Privacy Policy

Last updated: March 9, 2026

This Privacy Policy describes how Sir collects, uses, stores, and protects the personal information of users of the website https://www.alphakawa.com (hereinafter "the Site").

Sir is committed to respecting the privacy of its users and processing their personal information in accordance with the Act to modernize legislative provisions as regards the protection of personal information (Law 25, Quebec), the Personal Information Protection and Electronic Documents Act (PIPEDA, Canada), and the General Data Protection Regulation (GDPR, European Union) to the extent that these regulations apply.

By using the Site, you consent to the practices described in this policy.

1. Data Controller

Trade Name: Sir AlphaKawa

Address: Quebec, Canada

Email: [email protected]

Website: https://www.alphakawa.com

2. Personal Information Collected

We only collect personal information necessary to provide our services. The categories of data we may collect include:

2.1 Data Provided Directly by the User

• First and last name
• Email address
• Geographic location coordinates (GPS) — see section 2.4 for details on collection contexts
• Mailing address (optional, provided voluntarily in the member profile)
• Social media handles (e.g., Instagram, X/Twitter, Facebook, etc.) — optional, provided voluntarily in the member profile
• Messages sent via the contact form
• Information related to the creation of a member account (login credentials)

2.2 Automatically Collected Data

• IP address and browsing data (pages visited, session duration, browser type)
• Connection data and server access logs
• Device information (operating system, screen resolution)

2.3 Payment Data

Financial transactions are entirely processed by external platforms. Sir does not collect, store, or have access to credit card numbers or sensitive financial data. Only non-sensitive information (amount, transaction status, transaction ID) is stored by Sir.

2.4 Location Data (GPS)

The collection of geolocation coordinates (GPS) occurs in the following contexts:

• Mandatory during Site registration (member account creation)
• Mandatory when submitting the contact form
• Mandatory during the electronic signature of documents
• Voluntary upon each Site login — you may refuse this collection upon login without affecting access to your account

In the first three contexts, providing GPS data is a necessary condition for using these features. This data is used for identity verification, legal compliance, the integrity of electronically signed documents, and access security.

Location data constitutes sensitive personal information. Sir undertakes to use it only for the purposes explicitly mentioned in this policy and not to share it with third parties without your consent, unless legally required.

3. Purposes of Data Processing

Your personal information is used for the following purposes:

• Creation and management of your member account
• Providing access to paid content and purchased digital works
• Processing and tracking commercial transactions
• Sending the newsletter to active members, based on the existing business relationship (legitimate interest compliant with CASL) — see section 12
• Optional enrichment of the member profile (mailing address, social media handles) for personalization and communication purposes
• Responding to your requests sent via the contact form
• Identity verification and localization within the framework of electronic document signatures
• Site improvement and usage analysis
• Compliance with applicable legal and regulatory obligations
• Fraud prevention and access security

4. Legal Basis for Processing

The processing of your personal information is based on the following legal grounds, as applicable:

• Performance of a contract: when processing is necessary to provide the services you have subscribed to (member account, purchase of digital works)
• Express consent: for sending newsletters and commercial communications, for GPS data collection upon login, non-essential cookies, and voluntarily provided profile data (mailing address, social media handles)
• Legitimate interest: for site security, fraud prevention, and service improvement, provided these interests do not override your fundamental rights
• Legal obligation: when the law requires us to retain certain data (billing, document signatures)

5. Data Retention Period

We retain your personal information only for the period necessary to fulfill the purposes for which it was collected, according to the following principles:

• Active member account data: kept for the duration of your subscription, then deleted or anonymized within twelve (12) months following account closure
• Transaction and billing data: kept for seven (7) years in accordance with accounting and tax obligations applicable in Quebec
• Electronic document signature data: kept for the legal validity period of the signed document
• Newsletter data: kept until the withdrawal of your consent
• Contact form data: kept for twelve (12) months following the resolution of your request
• Server logs and browsing data: kept for a maximum of twelve (12) months

6. Sharing and Disclosure of Personal Information

6.1 General Principle

Sir does not sell, rent, or trade your personal information to third parties.

6.2 Third-Party Service Providers

Within the strict framework of providing its services, Sir may share certain data with the following third parties:

• None identified at this time

These providers act as subcontractors and are only authorized to use your data for the purposes for which it was shared with them.

6.3 Legal Obligation

Sir may be required to disclose your personal information if required by law, notably in response to a court order, a request from a competent government authority, or to protect the rights, property, or safety of Sir, its users, or the public.

