Privacy & Data Protection Policy

Updated on August 19, 2025

1. Introduction

(i) This Privacy & Data Protection Policy (the “Policy”) describes how The C.L.E.A.R. Institute Inc. (“we”, “our”, “us”) collects, uses, discloses and protects personal information in connection with the website learn.theclearinstitute.com (the “Site”), our applications (the “Applications”), and our educational services (the “Services”).

(ii) By accessing or using the Site, the Applications or the Services, you agree to be legally bound by this Policy.

2. Definitions

(i) “Applications” means any of our websites, learning platforms, social media pages or accounts, software or applications.

(ii) “Cookies” means small files stored on a device and similar technologies (e.g., pixels, tags, web beacons).

(iii) “Personal Data” means information relating to an identified or identifiable individual.

(iv) “Usage Data” means technical data generated by the use of the Site/Applications (e.g., IP address, device identifiers, pages visited).

(v) “User” means any individual accessing or using the Site, Applications or Services.

3. Personal Data We Collect

(i) Identification and contact data: name, email address, phone number, professional details (e.g., dental practice, role), account identifiers.

(ii) Transaction data: billing details, payment confirmations (payments are processed by third-party providers; we do not store full payment card numbers).

(iii) Communications: messages, support requests, survey responses.

(iv) Recordings and media: photographs, audio or video captured during online courses, live events, and in-clinic sessions, where applicable.

(v) Usage Data and Cookies: technical logs, session information, device/browser data, geolocation (where enabled).

(vi) In-clinic confidentiality: Users shall ensure that no patient personal information is shared with our experts during in-clinic sessions unless duly anonymized. Users (including clinics and dentists) remain solely responsible for compliance with professional secrecy, deontology rules, and patient data protection.

4. Purposes of Use

(i) To register Users and provide the Services, including course access, certificates, and support.

(ii) To process payments, issue confirmations, and manage accounts.

(iii) To communicate about programs, updates, and service-related notices (and, where permitted, marketing communications subject to opt-out).

(iv) To improve and secure the Site, Applications and Services (including analytics and troubleshooting).

(v) To comply with legal, regulatory and tax obligations, and to protect rights and safety.

(vi) To use recordings and media for educational, administrative, quality, or promotional purposes, where lawful; you may object in writing where applicable law provides such a right.

5. Legal Bases (where applicable)

(i) Performance of a contract with the User (e.g., providing courses or services).

(ii) Compliance with legal obligations, which may include obligations under the laws of Québec (Law 25), Canada (PIPEDA), the European Union (GDPR), the United States (such as CCPA/CPRA in California and similar state laws), or other applicable jurisdictions.

(iii) Legitimate interests (e.g., improving Services, ensuring security), balanced against Users’ rights and freedoms.

(iv) Consent, where expressly required by law (e.g., certain marketing communications or cookies).

6. Cookies and Similar Technologies

(i) We use Cookies to: (A) enable core functionality (essential); (B) remember preferences (functional); (C) measure performance and usage (analytics); and (D) personalize content or advertising where applicable (targeting).

(ii) You may manage Cookies via your browser settings and, where available, our cookie controls. Disabling certain Cookies may affect functionality.

7. Disclosures

(i) Service providers: we share data with vendors who process information on our behalf (e.g., hosting, analytics, payment processing) under confidentiality and “need-to-know” obligations.

(ii) Legal or regulatory disclosures: where required by law, court order, or to protect rights and safety.

(iii) Partners/sponsors: we may share information with trusted partners or sponsors only with your explicit consent.

(iv) Business transfers: in connection with a merger, acquisition or reorganization, subject to appropriate safeguards.

8. International Transfers

(i) Personal Data may be transferred outside the Province of Quebec (including to other provinces, the United States or the EU) where our service providers operate.

(ii) We take reasonable steps to ensure adequate protection consistent with this Policy and applicable laws.

9. Retention

(i) We retain Personal Data only as long as necessary for the purposes described, or as required by law.

(ii) Usage Data may be kept longer for security, auditing or improvement purposes.

10. Security

(i) We implement technical and organizational measures to protect Personal Data against unauthorized access, alteration or disclosure.

(ii) No method of transmission or storage is completely secure; we cannot guarantee absolute security.

11. Your Rights

(i) Subject to applicable law, you may request: access, rectification, deletion (where appropriate), restriction or objection to processing, and data portability.

(ii) You may withdraw consent at any time where processing is based on consent, without affecting prior lawful processing.

(iii) Requests must be made in writing to: info@theclearinstitute.com. We may verify your identity before responding.

12. Children’s Privacy

(i) Our Services are not directed to individuals under 18. We do not knowingly collect Personal Data from minors.

13. Changes to this Policy

(i) We may amend this Policy from time to time. The latest version will be posted here with the updated date.

14. Governing Law and Jurisdiction

(i) This Policy is governed by the laws of the Province of Quebec and the applicable federal laws of Canada.

(ii) Any dispute shall be submitted to the exclusive jurisdiction of the courts of the judicial district of Longueuil, Province of Quebec, Canada.

15. Contact

(i) Controller identity: The C.L.E.A.R. Institute Inc., a corporation governed under the Canada Business Corporations Act with head office in the Province of Quebec, Canada.

(ii) Contact email: info@theclearinstitute.com.

16. Interpretation

(i) In case of discrepancy between the English and French versions of this Policy, the French version shall prevail.

(ii) You may consult the French version.