Data Processing Policy

1. Introduction

This Data Processing Policy describes the principles and procedures we apply when processing personal data of users of the aifinportfolioLab.com website. This policy supplements our Privacy Policy and details the technical aspects of data processing.

We commit to processing personal data lawfully, fairly, and transparently, collecting it only for specific, explicitly stated, and lawful purposes and not processing it in ways incompatible with these purposes.

2. Data Processing Principles

When processing personal data, we are guided by the following principles:

• Lawfulness and fairness: data processing is carried out on lawful grounds and in a fair manner
• Purpose limitation: data is collected for specific, explicitly stated, and lawful purposes and is not processed in ways incompatible with these purposes
• Data minimization: only data necessary to achieve processing purposes is processed
• Accuracy: data is kept up to date and measures are taken to correct or delete inaccurate data
• Storage limitation: data is stored in a form that allows identification of data subjects no longer than necessary for processing purposes
• Integrity and confidentiality: data is processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing

3. Data Processing Processes

Personal data processing includes the following operations:

• Data collection through contact forms, registration, and website use
• Data storage in secure databases with encryption
• Data use for providing services and improving functionality
• Data analysis to understand user behavior and optimize the website
• Data transfer to service providers who help operate the website
• Data deletion or anonymization after the storage period expires

4. Technical Security Measures

To protect data, we apply the following technical measures:

5. Organizational Measures

In addition to technical measures, we apply organizational measures to protect data:

• Training employees on personal data protection and privacy
• Limiting data access based on the principle of minimum necessity
• Regular review and updating of data processing policies and procedures
• Appointing a person responsible for personal data processing
• Conducting data protection impact assessments for new processing processes

6. Data Processing by Third Parties

In some cases, we may engage third parties to process data on our behalf. All such data processors:

• Are selected based on their ability to ensure proper data protection
• Are bound by contractual obligations to protect data confidentiality
• Process data only in accordance with our instructions
• Apply appropriate technical and organizational security measures

We regularly verify that data processors comply with our requirements and applicable legislation.

7. Data Retention Periods

Personal data is stored for the period necessary to achieve the purposes of its processing, or for the period established by applicable legislation. After the retention period expires, data is deleted or anonymized in a secure manner.

Specific retention periods for different types of data are determined based on:

• Data processing purposes
• Applicable legislation requirements
• Business operational needs
• Legal grounds for processing

8. International Data Transfer

In case of data transfer outside Canada, we ensure that such transfers are carried out in accordance with applicable data protection legislation and with appropriate safeguards, such as standard contractual clauses or other mechanisms recognized by legislation.

9. Contact Information

If you have questions regarding the processing of your personal data or this policy, please contact us:

• Email: info@aifinportfolioLab.com
• Phone: +1 (613) 728-4916
• Address: 180 Wellington Street, Ottawa, ON K1P 5A9, Canada