Privacy Policy

Giiftii Systems Inc. (herein “Giiftii”, “we”, “us”, “our”) recognizes the importance of your personal information and is committed to providing a safe and personalized gifting experience.

This Privacy Policy sets out how Giiftii uses and protects the information that it collects from its customers, visitors and users (collectively, the “Users”) through, or in association with, its website with a homepage located at www.giiftii.com (the “Site”), its mobile applications, desktop applications and browser extensions (each, an “App” and collectively the “Apps”), its products and services that may be offered from time to time via the Site, its related social media sites, or otherwise through Users’ interactions with Giiftii (the Site, the Apps, products, services, and social media pages, collectively, the “Services”), why it collects that information, how it uses that information, and to whom and in what capacity it shares that information.

By accessing the Services, using features of the Services, and/or submitting information to Giiftii, you consent to our collection, storage, use and disclosure of your Personal Information and you are bound by all terms and conditions in the Terms of Use and this Privacy Policy. Where applicable law requires your express consent for a particular purpose, including the use of your Personal Information for profiling or for targeted advertising, we will notify you at the time of collection. If you reside in Quebec, cookies and similar technologies that are not strictly necessary, including those used for analytics, session recording, profiling or advertising, are off by default and are activated only if you turn them on through the cookie preference control.

If you reside in Quebec, the functions that allow us to profile you are turned off by default, and we will use your Personal Information for profiling only if you choose to turn them on, as described under “Profiling and personalized recommendations” in Section 1B. You may refuse or later withdraw that consent without losing access to the parts of the Services that do not depend on it. You may withdraw your consent at any time as described under “Your privacy rights” below; withdrawal does not affect processing carried out before the withdrawal took effect.

1. COLLECTION OF INFORMATION

Information you provide: We collect personal information and non-personal information. When you register an account, create a wishlist, gift board, registry or use the gift recommendation feature forming part of the Services, we collect some personal information, that is any information that can be directly or indirectly associated with you, herein “Personal Information”, such as your name, email address, phone number, address, date of birth, and other similar information. “Non-Personal Information” means information that does not identify you and that we do not link, and could not reasonably link, to you, such as aggregated or anonymized usage data, general demographic information, referring and exit pages and URLs, platform types and number of clicks. Information such as your IP address, cursor movement and session recording, device identifiers, advertising identifiers and records of your online activity is treated in this Privacy Policy as Personal Information, because it can be used, alone or in combination with other information, to identify you or your device. Information that has been de-identified (for example, by removing your name or replacing it with a code) but that could still be linked back to you, alone or in combination with other information, is treated as Personal Information.

Information another individual provides: If a user accesses the Services for the purpose of obtaining gift recommendations for a specific gift recipient, they may provide some Personal Information and Non-Personal Information about the intended gift recipient. Similarly, if someone sends you a communication from the Services (e.g., invitation to view their wishlist), we may collect your name and contact information necessary to send that communication. In both instances, we use that information only to provide the feature the user requested, such as sending the invitation or generating the recommendation. Where you provide us with Personal Information about another person, including a gift recipient or a person you invite to view a list, you confirm that you are authorized to do so and, where reasonable, that you have told that person about it. Please provide only what the feature needs (for example, a first name or nickname, an age range and interests) and do not provide health or other sensitive information about another person. We use information about a gift recipient only to provide the feature for which it was submitted. We do not use it to build a marketing profile of that person and we do not send that person marketing communications unless they separately create an account and consent. A person whose Personal Information has been provided to us by another user may contact our Privacy Officer to access, correct or request deletion of that information. Invitations and list-sharing messages sent at a user’s request identify the user who sent them, do not contain advertising, and include a link to this Privacy Policy and a way to ask us not to send further invitations. We delete information about a gift recipient or invitee who does not have an account when the related list, recommendation request or account is deleted, and we do not keep it longer than the feature needs.

Device Identifiers: When you access the Services by or through a device, we may access, collect, monitor and/or remotely store one or more “device identifiers”, device ID, device type, device model, operating system and version, mobile advertising identifiers (such as the Google Advertising ID), application instance identifiers and push notification tokens. Device identifiers allow us to uniquely identify your device and are used to enhance the Services (including sending updates and information from the Services). A device identifier may also be used in conjunction with other Personal Information. Not every App or version uses each of these identifiers. Section 11 describes what the current App and browser extension actually collect.

