Privacy Policy

1. Introduction

POLLNOVA (Business Registry No. 1001524500), located at 2616 Standardbred Dr, Oshawa, Ontario L1L 0S7, Canada ("we", "us", or "our"), owns and operates pollnova.com and all affiliated websites and mobile versions (the "Platform"). We respect your privacy and are committed to protecting your personal information through this Privacy Policy (the "Policy").

This Policy describes the types of personal information we may collect from you, or that you may provide to us, when you use the services offered on the Platform, and our practices for collecting, using, retaining, protecting, and disclosing your personal information. Please read this Policy carefully. If you do not agree with this Policy, your sole choice is to leave the Platform. By accessing or using PollNova, you agree to this Policy and consent to our collection, use, disclosure, retention, and protection of your information as described here.

We comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. We reserve the right to revise this Policy at any time. We will consider your continued use of the Platform after we post changes as your acceptance of those changes, so please periodically revisit this page and check the "Last updated" date above.

2. Age Requirement

We prohibit anyone under the age of eighteen (18) from accessing the Platform or using our services. We do not knowingly market to, collect, or solicit any personal information from or about anyone under 18. If you are under 18, you must not submit information to us and must immediately leave the Platform.

If we learn that we have collected information from a person under 18, we will delete that information as quickly as possible. If you believe we may hold such information, please contact us immediately at privacy@pollnova.com.

3. Information We Collect

We may collect several types of personal information from and about users of the Platform, including information that personally identifies you or that could reasonably be linked to you, such as: your name; alias; username; email address; IP address; billing information; order and transaction history; device identifiers; biometric information (creators only, for KYC); and inferences drawn from any of this information about your preferences or behaviour. This Policy does not apply to personal information that has been de-identified or that is otherwise publicly available.

4. How We Collect Your Information

We collect your personal information directly from you when you provide it to us, such as through:

• The account registration process;
• Your profile information and content uploads;
• Your purchases and other financial transactions;
• Your voting activity and content interactions;
• Your linked social media accounts (OAuth sign-in);
• Your responses to any surveys we ask you to complete; and
• Your communications and interactions with us, whether by contact form, email, or other means.

We also collect your personal information automatically from your device through cookies, web beacons, and other tracking technologies as described in Section 7.

4.1 Third-Party Collection on the Platform

Third parties — including service providers, analytics providers, and third-party plug-ins — may use cookies, web beacons, or other tracking technologies to collect your personal information, including information about your online activities over time and across different websites. We do not control these third-party tracking technologies. Your use of any third-party plug-ins or connected services is governed by the terms and privacy policy of the applicable third party.

5. How We Use Your Information

We may use your personal information to:

• Provide you with access to the Platform and all its features;
• Create, maintain, customise, and secure your account;
• Operate the Platform — display polls, record votes, update Picks balances, unlock media, manage your Library;
• Process payments and manage creator payouts, including fraud detection and chargeback management;
• Recognise you when you return to the Platform and personalise your experience;
• Send you notifications about polls you voted on, new polls from creators you follow, and other Platform activity;
• Respond to support requests, investigate and address your concerns, and resolve disputes;
• Notify you about changes to the Platform, these Terms, and our policies;
• Monitor, analyse, and improve Platform traffic, usage trends, and user experience;
• Verify the integrity and security of the Platform;
• Detect, investigate, and prevent unauthorised or prohibited uses of the Platform and protect against fraud and abuse;
• Comply with legal obligations under applicable Canadian law, including anti-money laundering requirements;
• Carry out our obligations and enforce our rights arising from any contracts between you and us;
• Respond to law enforcement requests as required by applicable law, court order, or governmental regulation;
• Conduct testing, research, and analysis for product development; and
• Send you marketing or promotional communications where you have consented (you may opt out at any time).

We will not use your personal information for materially different, unrelated, or incompatible purposes without providing you notice.

