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Privacy Policy

Koddian is committed to protecting your privacy.

Last updated: May 2026

This privacy policy contains information about the processing of personal data carried out by Solutions Kumojin inc. and all its affiliated companies ("Koddian" or "we") and about how you can exercise your rights regarding that personal data.

  1. 1.Transmission of personal information

    Koddian protects the personal information you entrust to us. If you voluntarily communicate personal or highly confidential information to a member of our staff, through an electronic form or email, only the information required to allow staff to respond to your request is used. We handle electronic correspondence with the same confidentiality measures as other written documents. This information is shared with third parties only with your consent or when permitted by law.

    The Act respecting access to documents held by public bodies and the protection of personal information grants you the following rights:

    • Respect for the confidentiality of your personal information
    • Access to our administrative documents and your personal information
    • Correction of your personal information if it is incomplete, inaccurate, ambiguous, or if its collection, disclosure, or retention is not authorized by law

    You may submit written comments about this privacy policy by mail or email to the person responsible for access to information:

    Mr. Lukasz Kokot
    CTO
    lkokot@kumojin.com

    SOLUTIONS KUMOJIN INC.
    200-125 Charest Est Blvd.
    Québec, QC G1K 3G5

    To make a request for access to documents or correction of personal information, you may submit an access to information request.

  2. 2.When does this policy apply?

    This Policy applies in the context of our digital marketing activities, such as the use of cookies, or when you interact with us through our social media, by email, or otherwise (our "digital services"). Here are some examples of our digital services:

    • Your browsing and use of our websites
    • Our use of personalized advertising
    • Our subscription list
    • The submission of a job application

    This Policy applies only to the processing of "personal data". By "personal data", we mean any data that allows us to identify you directly or indirectly, including cookies.

  3. 3.When does this policy not apply?

    This Policy also does not apply to the processing of your personal data carried out by websites, applications, or services provided by independent third parties.

    For example, if you click on a link on our website that leads to a third-party site, this Policy does not apply to the processing of your personal data by that third party. Third parties include social networks and services referenced through our digital services.

    Please review the privacy policies of these third parties to learn more about how they process your personal data.

  4. 4.Data automatically exchanged when accessing the site

    When you access the kumojin.com site, your computer and our server automatically exchange data without any action on your part. This exchange in no way allows us to personally identify you. It is necessary for the server to send you a file compatible with the computer equipment you are using. The data exchanged is as follows:

    • Identification of your Internet service provider (domain name)
    • IP address, the numeric address that identifies and locates your computer
    • Browser (Chrome, Explorer, etc.) and operating system (Windows, Mac OS, etc.) you use
    • Date and time of your access to the site
    • Web pages you visit
    • Address of the site that directed you to Koddian's site, if applicable

    This information is used in anonymous form for statistical purposes, including counting the number of visitors and identifying the most visited pages. To this end, Google Analytics, a website analysis tool, allows Koddian to produce reports on navigation within its site. You can install the Google Analytics browser opt-out add-on on your computer. This add-on prevents Google Analytics from recording data about your visits.

  5. 5.Use of cookies

    A "cookie" contains data collected from the websites you visit and is stored as a small text file in your browser. In this Policy, the term cookie includes tracking technologies such as invisible pixels and web beacons. If you would like more information about cookies, you can consult the information sheet published on the website of the Office of the Privacy Commissioner of Canada.

    Some of the data referred to in this Privacy Policy may not be protected by the laws that apply to you. This Privacy Policy is for informational purposes only.

    We use the cookies described below for the reasons indicated.

    Essential

    Essential cookies are necessary for your use of our digital services. These cookies cannot be disabled. They enable, for example, navigation from one page to another.

    Functional

    These cookies collect data to provide you with certain features, such as remembering your choices, preferences, and settings, in order to improve and personalize your experience. In Europe, we install these cookies based on your express consent. You may withdraw your consent at any time.