Analytics: When you access our Services, we may collect information (either directly or using third party services) using logging and cookies which can sometimes be correlated with Personal Information. We use this information to monitor and analyze use and interest in the Services. We may use session recording and heatmap tools on the Site and in the App to see how pages and features are used and to diagnose problems. We configure these tools to mask passwords and payment fields and the text you type into forms. Session recording and heatmap tools are not strictly necessary and are subject to your choices in the cookie preference control described below.

Log data: As with most website and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address of your device, the address of the web page visited before using the Services, the purchases that you make, the products you view, browser type and settings, the date and time the Services were accessed, information about browser configuration and plugins, language preferences and cookie data. It may also include your device’s GPS signal or information about nearby Wi-Fi access points and base stations that may be transmitted to us when you use certain Services and enable the location function on your device.

Cookie and Tracking Information: Cookies are small text files stored on your device by your web browser, allowing it to remember passwords, preferences, and other details when you visit a website. We use both persistent cookies, which remain on your device until deleted, and session cookies, which expire when you close your browser. These cookies help collect usage data, such as preferences, which may be linked to your Personal Information. We also use cookies to optimize product/merchant links, customize the Service, and improve offerings for merchants and advertisers. We may sync cookie identifiers with advertising partners to measure and personalize advertising, as described in Section 1B. These identifiers are Personal Information and are subject to your choices in Section 1B. If you reside in Quebec, cookies and similar technologies used to profile you or to serve advertising based on a profile are off by default and are activated only if you turn them on through the cookie preference control.

Additionally, we may use third-party cookies and tracking technologies across our Services and other sites, including social media platforms, for operational, performance, functionality, and advertising purposes. Where the law requires your consent before we use cookies and similar technologies that are not strictly necessary, including for analytics and advertising (for example, if you reside in Quebec), we use them only after you turn them on. Elsewhere, we use them by default and you can turn them off at any time through the cookie preference control available on every page of the Site and through your browser settings. Turning off advertising cookies in one browser does not change the personalization settings in your account; see Section 1B.

1A. INFORMATION WE COLLECT THROUGH THE APPS

When you download, install or use the App, we collect the categories of information described above and, in addition: (a) information about your device and its configuration, including device model, operating system and version, language and region settings, network type, App version and installation identifier; (b) diagnostic information, including crash reports, performance data and error logs; (c) information about how you interact with the App, including screens viewed, features used, and items saved, shared or selected; and (d) your push notification token, if you enable notifications.

The App may ask your permission to access certain features or information on your device. These permissions are optional and are requested at the point at which the related feature is used:

• Contacts. If you choose to use a feature that helps you find, invite, or create a list for people you know, we access the contact entries you select in order to provide that feature. We use the contact information you select only for the purpose of the feature you invoked. We do not upload your address book for advertising purposes, and we do not sell contact information.

• Camera and photo library. If you choose to add an image to a list, a gift or your profile, we access only the images you select.

• Notifications. If you enable notifications, we use your push notification token to send you the messages described in this Privacy Policy. You may disable notifications at any time in your device settings.

• Location. If you enable location services, we may use your approximate location to show locally relevant merchants, delivery options and gift guides. You may disable location access at any time in your device settings.

You may grant or withdraw any of these permissions at any time in your device settings. If you withdraw a permission, the feature that depends on it will stop working or will work only in part; the remainder of the Services will continue to be available to you.

The Apps include software development kits and other components supplied by third parties, which perform analytics, crash reporting, attribution, payment processing and advertising functions, and which may collect device identifiers and information about your use of the Apps directly from your device. These third parties act as our service providers, except where this Privacy Policy describes them as independent advertising partners.

1B. ADVERTISING, AFFILIATE TRACKING AND YOUR CHOICES

The Services contain affiliate links and paid placements, as described in our Terms of Use. When you follow a link to a merchant, the merchant or an affiliate network may record a click identifier so that a resulting purchase can be attributed to Giiftii for the purpose of paying a commission. We receive reports of those transactions, which may include the item purchased, the amount and the date, and we use them for payment reconciliation, fraud prevention and reporting.