6. Sharing Your Information

We do not sell your personal information. We may share publicly available information and de-identified information with third parties without restriction. However, we may only disclose your personal information to:

• Service providers: our subsidiaries, affiliates, contractors, hosting providers (including Vercel and Supabase), payment processors, payout processors, KYC verification providers, analytics providers, and other third parties necessary to provide the Platform — all under appropriate data processing agreements that restrict use to performing services on our behalf;
• Other users of the Platform: your public profile (username, bio, avatar) and creator poll content is visible to other users in accordance with the visibility settings you have chosen;
• Potential buyers or successors: in the event of a merger, acquisition, joint venture, divestiture, restructuring, reorganisation, dissolution, bankruptcy, or other sale or transfer of all or substantially all of the Company's assets — in which case your personal information may be among the assets transferred;
• Law enforcement and legal authorities: when required by law, court order, or lawful process, or to identify, contact, or bring legal action against someone violating our policies or rights, or to protect the rights, property, or safety of us, our users, or the general public;
• Internet cookie data recipients: such as analytics providers (e.g., Vercel Analytics) as described in Section 7; and
• Any other party with your consent.

When we disclose personal information to service providers for a business purpose, we require them to keep your information confidential and not use it for any purpose except performing the contracted services.

7. Cookies & Tracking Technologies

We use cookies and similar technologies (such as local storage and session tokens) on the Platform. A cookie is a small file stored on your device that allows us to recognise you on future visits.

7.1 Types of Cookies We Use

• Essential cookies: required for the Platform to function — including session authentication, security tokens, and user preference storage. These cannot be disabled without impairing Platform functionality.
• Functional cookies: used to remember your preferences (e.g., consent choices, display settings) between visits.
• Analytics cookies: used to understand how users interact with the Platform, measure performance, and improve our services. We use privacy-conscious analytics tools and, where possible, anonymise or aggregate data before analysis.

We do not use third-party advertising cookies or behavioural tracking cookies for ad targeting purposes.

7.2 Managing Cookies

You may control cookies through your browser settings. To learn how to manage cookies, visit www.allaboutcookies.org. However, disabling essential cookies may prevent you from accessing certain parts of the Platform. Unless you adjust your browser settings to refuse cookies, we will issue cookies when you access PollNova.

7.3 Do Not Track

Do Not Track ("DNT") is a browser privacy preference. We do not currently respond to DNT signals as the industry works toward a common standard for compliance. We will continue to monitor developments in this area.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes set out in this Policy, or as otherwise permitted or required by applicable law and regulation. Specifically:

• Your account data, profile, votes, and media Library are retained for as long as your account is active;
• Upon permanent account deletion, your profile and user-generated content are removed within 30 days, except where retention is required by law;
• Financial records — including transaction logs, Picks purchase history, and creator payout records — are retained for 7 years as required by Canadian tax and financial record-keeping obligations;
• KYC documents are retained for the period required under applicable anti-money laundering and identity verification regulations;
• Communication records with our support team may be retained for up to 2 years for dispute resolution and quality assurance purposes; and
• We reserve the right to retain publicly available information and de-identified or aggregated information indefinitely for legitimate business, research, and analytical purposes without further notice to you.

9. Your Rights

Under PIPEDA and applicable provincial privacy legislation, you have the following rights with respect to your personal information:

• Access: You may request a copy of the personal information we hold about you. We will provide this information within 30 days of receiving a verifiable request.
• Correction: You may request that we correct any inaccurate or incomplete personal information. In many cases, you can update your information directly in your Account Settings.
• Withdrawal of Consent: Where we process your personal information on the basis of your consent, you may withdraw that consent at any time. Withdrawal of consent may limit your ability to use certain Platform features.
• Deletion: You may request deletion of your account and associated personal data by deleting your account in Account Settings, or by contacting us. Deletion is subject to our retention obligations described in Section 8.
• Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Objection: You may object to or opt out of certain processing activities, including marketing communications. To opt out of marketing emails, use the unsubscribe link in any marketing email or contact us directly.
• Complaint: If you believe we have mishandled your personal information, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca, or with the applicable provincial privacy commissioner.

