Privacy and Personal Information Protection Policy

Last updated: July 9, 2026

This Privacy and Personal Information Protection Policy applies to DOCUGO,
a service operated by Azur Média inc., a company incorporated in Quebec.
For the purposes of this policy, the terms “DOCUGO”, “we”, “our” or “us” refer to DOCUGO
and/or Azur Média inc., depending on the context.

DOCUGO offers, among other things, services related to estate and administrative procedures, including
will search services and the processing of related documents. As part of its activities, DOCUGO may
collect, use, disclose, retain and destroy certain personal information.

This policy aims to clearly explain how DOCUGO protects the personal information
entrusted to it, in accordance with the laws applicable in Quebec, including the
Act respecting the protection of personal information in the private sector.

1. Purpose of the policy

This policy is intended to inform clients, website visitors, suppliers, employees, candidates,
consultants and any other concerned person about:

• the types of personal information that DOCUGO may collect;
• the purposes for which this information is collected and used;
• the persons or organizations to whom this information may be disclosed;
• the security measures in place to protect it;
• the rights of the persons concerned;
• how to contact the person in charge of personal information protection.

2. Scope

This policy applies to personal information collected by DOCUGO in the course of its activities,
including through:

• the website docugo.ca;
• online forms;
• communications by phone, email or any other electronic means;
• documents sent by clients or authorized third parties;
• payment or billing transactions;
• relationships with suppliers, employees, candidates and consultants.

It also applies to officers, employees, consultants, agents, service providers and any
other person who processes personal information on behalf of DOCUGO.

3. Definitions

Personal information is any information about a natural person that allows that person to be identified,
directly or indirectly. This may include, for example, a name, address, email address,
phone number, date of birth, financial information, information relating
to a death, or a document that makes it possible to identify a person.

Sensitive personal information is information that, due to its nature or the context of its
use or disclosure, gives rise to a high degree of reasonable expectation of privacy. This may
include, for example, financial, medical, legal, estate, identification or any
other confidential information.

Business contact information, such as a person’s name, title, position, business address, business
email address or business phone number, is generally not considered
personal information when it relates to the performance of a role within a business.

4. Personal information collected

DOCUGO collects only the personal information necessary to provide its services, manage
its files, comply with its legal obligations and improve its operations.

Depending on the nature of the file or the relationship with DOCUGO, the information collected may include:

• first and last name;
• mailing address;
• email address;
• phone number;
• language of communication;
• information related to a service request;
• information related to an estate or a will search;
• name of the deceased;
• date of birth and date of death, when necessary;
• documents provided by the client or an authorized person;
• billing and payment information;
• communication history;
• IP address, cookies and browsing data;
• any other information necessary to carry out the requested service.

DOCUGO does not knowingly collect unnecessary personal information. If personal information
is no longer required for the intended purposes, DOCUGO ensures that it is destroyed, anonymized or retained only
when required by law.

5. Purposes of collection and use

DOCUGO may use the personal information collected for the following purposes:

• provide the services requested by the client;
• open, process, monitor and complete a file;
• carry out the required administrative or estate procedures;
• communicate with the client or an authorized person;
• verify a person’s identity or authorization when necessary;
• submit requests, forms or documents to the relevant organizations or professionals;
• issue invoices, receive payments and manage accounting;
• respond to questions, requests for information or complaints;
• comply with applicable legal, tax, accounting or regulatory obligations;
• improve the website, services and customer experience;
• prevent fraud, errors, privacy incidents or unauthorized use.

6. Consent

In general, DOCUGO collects personal information directly from the person concerned or
from a person authorized to act on their behalf. By voluntarily providing personal information to DOCUGO,
the person concerned consents to its collection, use and disclosure for the purposes set out in
this policy or at the time of collection.

Where required by law, DOCUGO will request express consent, including for the use or disclosure
of sensitive personal information.

A person may withdraw their consent, subject to applicable legal, contractual or administrative
restrictions. However, withdrawing consent may prevent DOCUGO from providing certain services or completing
a file.

