Privacy Policy

This newsletter is published by:

Cogni6 inc. Quebec, Canada francis@cogni6.com

The person responsible for the protection of personal information (as required by Quebec's Law 25) is Francis Beaulieu, President. For any privacy-related request, question, or complaint, contact:

Francis Beaulieu francis@cogni6.com

The newsletter operates at newsletter.xpert6.ca.

We collect the following personal information:

• Email address: provided when you subscribe to the newsletter via the subscription form on our website
• Technical browsing data: collected automatically through cookies and analytics tools (pages visited, time on site, referral source, device type, approximate geographic region, browser type)
• Conversion data: whether a click on a Google ad led to a subscription

We do not collect your name, phone number, physical address, or any other personal information unless you voluntarily provide it by replying to an edition.

Your personal information is collected for the following purposes:

• Delivering the newsletter editions to your inbox (email address)
• Understanding how visitors interact with the website to improve content and user experience (analytics data)
• Measuring the effectiveness of our advertising campaigns (conversion tracking)

We do not use your personal information for profiling, automated decision-making, or any purpose not listed above.

Personal information is collected through:

• The subscription form on the website (email address, with your express consent)
• Statistical cookies placed by Google Analytics (browsing behavior)
• Conversion cookies placed by Google Ads (ad click to subscription tracking)
• Vercel Analytics (anonymous, aggregated data without cookies)
• Mailchimp tracking (email open rates and click-through rates)

We obtain your consent as follows:

• Newsletter subscription: express opt-in consent when you enter your email address and click the subscribe button. We recommend double opt-in (confirmation email) to ensure valid consent under CASL.
• Statistical and advertising cookies: these require your express consent before being activated. Non-essential cookies (Google Analytics, Google Ads) are not loaded until you consent.
• You may withdraw your consent at any time by unsubscribing (link in every edition) or by contacting us at francis@cogni6.com.

This website uses a limited number of cookies, exclusively for statistical and advertising measurement purposes.

• Statistical cookies (Google Analytics): collect anonymous data about site usage (pages visited, time on site, navigation paths). Set by Google (_ga, _gid). Expire after 13 months maximum. Do not identify you personally.
• Conversion cookies (Google Ads): measure whether a click on a Google ad led to a newsletter subscription. Not used for retargeting or behavioral advertising.
• Essential cookies (Vercel): minimal technical cookies required for hosting security and performance. Not used for tracking. These are strictly necessary and do not require consent.

We do not use retargeting cookies, social media tracking pixels, or third-party advertising cookies beyond conversion measurement.

You can disable non-essential cookies at any time through your browser settings or through the cookie consent mechanism on our website. The website will continue to function normally without them.

The following third-party service providers process personal information on our behalf:

• Mailchimp (The Rocket Science Group LLC, United States): manages our mailing list and delivers the newsletter. Processes email addresses, open rates, and click data. Privacy policy: mailchimp.com/legal/privacy
• Google Analytics (Google LLC, United States): collects anonymous website analytics via statistical cookies. Privacy policy: policies.google.com/privacy
• Google Ads (Google LLC, United States): measures advertising conversion. Privacy policy: policies.google.com/privacy
• Vercel Inc. (United States): hosts the website and provides anonymous analytics. Privacy policy: vercel.com/legal/privacy-policy

IMPORTANT: These service providers are located in the United States. By using this website and subscribing to the newsletter, your personal information may be transferred to and processed in the United States. We have assessed this transfer in accordance with Quebec's Law 25 (section 17) and determined that these providers offer adequate contractual protections for your personal information. However, US law may permit government access to data in circumstances that differ from Canadian law.

We do not sell, rent, or share your personal information with any other third parties.

• Email address: retained in our Mailchimp list for as long as you remain subscribed. Upon unsubscription, removed from our active list within 30 days. Mailchimp may retain anonymized or aggregated data beyond this period.
• Analytics data: retained in aggregated, anonymized form by Google Analytics for up to 26 months. Cannot be linked to individual users.
• Conversion data: retained by Google Ads for up to 90 days.
• Consent records: retained for the duration of the subscription plus 3 years, as evidence of valid consent under CASL and Law 25.

We implement reasonable administrative, technical, and physical measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These include:

• Encrypted transmission (HTTPS/TLS) for all data in transit
• Access controls limited to authorized personnel
• Use of reputable service providers with industry-standard security practices
• No storage of personal information on local devices or unprotected systems

No method of electronic transmission or storage is 100% secure. If you have reason to believe your information has been compromised, contact us immediately at francis@cogni6.com.

Under Quebec's Law 25 and Canada's PIPEDA, you have the following rights:

• Right of access: request a copy of the personal information we hold about you
• Right of rectification: request correction of inaccurate or incomplete personal information
• Right of withdrawal of consent: withdraw your consent to the collection, use, or communication of your personal information at any time
• Right to data portability: request your personal information in a structured, commonly used technological format (e.g., CSV)
• Right to de-indexation: request that we cease disseminating your personal information or de-index any hyperlink to it, where the dissemination contravenes the law or a court order
• Right to erasure: request deletion of your personal information, subject to legal retention obligations
• Right to be informed: be informed of the existence of automated decision-making and the right to have personal information handled by a human (we do not use automated decision-making)

To exercise any of these rights, contact:

Francis Beaulieu francis@cogni6.com

We will respond within 30 days of receiving your request, as required by law. If we are unable to fulfill your request, we will provide a written explanation.

If you are unsatisfied with our response, you may file a complaint with the Commission d'acces a l'information du Quebec (CAI) at cai.gouv.qc.ca, or with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca.

Under Canada's Anti-Spam Legislation (CASL), every newsletter edition includes:

• Clear identification of the sender (Cogni6 inc.)
• A valid physical mailing address or contact information
• A functional unsubscribe mechanism that is processed within 10 business days
• The unsubscribe link remains functional for at least 60 days after the message is sent

We only send the newsletter to subscribers who have provided express opt-in consent. We do not send unsolicited commercial messages. We maintain records of consent including the date, method, and content of the consent statement.

In accordance with Law 25, we maintain a register of confidentiality incidents. In the event of an incident involving your personal information that presents a risk of serious prejudice, we will:

• Notify the Commission d'acces a l'information du Quebec (CAI) with diligence
• Notify affected individuals with diligence
• Take reasonable measures to reduce the risk of harm

This privacy policy complies with:

• Loi sur la protection des renseignements personnels dans le secteur prive (Law 25, Quebec): governs the collection, use, communication, and retention of personal information by private-sector organizations in Quebec. Enforced by the CAI.
• Personal Information Protection and Electronic Documents Act (PIPEDA, Canada): federal privacy law applicable to interprovincial and international data flows. Enforced by the OPC.
• Loi canadienne anti-pourriel / Canada's Anti-Spam Legislation (CASL): governs the sending of commercial electronic messages. Enforced by the CRTC.
• Charte de la langue francaise (Quebec): this privacy policy is available in both French and English, with the French version being the legally authoritative version for Quebec.

We may update this policy from time to time. Any changes will be posted on this page with an updated "last updated" date. We will not materially change how we use your personal information without providing reasonable notice to subscribers. For significant changes, we will notify subscribers via the newsletter.