The Services may display advertising served by third-party advertising networks. Those networks may use cookies, device identifiers and mobile advertising identifiers to select and measure advertisements, and may combine that information with information they collect from other apps and websites. Where the law requires your consent before advertising may be selected on the basis of a profile, we will obtain that consent before allowing such advertising to be served to you.

You may limit interest-based advertising at any time. On Android, you may delete or reset your advertising identifier and opt out of advertising personalization in your device settings. On iOS, you may withhold or revoke tracking permission in your device privacy settings. In a browser, you may manage cookies through the cookie preference control on the Site and through your browser settings.

Profiling and personalized recommendations

The Services include technology that can profile you, meaning to build an assessment of your preferences, interests and characteristics from your activity on the Services, such as items you view, save or share. When this is on, we use it to personalize your gift recommendations, the order in which products are shown to you, and the merchant content and advertising you see.

Quebec residents. If you reside in Quebec, profiling is turned off by default. We will not profile you unless you turn on Personalized recommendations or Personalized ads in the privacy settings of your account on the Site or in the App. You can turn them off again at any time in the same place, or by contacting our Privacy Officer.

Other users. If you reside outside Quebec, personalized recommendations and personalized ads are turned on when you create your account, and we tell you about them when you sign up. You can turn either off at any time in the privacy settings of your account or by contacting our Privacy Officer. If you are in a US state that gives you the right to opt out of the sale or sharing of personal information for targeted advertising, you can also use the “Your Privacy Choices” link or a Global Privacy Control signal.

Recommendations you request. When you use the Gift Finder, we use the details you enter, such as budget, occasion and the recipient’s interests, to produce the recommendations you asked for. We do not add those details to a profile of you unless profiling is turned on.

If profiling is off. We continue to provide the Services using non-personalized recommendations. Profiling is never used for an account belonging to, or supervised on behalf of, a person under 18 (see Section 9).

We determine your province of residence from your account settings or, if you are not signed in, from your approximate location based on IP address. If we cannot determine your province, we apply the settings described above for non-Quebec residents.

2. USE OF INFORMATION

We generally use information that we collect for the purposes described below, with your consent (express or implied, depending on the sensitivity of the information and your reasonable expectations) or as otherwise permitted or required by law. More specifically, Giiftii uses Personal Information:

To provide, update, maintain and protect the Services and our business. This includes use of Personal Information to support delivery of the Services, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at your request. Giiftii may use your email address or phone number to send you notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with Giiftii by email, we may retain the content of your email messages, your email address and our responses.

To personalize your experience and improve customer service. This includes using your Personal Information to notify you of lists created and shared on Giiftii by your connections, to respond to your customer service requests and support needs, and to provide the features you use. Where profiling is turned on (see Section 1B), we also use your gift giving and gift receiving preferences to personalize recommendations and the products and advertising you are shown. We do this only in accordance with your profiling and advertising settings described in Section 1B.

As required by applicable law, legal process or regulation. Giiftii may in certain instances be compelled by law to process your Personal Information to comply with a binding order. We will only do so to the extent reasonably required by that order.

To communicate with you by responding to your queries, lists, requests, comments and questions. If you contact Giiftii, Giiftii may use your Personal Information to respond.

To send emails and other communications. Giiftii may send you service, technical and other administrative emails, messages and other types of communications. Giiftii may also contact you to inform you about changes in our services, and important notices, such as security and fraud notices.

To process transactions, including, billing, account management and other administrative matters. We will use your information to process transactions. This includes processing discount codes and affiliate links provided by our third-party affiliate brands. We may need to contact you for invoicing, account management, granting permissions to your connections and similar reasons, and we use account data to administer accounts.

To investigate and help prevent security issues and abuse and to otherwise monitor the Site for violations of our policies or applicable laws. To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities and/or attempts to harm our users.

