PRIVACY POLICY

Effective date 17^th of February 2020

CG Air Systèmes Inc, its website www.cgair.com, its brand ConnectedTub™ and its affiliates,  subsidiaries and all its apps ("CG AIR," "we," "us" or "our") are committed to your privacy protection.  Please read this Privacy Policy (the "Privacy Policy") carefully to understand our privacy policies and practices, and how we will handle it.

This Privacy Policy describes the types of information CG AIR collects from and about you when you visit our Site, use our mobile applications (“App”), or use our ConnectedTub™ products, devices and hydro massage components (“Products”). The Site, Apps, and Products are collectively the “Services.” This Privacy Policy also explains how CG AIR may use and disclose such information, as well as your ability to control certain uses of it. You may also use one of the following CG AIR services: ConnectedTub™ app, Connected Tub Alexa skill, Google Assistant ConnectedTub™ app.

Every time you use the Website, you recognize and agree to be bound by this Agreement as it is then read, and you assert and warrant that you have the legal authority to consent to and approve this Agreement on behalf of you and any person you claim to represent. If you disagree with each provision of this Agreement or are not allowed to consent to and approve this Agreement on behalf of the person you claim to represent, you may not access or use the Website or our app.

INFORMATION WE COLLECT :

Your personal information is collected, used, and disclosed by CG AIR only in accordance with this Privacy Policy, which is based on the Canadian Standard Association Model Code for the Protection of Personal Information (CAN/CSA-Q830-96). Personal information is defined as information about an identifiable individual, with the exception of business contact information such as a job title or work-related telephone number or address.

We will always collect your Personal Information by fair and lawful means (for example, when you enter information on CG AIR websites or any of our apps we may have with you). We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law. As a result, information may be collected by your use of the CG AIR websites and apps.

Furthermore, when you browse CG AIR website, you and your web browser may also transmit information that CG AIR automatically collects. This information may be combined with other Personal Information you have provided. The only other type of information automatically provided to CG AIR is the type of computer, operating system and browser you are using. This information is provided by your browser, which CG AIR may use to improve the performance of its website or for other similar technical or performance-related purposes.

CG AIR may also place small data files, called “cookies,” in the browser file of your computer’s hard drive. These cookies automatically identify your browser to the CG AIR server whenever you interact with a CG AIR website. CG AIR may use the cookies to record website data. For more information about cookies, please see the Cookie section below.

HOW WE USE INFORMATION :

We use your information for our business purposes. We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

• to respond to your inquiries;
• to advise you about new products and services that may be of interest to you;
• to collect opinions and comments regarding CG AIR’s operations;
• to add you to CG AIR mailing list(s);
• to recruit for positions at CG AIR and to process your application for employment and your resume;
• to manage our websites;
• to investigate legal claims;
• such other purposes for which CG AIR may obtain consent from time to time; and such other uses as may be permitted or required by applicable law.

STORAGE OF DATA

Where do we store your personal information?

We store your personal information in our offices in Canada, as well as our data centres. Your information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies in the U.S., pursuant to applicable laws.

Our service providers may, from time to time, also hold your personal information in connection with purposes for which you provided your consent. We may keep a record of your personal information, correspondence or comments in a file specific to you.

DATA SHARING :

We may share your Personal Information with our affiliates, our service providers, our business and marketing partners, to comply with laws, to protect ourselves or enforce our rights, in connection with a business transfer, or in other situations where we provide you with notice. Cookies and tracking technologies are used on our Services, which allows us, advertising networks, social media companies, and other providers to place or display ads relevant to you on our Services, as well as on other websites, apps, services, or devices you may use. Otherwise, we will only share Personal Information with unaffiliated parties for their direct marketing purposes with your consent.

CG AIR APPS

The CG AIR apps will be available for download and integrated on the following platforms:

• Google Play Store
• Apple App Store
• Amazon Alexa (Alexa Skill)
• Google Home

CG AIR apps are available on any device that supports the Alexa Voice service. Please refer to the privacy policy of your device, as well as Amazon's privacy policy for Alexa, to better understand what information those devices and services may collect when using any skill.

To find out more information about how the above platforms may collect information please refer to their privacy policies provided on their respected websites.

COOKIES

A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer. This unique number identifies your computer to CG AIR whenever you visit the CG AIR website. Cookies are an industry standard used by the most website and help facilitate users’ ongoing access to and use of a particular site. Since cookies are only text files, they cannot run on your computer, search your computer for other information or transmit any information to anyone.

To help serve you better, CG AIR sends a cookie to your computer to:

1. Help us remember who you are so that CG AIR can tailor information to suit your preferences. CG AIR uses cookies to store and sometimes track information about our users’ activities on the CG AIR website, for example, the pages you visit most. Cookies may also be used by our advertising partners.
2. Measure traffic patterns. Without cookies, it could be difficult for CG AIR to know that certain services are more popular than others. This information also helps us to understand how we can serve you better.
3. Estimate audience size. Cookies help us know whether or not users have seen particular content.

Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie or to refuse to accept cookies. You should understand that while CG AIR does not require you to use cookies, certain areas of the website will not function properly if you set your browser to not accept cookies.

