1. Purpose

This Policy supplements the Privacy Policy of Prosomo and is intended to inform users of the cookies and similar technologies used on the website https://prosomo.com, their purposes, their lifespan, and the means available to manage them.

It forms part of the obligations set out in Québec’s Act respecting the protection of personal information in the private sector (CQLR, c. P‑39.1), as amended by Law 25, and in Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

2. What is a cookie?

A cookie is a small text file placed on the user’s device by the website being visited. It allows the website to recognize the browser, to remember certain information from one page or one visit to the next, and in some cases to track browsing activity.

The website also uses related technologies with comparable effects, including browser local storage, tracking pixels, and tags. In this Policy, “cookie” covers all of these technologies.

Cookies may be placed by Prosomo (first-party cookies) or by third parties whose services are embedded in the website (third-party cookies). Third-party cookies allow those providers to collect information about the user’s browsing, including on other websites, under their own policies.

3. Categories of cookies used

The cookies used on the website fall into the following four categories. For each, the purpose pursued, the categories of providers involved, and the maximum lifespan of the cookies are indicated.

3.1 Essential cookies

Purpose: to ensure the technical operation of the website and the delivery of the services requested, including maintaining the session, security, load balancing, and remembering the cookie choice expressed. These cookies are not used to build a profile or for advertising purposes.

Categories of providers: website hosting and content management platform, security and content delivery services.

Maximum lifespan: Maximum lifespan: duration of the session, except for the cookie recording the acceptance, which is retained for 6 months. Consent required: no.

3.2 Preference cookies

Purpose: to remember the user’s display, language, or region choices in order to personalize the experience. These cookies are not necessary for the technical operation of the website.

Categories of providers: website content management platform, providers of personalization tools.

Maximum lifespan: 13 months.

3.3 Statistics cookies

Purpose: to measure website traffic, determine which pages are viewed, and improve the content offered. These cookies are not necessary for the technical operation of the website.

Categories of providers: providers of web audience measurement tools.

Maximum lifespan: 13 months.

3.4 Marketing cookies

Purpose: to present the user with advertising matched to their interests, to measure the effectiveness of advertising campaigns, and where applicable to retarget the user on other sites or platforms. These cookies are not necessary for the technical operation of the website.

Categories of providers: advertising networks, social media platforms, advertising delivery and measurement partners.

Maximum lifespan: 13 months.

3.5 Identification, location, or profiling functions

Statistics and marketing cookies include functions allowing the user to be identified, located, or profiled based on browsing habits or interests. The means available to deactivate these functions are described in Section 6.

4. Third-party providers and transfers outside Québec

Several third-party cookie providers process the information collected outside Québec or Canada. These transfers are governed as described in Section 9 of the Privacy Policy.

The identity of the providers involved and links to their respective privacy policies may be obtained on request from the person in charge of the protection of personal information, whose contact details appear in Section 8.

5. Consent and conditions of access to the website

On the first visit, a banner is displayed informing the user of the categories of cookies used on the website and their purposes. No cookies other than essential cookies are placed on the user’s device before the user has clicked the acceptance button.

Access to the content of the website requires the acceptance of all cookies described in Section 3, including preference, statistics, and marketing cookies. If the user does not accept, the user cannot access the content of the website.

Prosomo informs the user transparently of the scope of this choice. Preference, statistics, and marketing cookies are not necessary for the technical operation of the website: they serve the purposes described in Section 3. Their acceptance is nonetheless required as a condition of access to the website.

A record of the acceptance is retained, including its date and the version of the text presented to the user. The choice expressed is remembered for 6 months, after which the banner is displayed again.

The Privacy Policy, this Policy, and the contact details of the person in charge of the protection of personal information remain accessible without the user having to accept cookies. The rights set out in Section 12 of the Privacy Policy, including the rights of access, rectification, and portability, as well as the right to file a complaint with the Commission d’accès à l’information, may be exercised at any time, regardless of the choice expressed.

6. Managing and withdrawing consent

6.1 Through browser settings

Most browsers allow cookies to be blocked or deleted, or provide a warning before they are placed. The procedures are set out in the documentation of the browser used:

• Google Chrome: Settings > Privacy and security > Cookies and other site data
• Mozilla Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Settings > Privacy > Manage Website Data
• Microsoft Edge: Settings > Cookies and site permissions

Deleting the cookies placed amounts to a withdrawal of consent. Withdrawing consent may have the effect of preventing subsequent access to the website. Blocking essential cookies prevents the website from functioning normally.

6.2 Through third-party provider tools

Some providers offer their own opt-out mechanisms, independent of the website. Links to these mechanisms may be obtained on request from the person in charge of the protection of personal information.

6.3 Through device settings

Users may also enable settings in their browser or operating system that limit advertising tracking, such as refusing third-party cookies or limiting cross-app tracking.

7. Changes to this Policy

This Policy is updated when the categories of cookies used, their purposes, or the categories of providers involved change. Any amendment is posted on the website with a revised last-updated date. Fresh consent is sought when a new purpose is introduced.

8. Contact and complaints

For any question about this Policy, users may contact the person in charge of the protection of personal information:

Name: Florian
Email: florian.c@prosomo.com
Telephone: 8199190943

A complaint may also be filed with the Commission d’accès à l’information du Québec (www.cai.gouv.qc.ca) or, elsewhere in Canada, with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).