For marketing purposes. Giiftii may use the information we collect, including Personal Information, to market the products and services of our merchant partners and advertisers to new and existing customers, and to understand our audience. Where you have consented, or where Canada’s Anti-Spam Legislation and other applicable law otherwise permit, Giiftii may send you marketing messages. We may use Service Providers to send those messages on our behalf, but we do not give your contact information to merchants or advertisers so that they can market to you unless you ask us to. If you don’t want to receive these messages, you can opt out by following the instructions in the message or by submitting your request to privacy@giiftii.com.

To improve our Site. We continually strive to improve our Site’s offerings based on the information and feedback we receive from our users and visitors.

We also use Information as otherwise described in this Privacy Policy, permitted by law, or as we may notify you.

3. PROTECTING YOUR INFORMATION

Giiftii implements security measures designed to maintain the security of your information from unauthorized access. These security measures are implemented both during transmission of Personal Information and once received. The security of your Personal Information is important to us. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password. We maintain administrative, technical and physical safeguards appropriate to the sensitivity of the information.

Information submitted through the Services is encrypted in transit using current industry-standard transport layer security. Payments are processed by third-party payment processors and, where a purchase is made within the App, by the operator of the applicable app store; we do not receive or store complete payment card numbers. However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure. By using or accessing the Site, you acknowledge that you understand and agree to assume these risks.

3A. SECURITY INCIDENTS

If a breach of security safeguards involving your Personal Information creates a real risk of significant harm to you, or, for Quebec residents, a confidentiality incident presents a risk of serious injury, we will notify you and report it to the Office of the Privacy Commissioner of Canada and, where applicable, the Commission d’accès à l’information du Québec, as soon as feasible and as required by law. We may also notify other organizations or government institutions that may be able to reduce the risk of harm. We keep a record of every breach of security safeguards and confidentiality incident, as required by law.

4. LINKS TO OTHER WEBSITES

As part of the Services, you may encounter links to other websites or applications. When you access these other websites or applications, you are leaving the Services. We are not responsible for the privacy practices employed by those websites or the information, content, or products and/or services they contain or offer. This Privacy Policy applies solely to information collected by us through the Services. Therefore, this Privacy Policy does not apply to your use of a third-party website accessed by a link on our Site. To the extent that you access or use the Site through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements posted on each such third-party site before proceeding to use them.

5. INFORMATION SHARING AND DISCLOSURE

Giiftii may share, transfer and/or disclose your Personal Information to or with third parties to provide the services or products requested by you, and under the following circumstances:

• Giiftii may share Personal Information and other information we collect with our Service Providers that help us with our marketing and business development efforts. These third-party service providers may have access to information about you if it is needed to perform their functions for us, but they are not authorized by us to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements, and they are required to maintain the information in confidence.

• Giiftii shares device, analytics and usage information with Service Providers to understand and improve how the Services are used. Where this information is Personal Information, it is handled as described in this Privacy Policy.

• Giiftii reserves the right to disclose Personal Information: as permitted or required by law; when Giiftii believes disclosure is necessary to protect our rights or to comply with a legal process; and/or in the event it is necessary to prevent, investigate or take action regarding unlawful, illegal or suspicious activities that violate the Terms of Use or this Privacy Policy.

• Giiftii may share your Personal Information in response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request.

• Giiftii may share your Personal Information with third parties to investigate, prevent, or take action regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies or the law.

• Giiftii may transfer Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Giiftii about Giiftii’s Users is among the assets transferred. Before the transaction is completed, any prospective buyer may receive only the Personal Information needed to evaluate the transaction, under an agreement requiring it to use and protect that information only for that purpose.

All information voluntarily shared by you through forums, comments, or blog posts is publicly available and your username may be visible by other Users. Giiftii is not responsible for any information you submit that can be read by other Users and can be used to send you unsolicited information by other Users.

Lists, wishlists, gift boards and registries. When you create a list, you choose who can see it. New lists are private (visible only to you) until you choose to share them with specific people or make them public. A public list, including the name, profile image and items shown on it, can be seen by anyone with the link and may be indexed by search engines. Think carefully before adding items, notes or photos that reveal sensitive information, such as a health condition or a pregnancy. You can change a list’s visibility, or delete it, at any time.

Giiftii may, from time to time, choose to post certain Personal Information about a User for promotional or Service-related purposes; prior to posting said information, Giiftii will obtain the User’s consent via email.

