Privacy Policy

1. Introduction

Soradin Inc. is committed to protecting your privacy and handling personal information responsibly. This Privacy Policy explains how we collect, use, disclose and protect personal information when you access or use the Soradin platform.

Soradin operates in both Canada and the United States and complies with applicable privacy laws in both jurisdictions including:

• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
• British Columbia's Personal Information Protection Act (BC PIPA)
• Alberta's Personal Information Protection Act (Alberta PIPA)
• Applicable US state privacy laws including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
• Canada's Anti-Spam Legislation (CASL)

PIPEDA is built on ten fair information principles that govern how organizations collect, use and disclose personal information: accountability, identifying purposes, consent, limiting collection, limiting use disclosure and retention, accuracy, safeguards, openness, individual access and challenging compliance. Soradin's privacy practices are designed to fulfill each of these principles as described throughout this policy.

By using the platform you agree to the collection and use of information in accordance with this Privacy Policy.

2. Privacy Officer and Accountability

Soradin has designated a Privacy Officer who is responsible for overseeing compliance with PIPEDA, BC PIPA, Alberta PIPA and applicable US privacy laws. The Privacy Officer is accountable for Soradin's personal information handling practices and ensuring that third party service providers who handle personal information on Soradin's behalf maintain appropriate protections.

Privacy requests, complaints and inquiries should be directed to:

Privacy Officer

Email: support@soradin.com

Website: soradin.com

Soradin will respond to all privacy requests within 30 days.

3. Information We Collect and Why

Soradin identifies the purpose for collecting personal information before or at the time of collection and collects only the information necessary for identified purposes.

3.1 Information You Provide Directly

When you use Soradin you may voluntarily provide:

• Name, email address and phone number for the purpose of facilitating consultation requests and account management
• Details about your estate planning needs submitted through consultation request forms for the purpose of connecting you with relevant professionals
• Account registration information for the purpose of managing your account
• Payment information processed through Stripe for the purpose of processing subscription payments
• Communications sent through the platform for the purpose of facilitating connections between families and professionals
• Feedback and survey responses for the purpose of improving the platform

Professionals creating or claiming accounts may additionally provide professional credentials and license numbers, business address and contact information, professional biography and photograph, service descriptions and specialties and educational content submissions.

3.2 Publicly Available Professional Information

Soradin compiles professional directory listings using publicly available information sourced from government regulatory registries and other public sources. This includes state and provincial bar association registries, FINRA BrokerCheck and SEC IAPD databases, state and provincial insurance regulatory databases, CPA regulatory body registries, funeral regulatory authority registries and publicly available business websites and professional profiles.

Under PIPEDA and BC PIPA and Alberta PIPA, business contact information that professionals have made publicly available for professional purposes is not subject to consent requirements when used for directory purposes consistent with the reason the information was made public. An employee's name, title and business contact information are not considered personal information under PIPEDA when used for business communications.

3.3 Automatically Collected Information

When you access Soradin we automatically collect IP address and approximate geographic location, device type, operating system and browser type, pages viewed, features used and actions taken on the platform, time and duration of platform visits, referring websites or links and search terms used within the platform. This information is collected for the purpose of improving platform performance, analyzing usage patterns and maintaining security.

3.4 Cookies and Tracking Technologies

Soradin uses cookies, web beacons and similar tracking technologies. Essential cookies are required for platform functionality and cannot be disabled. Analytics cookies help us understand how users interact with the platform. Marketing cookies are used to deliver relevant communications where consent has been obtained.

Users may control non-essential cookies through browser settings or our cookie preference center. Disabling cookies may affect certain platform features. California residents and other users with applicable rights may opt out of certain tracking through our cookie preference center.

4. How We Use Your Information

Soradin uses personal information only for the purposes for which it was collected or for consistent purposes that individuals would reasonably expect. Soradin uses personal information to operate, maintain and improve the platform, facilitate consultation requests between families and professionals, process subscription payments and manage billing, send service-related communications including confirmations and account updates, send commercial electronic messages where consent has been obtained or implied consent exists under CASL, respond to support inquiries and resolve disputes, comply with legal, regulatory and tax obligations, maintain platform security and prevent fraud and abuse, analyze usage patterns and improve user experience and enforce these Terms and our policies.

Soradin does not sell personal information to third parties.