    Analytics

    We use Google Analytics to obtain statistics on the performance of our digital services. This data shows key metrics such as the number of visitors to the website and our social media, peak traffic hours, conversion rates, geographic location of users, and their preferences. This data helps us understand how you use our services in an anonymized way so we can improve your experience.

    Marketing

    As part of our digital advertising activities, we use advertising cookies and similar tracking technologies. In the interest of transparency, we adhere to the AdChoices self-regulatory program, which allows Canadians to better understand and control the ads presented to them. To learn more about this program, visit the AdChoices page of the Digital Advertising Alliance of Canada.

  6. 6.What personal data do we collect and for what purposes?

    We collect your personal information in order to provide you with digital services, which includes marketing our products and services, as well as responding to your requests or interacting with you on social networks.

    When we collect this personal information, we act as the data controller for individuals located in the European Union, the United Kingdom, and all other relevant regions ("Europe"). As such, we determine the legal bases for processing your personal data.

    When we process your personal data based on your consent, you may withdraw that consent at any time by contacting us at info@koddian.io. Some services may not be available without your consent to data processing.

    Personal data relating to your communications

    Examples: email addresses, information related to your social networks, content of emails and messages.

    We collect and process your personal data when you communicate with us by email, through social media, or otherwise. If you communicate with us via our social media, we may have access to the personal data you make publicly available. We collect the personal data you choose to provide and do not use it for other purposes. If you are located in Europe, we respond to your requests based on our legitimate interests, or based on your express consent in certain cases.

    Personal data used for digital advertising purposes

    Examples: browsing preferences, profession, location, browsing habits, interests, emails.

    We use targeted advertising cookies to offer you advertising personalized to your interests and to present you with advertising about our services and products. In Europe, the use of targeted advertising is subject to your explicit consent. As part of our newsletter, we use your email to send you promotional communications. In Europe, these communications are only sent with your express consent. You may unsubscribe at any time by following the link provided in the email or by writing to us at info@koddian.io.

    Personal data relating to employment

    Examples: professional and academic experience, letters of recommendation, curriculum vitae, cover letters.

    If you apply for a position listed on our website, we collect the personal data you provide to us for that purpose. If your application is successful, you may be required to provide personal information to complete a criminal background check and verification of professional experience. We only process your personal data for the purposes of your job application, but we may retain your application for a few months if we believe reasonably related positions will be available soon, unless you indicate otherwise. If you are located in Europe, we process your employment-related personal data based on our legitimate interests: responding to your application and filling our open positions.

    Electronic personal data

    Examples: technical logs, IP address, device ID, browser type and configuration, operating system, mobile device type, number of visitors, number of pages viewed, visit duration, websites visited, frequency of use, geographic location, language preferences, and device information.

    We automatically collect information relating to usage and technical connection through cookies when you visit our website. This personal data is used to secure our services, manage the performance of our services, and provide you with digital services. In Europe, we process this personal data on the legal basis of our legitimate interest in monitoring and securing our services.

  7. 7.What is personalized advertising and how do we use it?

    Targeted advertising works through advertising cookies that collect information about your browsing habits. This way, the ads you receive are tailored to your interests. Without targeted advertising, you would still receive ads, but they would not be relevant to you.

    To learn more, you can also consult the resources published by the Digital Advertising Alliance of Canada.

    Here are some examples of our use of targeted advertising.

    Google Ads

    Google Ads offers a feature for targeting marketing audiences. This allows us to create segments based on the data we have obtained and use these for targeted marketing campaigns through our Google Ads account.

  8. 8.How can you manage your cookie preferences?

    The Digital Advertising Alliance of Canada, through the AdChoices program, allows you to control your cookies through a tool and an application.

    • To manage preferences on your computer, use the WebChoices browser opt-out tool
    • To manage preferences on your mobile device, use the AppChoices application

    If you choose to decline personalized ads, you may still receive Koddian ads, but they will not be personalized.