6. RETENTION OF INFORMATION

Giiftii will retain your Personal Information only for as long as necessary for the purposes set out in this Privacy Policy. We will also retain and use your Personal Information to the extent necessary or reasonable to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. In practice, we retain the Personal Information associated with your account for as long as your account remains open. Following deletion of your account, we delete or de-identify that information within 30 days in our active systems and within 90 days in our backups, except for information we are required or permitted by law to retain. Information retained after deletion may include transaction, payment and tax records, records relating to unredeemed or outstanding gift value, records reasonably necessary for fraud prevention and platform security, records subject to a legal hold or to an unresolved dispute or chargeback, and a record of your communication preferences so that we can continue to honour your opt-out. Information retained for these purposes is not used for marketing or profiling.

Giiftii will also retain usage and log information (such as the log data described in Section 1) for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7. TRANSFER OF INFORMATION

Your information, including Personal Information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located outside of Canada, please note that we transfer data, including Personal Information, to Canada and process it there. By using the Services, you understand and acknowledge that your Personal Information will be transferred to and processed in Canada, which may have different data protection rules than in your country.

We use service providers, including cloud hosting, analytics, communications, payment and advertising providers, that are located in, or that store or process information in, the United States and other countries outside Canada. Your Personal Information may therefore be stored or processed outside Canada and outside your province of residence, and while it is there it is subject to the laws of those jurisdictions, including lawful access by their courts, law enforcement agencies and national security authorities.

Giiftii will take steps reasonably designed to treat your Personal Information securely and in accordance with this Privacy Policy, as further described below.

8. SHARING OF INFORMATION

Personal Information - We do not sell, trade or rent your Personal Information, and we do not share your Personal Information with third parties for those parties’ own marketing purposes without your consent. We do share Personal Information with advertising and analytics partners for the purposes and on the basis described under Section 1B herein. Some privacy laws define a “sale” or “share” of personal information broadly enough to include disclosures of that kind for targeted advertising; where such a law applies to you, you may exercise the opt-out described in that section. We may share your Personal Information with Service Providers who assist us, such as email servers, but they can only use your information as directed by us and in accordance with this Privacy Policy. Your Personal Information is primarily used to manage your account, communicate with you, respond to inquiries, provide technical support, and inform you about updates and service tips.

Non-Personal Information - We use Non-Personal Information to improve our Services, customize user experiences, track trends, and analyze usage patterns. IP addresses are used to reduce fraud and identify non-human browsing activity. We may share Non-Personal Information with partners, advertisers and other third parties. Before sharing information on this basis, we anonymize or aggregate it, in accordance with applicable law, so that it cannot reasonably be used to identify you, we do not attempt to re-identify it, and we require the recipient by contract not to attempt to re-identify it. You grant Giiftii a non-exclusive, perpetual, worldwide license to aggregate user-provided content and create de-identified, aggregate data to identify trends and other metadata that cannot reasonably be used to identify you.

9. CHILDREN’S PRIVACY

You must be 18 years or older to use our Services. Minors under 18 and at least 13 years of age are only permitted to use our Services through an account owned by a parent or legal guardian with their appropriate permission and under their direct supervision. Children under 13 years are not permitted to use the Site, the Apps or the Services. No one under age 13 may provide any information to or on the Site or through the App. We do not knowingly collect personal information from children under 13. In Quebec, Personal Information about a minor under 14 is collected only with the consent of the person having parental authority. Gift recipients may be children. Information about a child that a parent or other user provides for a gift recommendation or list is used only for that feature, is never used for profiling or advertising, and should be limited to what the feature needs, such as a first name or nickname, an age range and interests.

If you are a parent or guardian and learn that your child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under 13 (or under 14 in Quebec), we will delete it.

10. SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate the Services and our provision of Services through the Site, to provide the Services on our behalf, to perform services related to the Services (as discussed above), to assist us in analyzing how our Services are used, and to assist us with business development and marketing efforts related to the Services (“Service Providers”). These Service Providers may have access to your Personal Information only to perform these tasks on our behalf. We do not permit Service Providers to use Personal Information for their own purposes, including to train their own artificial intelligence models, except aggregated, anonymized data that can no longer identify you, where the law permits.

