.
• Category I (Professional/employment information): We retain professional and employment information only for as long as necessary to maintain business relationships, manage communications, and comply with applicable legal or contractual obligations.

Sources of Personal Information
See “WHAT INFORMATION DO WE COLLECT?” for sources of personal information we collect.

How We Use and Share Personal Information
See “HOW DO WE PROCESS YOUR INFORMATION?” for how we use personal information.
See “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” for how and with whom we disclose personal information.

We may allow certain tracking technologies (for example, targeting cookies/marketing cookies, pixels, tags). Some social media features (such as “Like” buttons or “Share” widgets) on our Services may collect your IP address and information about pages you visit and may set a cookie. If you’re logged in to that platform, that activity may be linked to your profile there. Your interactions with those features are governed by the privacy notices of the companies providing them.

We may disclose your personal information to our service providers pursuant to a written contract between us and each provider. We may also use your personal information for our own business purposes, such as internal research for technological development and demonstration. This is not considered “selling” your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
We have disclosed certain categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. The categories of third parties are described in “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

Your Rights (US State Privacy Laws)
Depending on where you live, you may have the right to:
• Know whether we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request deletion of your personal data
• Obtain a copy of personal data you previously provided
• Be free from discrimination for exercising your rights
• Opt out of the processing of your personal data for targeted advertising (or “sharing,” as defined under California law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

In some states you may also have the right to:
• Know which categories of personal data are being processed
• Obtain a list of the categories of third parties to whom we disclosed personal data
• Obtain a list of specific third parties to whom we disclosed personal data
• Obtain a list of third parties to whom we sold personal data
• Review, understand, question, and in some cases correct how your personal data has been profiled
• Limit the use and disclosure of sensitive personal data
• Opt out of the collection of sensitive data and personal data collected through voice or facial recognition features

How to Exercise Your Rights
You can contact us by emailing marketing@researchoninvestment.com, using https://www.researchoninvestment.com/contact-us, or using the contact details at the bottom of this Privacy Notice.

Under certain US state laws, you can designate an authorized agent to make a request for you. We may deny a request from an agent that does not submit proof they are authorized to act on your behalf.

Request Verification
When you make a request, we will need to verify your identity. We will use the personal information provided in the request only to verify your identity or authority. If we cannot verify based on existing information, we may request additional information. If you submit through an authorized agent, we may require written permission from you.

Appeals
Certain US state privacy laws give you the right to appeal if we decline to act on a request. You can appeal by emailing marketing@researchoninvestment.com. We will inform you in writing of any action taken or not taken in response, including an explanation. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine the Light” Law
California Civil Code Section 1798.83 (“Shine the Light”) permits our users who are California residents to request and obtain, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all such third parties. If you are a California resident and would like to make such a request, please contact us using the details in “HOW CAN YOU CONTACT US ABOUT 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 “Last updated” date at the top of this Privacy Notice. If we make material changes, we may notify you 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 stay informed about how we are protecting your information.

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

ROI Research On Investment Inc.
75 Queen Street, Suite 1400
Montréal, Québec H3C 2N6
Canada

Email: marketing@researchoninvestment.com

Based on the applicable laws of your country or (if you are in the US) your state of residence, you may 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. You may also have the right to withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please email:
marketing@researchoninvestment.com