    In addition, browsers and devices have tools that allow you to control cookies; you can block them, ensure you are notified when cookies are used, and control cookies already stored on your device. However, if you block all cookies, you may not be able to access all features of the service.

    Cookie control tools vary by browser. Click the link for your browser for more information:

    • Google Chrome
    • Firefox
    • Safari
    • Microsoft Edge
    • Opera
    • Brave

    You can also manage your preferences using the "Limit Ad Tracking" feature on iOS devices or by disabling "Ad Personalization" on Android devices.

    Finally, you can opt out of having your web activity made available to Google Analytics by installing the Google Analytics browser opt-out add-on. This add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information about your web visits with Google Analytics. For more information about Google's privacy practices, please visit the Google Analytics web page.

  9. 9.To whom do we disclose your personal data?

    As part of our digital services, some of your information may be shared with advertising partners, such as Google AdWords, as well as with our subcontractors.

    We also disclose your personal data in the following situations:

    • If the law, a subpoena, or an authority request we believe we must respond to requires it, or if disclosure is necessary for an urgent and justified medical situation.
    • With our subsidiaries and sister companies, when necessary for the purposes of providing professional services or for business development purposes.
    • In the context of a merger, acquisition, or sale of part or all of our assets.

    As part of our digital services, we may share or disclose your personal data to the following categories of third parties.

    Business partners

    We use third parties to promote, sell, or distribute our products and services. As part of these outreach efforts, our partners may share personal data about their business contacts with us, and vice versa.

    IT service providers

    We use service providers such as data hosting centers to offer our digital services. For example, we use HubSpot for email distribution.

    Analytics service providers

    We use Google Analytics to better understand traffic related to our digital services and the performance of our advertising. Google Analytics does not allow us to track you individually; we can only see anonymized and aggregated traffic on our website. However, Google Analytics does collect data about your browsing habits through its related cookies.

    Advertising partners

    As part of targeted advertising, we may share your personal information with partners such as Google, LinkedIn, or Facebook. This information is generally what these entities collect through our website to offer us digital advertising features.

  10. 10.Where do we store your personal data?

    Your data may be hosted outside the region where you are located. For example, your personal data may be hosted in Canada, Europe, or the United States. When we transfer your personal data outside your country of residence, we ensure that appropriate safeguards are in place so that your personal data receives protection similar to that prevailing in your country of residence. For example, in the European Union, we may use standard contractual clauses.

  11. 11.How long do we retain your personal data?

    We retain your personal data for as long as necessary to provide our services, or longer if required by applicable law.

    We use both persistent cookies and session cookies. Session cookies are deleted as soon as you close your browser, while persistent cookies remain active on your device for a period of time. For example, Google Analytics cookies remain installed on your device for two years.

  12. 12.How do we ensure the security of your personal data?

    The security of your data matters to us, but remember that no method of transmission over the Web or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. We have put in place reasonable security measures for the risks related to your personal data. For more information, please contact us.

  13. 13.What are your rights regarding your personal data?

    You have certain rights regarding your personal data. Your rights vary depending on the laws that apply to you and the specific circumstances of your request.

    Europe

    If you are located in Europe, including the United Kingdom, we are the controller of your personal data. We will respond to your requests regarding the rights provided by law, including:

    • The right to information
    • The right to object
    • The right to data rectification
    • The right to verify your data
    • The right to de-reference content
    • The right to data portability
    • The right to request deletion of your personal data
    • The right to restriction of processing
    • The right to object to profiling and to request human intervention in an automated decision affecting you

    The Commission Nationale Informatique et Liberté has published a guide on these rights. It is important to understand that these rights are subject to certain conditions and may not be applicable.

    Canada

    If you are located in Canada, your rights may vary by region but generally include the right to access your personal data and to have it corrected in certain cases.