11. APP AND EXTENSIONS

This section describes the information practices of the current version of the Giiftii mobile app (Version 1) and the Giiftii Chrome extension. Where this section is more specific than the rest of this Privacy Policy, this section governs for the App and the extension.

11.1 Account information and support

Your Personal Information is primarily used to manage your account, communicate with you, respond to inquiries, provide technical support, and inform you about updates and service tips.

If you contact Giiftii, Giiftii may use your Personal Information to respond.

11.2 Service emails

Giiftii may send you service, technical and other administrative emails, messages and other types of communications. Giiftii may also contact you to inform you about changes in our services, and important notices, such as security and fraud notices.

11.3 Selected photos

If you choose to add an image to a registry, we access only the image you select from your photo library. Version 1 does not access your camera or request access to your full photo library.

11.4 Account deletion requests

After you request account deletion, we send you an email asking you to confirm the request. Once you confirm using the link in that email, your account is immediately disabled and you can no longer log in. Disabling access is a separate step from completing deletion of your stored personal information.

Deleting the App from your device does not delete your account.

11.5 Features covered by the broader policy

The broader policy describes features across the Giiftii Services. Those descriptions do not mean that every feature is available or enabled in Version 1. Version 1 does not use camera capture, device contacts, device location, biometric authentication, push notifications or mobile advertising identifiers. These statements concern the mobile app and do not describe server-side logging or the practices of retailers and other external websites.

11.6 Giiftii Chrome extension

This section describes the Giiftii Chrome extension. It explains the extension-specific information handling alongside the existing policy below.

11.7 Selected shopping page

When you open the extension, it reads product information from the shopping tab you selected, including available product title, image address, price, currency, brand, description and page URL. It does not automatically scan unrelated tabs or request access to your general browsing history. Detection depends on the page loading and providing product information. Retailer images and favicons may be requested to display the preview, which exposes normal network-request information to those servers.

11.8 Sign-in and local storage

Your email or username and password are sent over HTTPS to Amazon Cognito for Giiftii authentication. The extension does not persist your password. It stores session and refresh tokens and basic account information in extension-owned Chrome storage to keep you signed in, together with your last selected destination and an opaque pending-save fingerprint. Destination information is cached for the browser session. The account country setting, when available, is used for the supported saving market. The extension does not request GPS access.

11.9 Saving and access

When you choose a destination and click Add to Giiftii, the extension sends the detected product information, optional size and colour, destination identifier and authentication token to Giiftii. It requests quantity one. Giiftii verifies access to the destination before saving. The extension does not provide payment, health-record or messaging forms.

11.10 Links you save

The extension sends the product link to Giiftii exactly as it appears on the shopping page. The extension does not add, change or open affiliate links, does not rewrite links on the shopping page and does not set retailer cookies. On giiftii.com, the Shop link of a saved product may be a Giiftii affiliate link, and Giiftii may earn a commission from a purchase made through it. This is done by the website, not by the extension, and is described under “Advertising, affiliate tracking and your choices” above. To prepare that Shop link, Giiftii’s servers may send the product link to affiliate programs; this request does not include the account email or destination identifier. Affiliate programs and merchants may process information when their links are followed, under their own privacy policies.

11.11 Diagnostics and retention

Giiftii’s general API request log records a request identifier, method, route template, response status and duration. It excludes request headers and bodies. Some affiliate error logs may contain the submitted merchant URL and its query parameters. Server logs are configured for daily rotation with fourteen retained rotations. Authentication services, error monitoring, affiliate providers, account records and backups have separate retention practices; the rotation setting is not a promise that all account data is deleted after fourteen days. Sections 6 and 15 describe retention and your privacy rights.

11.12 Logout, uninstall and account deletion

Sign out clears the extension’s locally stored session and account data, destination cache and pending-save state. It attempts to revoke the Cognito refresh token; a network failure may prevent that remote revocation. Removing the extension clears its storage for that Chrome installation. Neither logout nor uninstall deletes previously saved products or the Giiftii account, or guarantees immediate revocation of every previously issued token. To request account-data deletion, use Giiftii’s account deletion controls or contact privacy@giiftii.com. Account disabling and completion of deletion are separate steps, as explained above.