RETENTION OF YOUR INFORMATION

If you contact us with a question or comment, any personal information is normally kept only long enough for us to provide you with a response, unless we need to keep your information for a longer period to service your needs or address your concerns. If you request a quote, your information is retained for a maximum of one year on CG AIR servers. However, keep in mind that residual information about you may remain for a longer period in archives, copies or back-up tapes.

ACCURACY

When requesting CG AIR services, it is your responsibility to provide current, complete and accurate information about yourself, and you agree not to misrepresent your identity.

CG AIR relies heavily on you in order to maintain accurate databases. To ensure that you are kept up-to-date on the products and services we offer, and that there is no interruption in our communications with you, please contact us to advise us of any changes in your information.

SPAM

Periodically we may use e-mail as a way to keep in touch with our existing users and other interested individuals. However, we do not send "spam" (unsolicited commercial electronic messages), and have taken the necessary steps to ensure we are complying with Canada’s anti-spam law (“CASL”). If you agree to receive e-mail communications from us for marketing purposes, or have a business relationship with us, you will receive promotional messages from CG AIR, but every e-mail message we send to you will include an unsubscribe link which allows you to opt-out of our lists at any time.

CALIFORNIA - Your Rights Under the CCPA

Right to Access and Request:

If you are a resident of California, you have the right to request that CG AIR identify and disclose to you and deliver your Personal Information under our control collected within the last twelve months. This information will be provided in the form of a report to you, free of charge. At the time your request is made, you may ask that the report be in either paper or electronic format. If in paper format, CG AIR will send the requested information via FedEx or a different carrier. If in electronic format, CG AIR will send the requested information via email.

• Once your status as a California resident is confirmed and your identity and request verified, CG AIR will make all reasonable efforts to provide a response in 45 days but may notify you of our intention to extend the timing of our response for an additional 45 days (total of 90 days).
• Once your identity and the relevance of your request have been verified, CG AIR will include the following information in our response:
• Categories of Personal Information collected.
• Categories of sources from which the Personal Information was collected.
• Business or commercial purpose for collecting or selling the information.
• Categories of third parties with whom the business shares and/or sells the information.
• You may request a copy of your Personal Information no more than two (2) times in a 12-month period.

Right to Delete :

• If you are a resident of California, you have the right to request that CG AIR delete any Personal Information about you we have collected. Once your status as a California resident is confirmed and your identity and request verified, CG AIR will delete the information and direct any third-party service providers to delete the information from its records.
• However, all or part of your Personal Information may be retained if it is needed by us for a reasonable business justification, including but not limited to the following:
• Complete the transaction for which the information was collected, provide a good/service requested by you (or reasonably anticipated within the context of an ongoing business relationship with you), or otherwise perform a contract between CG AIR and you.
• Detect security incidents or otherwise protect against malicious, deceptive, fraudulent, or illegal activity, up to and including pursuing prosecution of those responsible for the illegal activity.
• Debug the information to identify and repair errors impacting functionality.
• Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act.
• Engage in public or peer-received scientific, historical, or statistical research in the public interest.
• Enable internal uses that are reasonably aligned with expectations based on your relationship with the business.
• Fulfill the terms of a written warranty or product recall.
• Comply with a legal obligation.
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.To read more about your rights visit https://oag.ca.gov/privacy/ccpa

RESIDENTS OF EUROPE

Under the GDPR, you may, if applicable, be entitled to additional rights, including:

• the right to withdraw consent to processing where consent is the basis of processing;
• the right to access your personal information and certain other supplementary information, under certain conditions;
• the right to object to unlawful data processing, under certain conditions;
• the right to erasure of personal information about you, under certain conditions;
• the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate;
• the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions;
• the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; and
• the right to lodge a complaint with data protection authorities.

If you want to learn more about your rights under the GDPR, you can visit the European Commission’s page on Data Protection at http://ec.europa.eu/justice/data-protection/index_en.htm

This is not an admission that we or this Website are subject to the GDPR or the jurisdiction of any court or agency outside of the Canada.

RESIDENTS OF CANADA

We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.

COMMUNICATIONS PREFERENCES

We may send electronic newsletters and other communications on a periodic basis to various individuals and organizations. We may also send email communications regarding topics such as website updates, and product or service offerings. We offer you appropriate consent mechanisms, such as opt-out, for marketing and certain other communications. You can also manage your communications preferences by using the opt-out or unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us directly at cgair@cgair.com. We reserve the right to notify you of changes or updates to the Site or this Privacy Policy whenever necessary.

CHILDREN

We request that children under the age of 13 not use the website or submit any personal information to the website. We do not direct the website to children under the age of 13 and we do not knowingly collect, use, store, or disclose the personal information of children under the age of 13.

CHANGES TO PRIVACY POLICY

We reserve the right to change this Privacy Policy, and any of our policies or procedures concerning the handling of personal information, without prior notice. You can determine when this Statement came into effect by referring to the "Effective Date" at the bottom of this page. Any changes to our Statement will become effective upon posting of the revised Statement on the Internet. Use of the CG AIR website following such changes constitutes your acceptance of the Privacy Policy in effect.

CONTACT US

If you have questions, comments, concerns or complaints about this Privacy Policy or our privacy practices, please feel free to contact us at cgair@cgair.com

February 17^th 2020
Sainte-Marguerite, Québec, Canada.