    Processing your request

    To exercise your rights or if you have questions about how we process your personal data, you may contact us:

    Personal Data Protection Officer / Person Responsible for the Protection of Personal Information:

    Mr. Lukasz Kokot
    CTO
    lkokot@kumojin.com

    SOLUTIONS KUMOJIN INC.
    200-125 Charest Est Blvd.
    Québec, QC G1K 3G5

    For security reasons and to avoid fraudulent requests, we may ask you to provide proof of identity with your request. Once the request is processed, we will securely delete this personal data. We will assist you free of additional charge. However, if you request a transcript, reproduction, or transmission of personal data concerning you, we may charge a reasonable fee to process your request, subject to applicable laws. In that case, we will contact you about these fees before processing your request. If your request is rejected, we will notify you in writing, providing detailed reasons and information on how to challenge our decision. We will retain the relevant personal data until you have exhausted your remedies. We will respond to your request within 30 days.

    Recourse in case of refusal

    If you are a resident of Europe, you may file a complaint with your local authority if you are not satisfied with our practices regarding your personal information or our response to your request. For example, if you are in France, you may address your complaint to the Commission Nationale Informatique et Liberté.

    If you are located in Canada, you may file a complaint with the Office of the Privacy Commissioner of Canada, or, if you are located in Québec, with the Commission d'accès à l'information.

    We will do our best to improve our processes. If you are not satisfied with how we handle your request, you may file a formal complaint with the Office of the Privacy Commissioner of Canada, or with the local authorities in your country of residence.

  14. 14.Can we update this privacy policy?

    We may update this Privacy Policy as needed and to reflect our personal data protection obligations. The most recent update date appears at the beginning of the Policy.

  15. 15.How do I submit an access or correction request?

    Your recourse

    Following a written access request, you may submit a review request to the Commission d'accès à l'information du Québec if:

    • You received a refusal or a response you consider unsatisfactory from us;
    • You did not receive a response.

    You must exercise this recourse within thirty days of the refusal or the expiry of our response deadline. To learn more, consult the Recours devant la Commission page on the Commission d'accès à l'information du Québec website.

    What is an access request?

    An access request must target administrative documents or personal information held by KUMOJIN in the exercise of its functions. An access request is therefore not a request for general information. The right of access to administrative documents or personal information includes several restrictions. Consequently, access to certain administrative documents or personal information may be refused in whole or in part if a restriction provided under the Act respecting access to documents held by public bodies and the protection of personal information, the Act respecting occupational health and safety, or the Act respecting industrial accidents and occupational diseases applies.

    Please use our forms on the Contact page or contact us at info@kumojin.com for, among other things: general information, questions about your application, or a copy of it.

    What is a correction request?

    A correction request aims to correct personal information that is inaccurate, incomplete, or ambiguous, or whose collection, disclosure, or retention is not authorized under one of the aforementioned laws.

    Submitting an access or correction request

    You may submit any written request for access to or correction of personal information by mail or email to the attention of the person responsible for access to documents and the protection of personal information. Your written request must be sufficiently detailed and specific to allow us to accurately identify the documents or personal information you wish to obtain or have corrected. We ask that you include your contact details (first name, last name, address, telephone number, etc.) so that we can send you a response or contact you if we need additional information in processing your request.

    We have twenty days from receipt of an access request to respond. However, this period may be extended by ten days if necessary. For requests for access to administrative documents, please indicate your preferred method of response, either by email or mail. For requests for access to personal information or correction, the response is sent by mail only. We cannot send personal information by email as this method of transmission is not sufficiently secure.

    To help you submit your access or correction request, consult the Forms and template letters section on the website of the Commission d'accès à l'information du Québec. We strongly recommend using these templates to avoid delays in processing your request.

    Here are the relevant forms for submitting a request:

    • Request for access to documents
    • Request for access to personal information
    • Request for correction of personal information
    Consulting documents that have already been the subject of an access request

    You may consult documents transmitted in response to an access request in accordance with the Regulation respecting the dissemination of information and the protection of personal information.