12. SWEEPSTAKES AND COMPETITIONS

We may run sweepstakes, competitions and other engagements from time to time and participation may require that you opt in to receive marketing communications from us, among other conditions. You may opt out of receiving marketing or other communications from us at any time by following the steps described below. In the event of any differences between the terms of the engagement and the terms of this Privacy Policy, the terms of the engagement will take precedence.

13. COMMUNICATIONS OPT-OUT

You may opt out of receiving marketing or other communications from Giiftii at any time by following the opt-out link or other unsubscribe instructions provided in any email message received, or by submitting your request to privacy@giiftii.com. We give effect to your request without delay and in any event within 10 business days. Note that, even if you opt out of receiving marketing communications from Giiftii, we will still send you account management confirmations and other non-marketing related messages.

14. EDIT OR DELETE ACCOUNT

If your Personal Information changes, you may correct, update or amend it on the account profile page after you log in at www.giiftii.com, or in the account settings of the App. You may delete your account, and the Personal Information associated with it, at any time: (a) in the account settings of the App; (b) in your account settings on the Site; or (c) by submitting a request to privacy@giiftii.com. Deleting the App from your device does not delete your account. We will confirm your request and complete the deletion within the periods described under “Retention of information” above.

15. YOUR PRIVACY RIGHTS

Subject to the limits and exceptions provided by applicable law, you have the right to:

• Access. Ask us to confirm whether we hold Personal Information about you, to provide you with a copy of it, and to tell you how it has been used and to whom it has been disclosed.

• Correction. Ask us to correct Personal Information that is inaccurate, incomplete or out of date.

• Withdrawal of consent. Withdraw your consent to a use or disclosure of your Personal Information at any time, subject to legal and contractual restrictions and reasonable notice. We will tell you what the consequences of withdrawal will be before we act on it.

• Deletion. Ask us to delete your account and the Personal Information associated with it, as described above.

• Portability. If you reside in Quebec, ask us to give you Personal Information collected from you in a structured, commonly used technological format, or to send it to a person or body you designate.

• Stop dissemination and de-indexing. If you reside in Quebec, ask us to stop disseminating your Personal Information, or to de-index any hyperlink attached to your name that gives access to it, where the law allows.

• Control of profiling. Turn profiling on or off at any time, as described under “Profiling and personalized recommendations” in Section 1B. If you reside in Quebec, profiling stays off unless you turn it on.

To exercise any of these rights, contact our Privacy Officer using the details below. We will respond within 30 days of receiving your request, or within any shorter period required by applicable law. We may ask you for information reasonably necessary to verify your identity before acting on a request. There is no charge for making a request. If you are not satisfied with our response, you may make a complaint to the Office of the Privacy Commissioner of Canada or, if you are a resident of Quebec, to the Commission d’accès à l’information du Québec.

16. CHANGES TO PRIVACY POLICY

Giiftii may amend or update this Privacy Policy from time to time. Any such amendment or update will be effective upon our posting of the revised Privacy Policy, and we will revise the effective date below. If an amendment materially affects the purposes for which we collect, use or disclose your Personal Information, or the parties with whom we share it, we will notify you in advance through the Services or by email, and, where the law requires it, we will obtain your consent before applying the change to Personal Information already collected. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement and acceptance of the amended Privacy Policy.

17. EFFECTIVE DATE

This Privacy Policy is effective as of October 23, 2026.

18. CONTACT INFORMATION

If you have any question about this Privacy Policy, wish to exercise any of the rights described above, or wish to make a complaint, please contact our Privacy Officer, who is also the person in charge of the protection of personal information under Quebec law: Privacy Officer, Giiftii Systems Inc., 3300 Bloor Street West, Suite 670, West Tower, Toronto, Ontario, M8X 2X2, privacy@giiftii.com.

19. LANGUAGE

This Privacy Policy is available in French at https://www.giiftii.com/privacy-policy/fr. Cette politique de confidentialité est disponible en français à l’adresse https://www.giiftii.com/privacy-policy/fr.