To exercise any of these rights, submit a verifiable request to privacy@pollnova.com, including your account username or email address and a clear description of your request. We will respond within 30 days of receipt. If we require more time (up to an additional 30 days), we will notify you of the reason and extension in writing.

Only you, or someone legally authorised to act on your behalf, may make a verifiable request related to your personal information. We cannot respond to your request or provide personal information if we cannot verify your identity or authority to make the request.

We will not discriminate against you for exercising any of your privacy rights. We will not deny you services, charge you different prices, or provide a lower quality of service as a result of your exercising these rights.

10. Security

We are committed to protecting your personal information and have implemented technical and organisational measures designed to secure it from accidental loss and from unauthorised access, use, alteration, and disclosure. These measures include:

• Encryption of data in transit using Transport Layer Security (TLS);
• Encryption of sensitive data at rest;
• Row-level security (RLS) database policies ensuring users can only access their own data;
• Secure, hashed storage of passwords (we never store passwords in plain text);
• Access controls limiting internal access to personal data on a need-to-know basis; and
• Regular security reviews and vulnerability assessments.

However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used on the Platform. If you have reason to believe your interaction with us is no longer secure, please contact us immediately at support@pollnova.com.

11. Children's Privacy

PollNova is intended solely for users aged 18 and over. We do not knowingly collect personal information from individuals under the age of 18. If you are under 18, you must not access or use the Platform or provide any information to us.

If we discover or are notified that we have inadvertently collected personal information from a person under 18 without verified parental consent, we will take steps to delete that information as quickly as possible. If you are a parent or guardian and believe your child under the age of 18 has provided us with personal information, please contact us at privacy@pollnova.com immediately and we will take appropriate action.

12. International Transfers

This Policy is intended to cover the collection and use of personal information in connection with our operations. Your personal information may be stored and processed in countries outside Canada — including the United States — where our infrastructure and service providers operate. These countries may have data protection laws that differ from those in Canada.

When we transfer personal information internationally, we take steps to ensure appropriate safeguards are in place, consistent with the requirements of PIPEDA and applicable provincial law, such as through contractual data processing agreements with our service providers. By using PollNova, you consent to the transfer of your personal information to countries outside Canada, including the United States, for the purposes described in this Policy.

13. Provincial Privacy Rights

13.1 Quebec (Law 25)

If you are a resident of Quebec, you have additional rights under Law 25 (Act respecting the protection of personal information in the private sector), including the right to data portability, the right to de-indexation, and the right to be informed of any automated decisions made about you. To exercise these rights, contact our Privacy Officer at privacy@pollnova.com.

13.2 Alberta & British Columbia

If you are a resident of Alberta or British Columbia, your personal information is also subject to the provincial privacy legislation of your province (PIPA Alberta or PIPA BC), which provides rights similar to those described in Section 9. To exercise your rights or file a complaint under provincial legislation, you may also contact the applicable provincial privacy commissioner.

13.3 International Users

If you are accessing PollNova from outside Canada, you understand and agree that your personal information may be transferred to, stored, and processed in Canada or in the jurisdiction of our service providers. The data protection laws of Canada or such other jurisdictions may not be as comprehensive as those in your country. By using the Platform, you consent to this transfer and processing.

14. Changes to This Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated Policy on the Platform and update the "Last updated" date at the top of this page. Your continued use of the Platform following the posting of changes constitutes your acceptance of those changes.

For material changes that significantly affect how we handle your personal information, we will provide additional notice where required by law, such as by email or in-platform notification.

15. Contact Us

If you have any questions, comments, or requests regarding this Policy, our data practices, or your rights under applicable privacy law, please contact our Privacy Officer:

If you are unsatisfied with our response to a privacy concern, you may contact the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca, or your applicable provincial privacy commissioner.