7. Data Transfers Outside of Canada

As the Site is accessible internationally, some data may be transferred to countries other than Canada, notably:

• To any country from which you access the Site

For users residing in the European Union, these transfers are framed in accordance with GDPR requirements. Sir ensures that appropriate safeguards are in place to protect your data during these transfers.

8. Cookies and Similar Technologies

8.1 What is a cookie?

A cookie is a small text file placed on your device during your visit to the Site. It allows the Site to remember certain information about your browsing.

8.2 Types of Cookies Used

• Essential Cookies: indispensable for the Site's operation (session management, member account authentication). These cookies cannot be deactivated without affecting basic functionality.
• Functional Cookies: allow your preferences to be remembered (language, display settings)
• Analytical Cookies: allow for the analysis of Site traffic and usage to improve performance — placed only with your consent

8.3 Cookie Management

During your first visit, an information banner allows you to accept or refuse non-essential cookies. You can also change your preferences at any time via your browser settings.

Refusal of essential cookies may prevent access to certain features of the Site, notably the members' area.

9. Data Security

Sir implements appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction, including:

• Encryption of communications via HTTPS (TLS) protocol
• Restricted access to personal data, limited to authorized personnel only
• Monitoring and logging of server access
• Physical and logical security measures for the self-managed hosting server

However, no data transmission over the Internet or any electronic storage system can be guaranteed to be 100% secure. In the event of a privacy incident likely to cause serious injury, Sir undertakes to notify you in accordance with the obligations set forth by Law 25.

10. Your Rights

10.1 Rights Applicable to All Users (Law 25 — Quebec)

In accordance with Law 25, you have the following rights:

• Right of Access: to obtain communication of the personal information concerning you held by Sir
• Right to Rectification: to have inaccurate, incomplete, or equivocal information corrected
• Right to Erasure: to request the deletion of your data when its retention is no longer justified
• Right to Portability: to receive your data in a structured and commonly used technological format
• Right to Withdraw Consent: to withdraw your consent at any time, without retroactive effect

10.2 Additional Rights for European Union Residents (GDPR)

In addition to the rights mentioned above, if you reside in the European Union, you also benefit from the following rights:

• Right to Object: to object to the processing of your data based on legitimate interest
• Right to Restriction of Processing: to request the temporary suspension of the processing of your data
• Right not to be subject to a decision based solely on automated processing
• Right to lodge a complaint with a supervisory authority (e.g., CNIL in France, or the competent authority in your country of residence)

10.3 How to Exercise Your Rights

To exercise any of your rights, please send a written request by email to:

[email protected]

Please include in your request your first and last name, the email address associated with your account, and a precise description of the right you wish to exercise. Sir undertakes to respond within thirty (30) days following receipt of a complete request.

In some cases, verification of your identity may be required before responding to your request, in order to ensure the protection of your data.

11. Minors

The Site is not intended for individuals under the age of 18. Sir does not knowingly collect personal information from minors. If you are a parent or guardian and have reason to believe that your child has provided us with personal information without your consent, please contact us at [email protected] so that we may proceed with the deletion of such data.

12. Newsletter and Commercial Communications

When creating an account on the Site, each member gives their express consent to receive commercial communications and Sir's newsletter, via the following notice displayed at the time of registration: "By creating an account, you agree to receive our commercial communications and our newsletter. You can unsubscribe at any time."

This mailing is therefore based on the express consent of the member, in accordance with the requirements of the Canadian Anti-Spam Legislation (CASL) and, for members residing in the European Union, the General Data Protection Regulation (GDPR).

You can withdraw your consent and unsubscribe at any time, free of charge and without justification, by:

• Clicking the unsubscribe link found in each email
• Modifying your consent settings on your profile

13. Changes to This Policy

Sir reserves the right to modify this Privacy Policy at any time, notably to comply with legislative or regulatory changes, or to reflect new data processing practices.

In the event of a substantial modification, we will inform you by email (if you have an account) or by a visible notice on the Site, at least thirty (30) days before the changes take effect. The update date at the top of this document will also be updated.

Your continued use of the Site after the modifications take effect constitutes acceptance of the new version of the policy.

14. Contact and Complaints

14.1 Contacting Us

For any questions, concerns, or requests relating to this policy or the processing of your personal information, please contact us:

Sir AlphaKawa

Quebec, Canada

Email: [email protected]

Website: https://www.alphakawa.com

14.2 Lodging a Complaint

If you believe that the processing of your personal data does not comply with applicable legislation, you have the right to lodge a complaint with the competent authorities; however, we encourage you to contact Sir first to attempt to resolve any concerns amicably.

Version effective as of March 15, 2026 — Sir AlphaKawa