Privacy Policy

ELVRU TECHNOLOGIES INC.

PRIVACY POLICY

Effective Date: February 13, 2026

Elvru Technologies Inc. (“Elvru”, “we”, “us”, or “our”) is committed to protecting the privacy and security of personal information.

This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with our website and the Elvru Operational Infrastructure.

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1. Scope

This Privacy Policy applies to:

• Visitors to our website

• Business clients engaging our services

• Individuals whose data is processed through our platform on behalf of our clients

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2. Information We Collect

A. Information We Collect Directly

We may collect:

• Name

• Email address

• Phone number

• Business information

• Billing details

• Communications with us

B. Information Processed on Behalf of Clients

As part of providing services, we process personal information on behalf of our clients, including:

• Contact details

• Communication history

• CRM records

• Lead information

In these cases, the client is the data controller and determines how the information is used.

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3. How We Use Information

We use personal information to:

• Provide and maintain services

• Process payments

• Communicate with clients

• Improve platform functionality

• Ensure compliance with legal obligations

We do not sell personal information.

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4. Legal Basis & Consent

We process personal information in accordance with applicable laws including PIPEDA and other relevant privacy legislation.

Clients are responsible for obtaining lawful consent from their contacts where required.

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5. Sharing & Disclosure

We may share information with trusted third-party service providers, including:

• CRM infrastructure providers

• Telecommunications providers

• Hosting providers

• Payment processors

These providers are engaged solely for service delivery and are subject to reasonable confidentiality and data protection obligations.

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6. Cross-Border Processing

Information may be stored or processed in jurisdictions outside of Canada through third-party service providers.

By using our services, you acknowledge and consent to such transfers where necessary.

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7. Data Security

We implement commercially reasonable administrative and technical safeguards to protect personal information, including:

• Access controls

• Role-based permissions

• Secure authentication practices

No system can guarantee absolute security.

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8. Data Retention

We retain personal information only as long as necessary to fulfill service obligations or comply with legal requirements.

Upon termination of services, client data is handled in accordance with our Data Processing Addendum.

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9. Individual Rights

Depending on applicable law, individuals may have the right to:

• Request access to their personal information

• Request correction of inaccurate data

• Request deletion where legally permissible

Requests may be directed to the contact information below.

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10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of such sites.

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11. Updates to This Policy

We may update this Privacy Policy from time to time. Continued use of our services constitutes acceptance of the updated policy.

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12. Contact Information

For privacy-related inquiries, please contact:

Elvru Technologies Inc.

Email: [email protected]