5. Consultation Request Data

When a family submits a consultation request the family's name, contact information and inquiry details are shared with the relevant professional. For unclaimed profiles where Soradin holds the professional's publicly sourced contact information Soradin may forward consultation request notifications to that contact to notify the professional of consumer interest. Families acknowledge that by submitting a consultation request their contact information and inquiry details will be shared with the professional they are contacting.

6. Sharing and Disclosure of Information

Soradin collects personal information only for identified purposes and does not use or disclose it for other purposes without consent except as required or permitted by law.

With professionals: When a family submits a consultation request relevant contact and inquiry information is shared with the professional.

With service providers: Soradin works with Vercel for platform hosting, Supabase for database services, Stripe for payment processing and analytics providers. These providers access information only as necessary to provide their services and are required to maintain appropriate security and confidentiality consistent with this Privacy Policy. Soradin remains accountable for personal information handled by these providers.

As required by law: Soradin may disclose information in response to valid legal process including court orders, subpoenas or government requests, to comply with applicable laws, to protect the rights and safety of users or the public or to prevent fraud or illegal activity.

Business transactions: In connection with a merger, acquisition, financing or sale of all or part of Soradin's business personal information may be transferred as part of that transaction. Users will be notified of any such transfer and changes to this Privacy Policy.

With your consent: Soradin may share information in other circumstances with your express consent.

7. Professional Directory Data — Jurisdiction Specific

7.1 Canadian Professionals — Federal (PIPEDA)

Professional information compiled from public sources for Canadian professionals operating across provincial borders or in federally regulated industries is handled in accordance with PIPEDA. Canadian professionals may request access to personal information Soradin holds about them, request correction of inaccurate information and request removal of their unclaimed profile from the Soradin directory. Requests should be submitted to support@soradin.com. Soradin will respond within 30 days and process removal requests within 14 business days.

7.2 British Columbia Professionals — BC PIPA

Soradin is based in British Columbia and handles personal information in accordance with BC's Personal Information Protection Act for information collected used or disclosed within BC. BC residents have the same access, correction and removal rights as described under PIPEDA. Complaints about Soradin's privacy practices in BC may be directed to the Office of the Information and Privacy Commissioner for BC at oipc.bc.ca.

7.3 Alberta Professionals — Alberta PIPA

Alberta's Personal Information Protection Act applies to personal information collected used or disclosed within Alberta. Alberta residents have the same access, correction and removal rights as described under PIPEDA. Complaints about Soradin's privacy practices in Alberta may be directed to the Office of the Information and Privacy Commissioner of Alberta at oipc.ab.ca.

7.4 United States Professionals

Professional information compiled from public regulatory records for US professionals is maintained consistent with applicable public record doctrine and US privacy law. US professionals may claim their profile to control how their information is presented. Soradin does not offer removal of US professional listings from its public directory where the information is sourced from public regulatory records.

8. Data Security and Safeguards

Soradin implements reasonable technical and organizational security measures to protect personal information from unauthorized access, use, disclosure, alteration or destruction including encryption of data in transit using TLS, access controls limiting employee access to personal information, regular security monitoring and vulnerability assessment and secure third party service provider agreements.

No internet-based system can guarantee complete security. Users acknowledge that information transmitted online carries inherent risks.

8.1 Data Breach Notification

In the event of a privacy breach that poses real risk of significant harm to individuals Soradin will notify the applicable Privacy Commissioner and affected individuals as required by applicable law including PIPEDA's mandatory breach of security safeguards reporting requirements. Notification will occur as soon as reasonably possible after Soradin becomes aware of the breach. Soradin maintains a record of all privacy breaches regardless of whether notification is required.

9. Data Accuracy

Soradin makes reasonable efforts to ensure that personal information is accurate, complete and current for the purposes for which it is used. Users may request correction of inaccurate information by contacting support@soradin.com. Professionals who identify inaccuracies in their publicly sourced profile information may claim their profile to correct it or contact support@soradin.com.

10. Data Retention

Soradin retains personal information only as long as necessary to fulfill the purposes for which it was collected or as required by applicable law. Account information is retained for the duration of the account relationship and for a reasonable period thereafter. Consultation request data is retained for platform record keeping and dispute resolution purposes. Payment information is retained as required by tax and financial record keeping obligations. Publicly sourced professional directory data is retained as part of the platform directory subject to removal rights described in Section 7. Analytics data is retained in aggregated anonymized form indefinitely with individual usage data retained for up to 24 months.

Upon account deletion personal account data is removed or anonymized within 30 days except where retention is required by law.

11. Your Privacy Rights

11.1 All Users

Regardless of jurisdiction all users may request access to personal information Soradin holds about them, request correction of inaccurate information, withdraw consent for marketing communications at any time and lodge a complaint with a privacy regulatory authority.

11.2 Canadian Users — Federal

Canadian users have rights under PIPEDA to access and correct personal information and to challenge Soradin's compliance with PIPEDA. Unsatisfied users may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

11.3 BC Users

BC residents have rights under BC PIPA including access to and correction of personal information. Complaints may be filed with the Office of the Information and Privacy Commissioner for BC at oipc.bc.ca.

11.4 Alberta Users

Alberta residents have rights under Alberta PIPA including access to and correction of personal information. Complaints may be filed with the Office of the Information and Privacy Commissioner of Alberta at oipc.ab.ca.

11.5 California Users

California residents have rights under the CCPA and CPRA including the right to know what personal information is collected and how it is used, the right to delete personal information, the right to correct inaccurate personal information, the right to opt out of the sale or sharing of personal information and the right not to be discriminated against for exercising privacy rights. Soradin does not sell personal information. California residents may submit privacy requests to support@soradin.com.

11.6 Other US State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Texas and other states with comprehensive privacy laws may have similar rights under their applicable state laws. Soradin will respond to requests from residents of these states in accordance with applicable law.

12. Openness — How We Communicate Our Privacy Practices

Soradin makes information about its privacy policies and practices readily available to individuals. This Privacy Policy is publicly available at soradin.com/privacy. Users with questions about Soradin's privacy practices may contact the Privacy Officer at support@soradin.com.

13. CASL Compliance

Soradin complies with Canada's Anti-Spam Legislation in all commercial electronic messages sent to Canadian recipients. Commercial electronic messages sent to professionals are sent pursuant to implied consent under CASL where the professional has conspicuously published their business contact information for professional purposes without any statement indicating they do not wish to receive unsolicited messages, or pursuant to express consent where obtained.

All commercial electronic messages from Soradin include a clear functional unsubscribe mechanism. Unsubscribe requests are processed within 10 business days. You may also unsubscribe by contacting support@soradin.com. All commercial electronic messages sent by Soradin are relevant to the recipient's professional role or estate planning needs and identify Soradin as the sender.

14. Cross Border Data Transfers

Soradin operates in both Canada and the United States. Personal information may be stored, processed or transferred between these jurisdictions. When information is transferred between jurisdictions it remains subject to this Privacy Policy and Soradin's security standards. By using the platform you consent to the transfer of your personal information to and within Canada and the United States as described in this Privacy Policy.

15. Forward Looking Compliance

Canadian and US privacy laws are evolving. Canada's proposed Consumer Privacy Protection Act (Bill C-27) proposes significant updates to federal privacy requirements that would bring Canadian law closer to international standards. Multiple US states continue to enact comprehensive privacy legislation. Soradin monitors legislative and regulatory developments in both countries and will update its privacy practices and this policy as new requirements come into effect.

16. Third Party Links and Services

The Soradin platform may contain links to third party websites or services. Soradin is not responsible for the privacy practices of third party sites. Users should review the privacy policies of any third party sites they visit through links on the Soradin platform.

17. Children's Privacy

The Soradin platform is not intended for individuals under 18 years of age. Soradin does not knowingly collect personal information from minors. If Soradin becomes aware that personal information has been collected from a minor it will be promptly deleted. Parents or guardians who believe a minor's information has been collected may contact support@soradin.com.

18. Accessibility of This Policy

Soradin is committed to making this Privacy Policy accessible to all users including those with disabilities in accordance with WCAG 2.1 Level AA standards. If you require this Privacy Policy in an alternative format please contact support@soradin.com.

19. Changes to This Privacy Policy

Soradin may update this Privacy Policy from time to time. Material changes will be communicated to registered users by email at least 14 days before taking effect. The updated policy will be posted with a revised date. Continued use of the platform after changes are posted constitutes acceptance of the revised Privacy Policy.

20. Contact and Privacy Officer

Privacy inquiries, access requests, correction requests and complaints may be directed to:

Privacy Officer

Email: support@soradin.com

Website: soradin.com

Soradin will respond to all privacy inquiries within 30 days.