7. Collection from third parties

In certain cases, DOCUGO may receive or collect personal information from third parties, including when
such information is necessary to process a file or complete a procedure requested by the client.

These third parties may include, depending on the context:

• a person authorized by the client;
• a family member or legal representative;
• a notary, lawyer or other professional;
• a public or para-public body;
• a provider of technology, payment, delivery or hosting services;
• any other third party where permitted by law or where consent has been obtained.

When personal information is not collected directly from the person concerned, that person may
ask DOCUGO for the source of the information, subject to the exceptions provided by law.

8. Disclosure of personal information

DOCUGO does not sell personal information. However, DOCUGO may disclose certain personal information
to third parties when necessary to provide its services, comply with a legal obligation or protect its
rights.

Personal information may be disclosed to the following categories of third parties, among others:

• organizations or institutions involved in a will search or administrative request;
• notaries, lawyers or professionals mandated or involved in the file;
• payment service providers;
• web hosting, email, cloud storage or technology providers;
• administrative, accounting or professional service providers;
• public bodies when required by law;
• competent authorities in the event of a legal obligation, fraud, litigation or security incident.

When DOCUGO entrusts personal information to a service provider, DOCUGO takes
reasonable measures to ensure that the information is used only for the intended purposes and is protected
adequately.

9. Payment providers and technology services

DOCUGO may use payment providers or external technology platforms to process
certain transactions, communications or online requests.

Depending on the services used, these providers may include:

• Stripe —
  Stripe Privacy Policy
• Clover —
  Clover Privacy Policy
• Global Payments —
  Global Payments Privacy Policy

Payment information, such as credit card numbers, is generally processed directly by secure
payment providers. DOCUGO does not store full credit card numbers, unless otherwise indicated
or required by applicable law.

10. Disclosure outside Quebec

Some personal information may be hosted, processed or disclosed outside
Quebec, including when DOCUGO uses cloud, payment, email,
web analytics or hosting service providers whose servers are located elsewhere in Canada or abroad.

Where required by law, DOCUGO takes reasonable measures to assess the risks associated with this
disclosure and to ensure that personal information receives adequate protection.

11. Cookies and similar technologies

DOCUGO’s website may use cookies, as well as other
similar technologies.

These cookies may be used, among other things, to:

• ensure the website functions properly;
• remember certain browsing preferences;
• analyze website usage;
• improve content, performance and user experience;
• measure the effectiveness of certain advertising campaigns or digital communications.

Visitors can configure their browser to refuse or delete certain cookies. However, some
website features may then not function properly.

12. Google Analytics and analytics tools

DOCUGO may use Google Analytics or other analytics tools to better understand how its
website is used and to improve its services.

These tools may collect certain browsing data, such as pages viewed, visit duration,
device type, browser used, approximate traffic source and certain interactions with
the site.

Visitors who wish to disable Google Analytics can consult the add-on offered by
Google:

disable Google Analytics
.

13. Security of personal information

DOCUGO implements reasonable security measures to protect the personal information it
holds against loss, theft, unauthorized access, unauthorized use, unauthorized disclosure,
unauthorized modification or unauthorized destruction.

These measures may include, among other things:

• limiting access to personal information to only those who need access;
• the use of passwords, permissions and controlled access;
• reasonable IT security measures;
• internal procedures for managing documents and files;
• staff awareness of confidentiality;
• secure destruction of information when it is no longer needed.

Despite the measures in place, no technological system can be guaranteed to be completely secure.
However, DOCUGO undertakes to take reasonable measures proportionate to the sensitivity of the information
processed.

14. Retention and destruction of personal information

DOCUGO retains personal information only for as long as necessary to achieve the purposes for
which it was collected, or for the period required by applicable laws, including tax,
accounting, administrative or legal requirements.

When personal information is no longer necessary, DOCUGO ensures that it is destroyed securely,
anonymized or retained only when permitted or required by law.

15. Privacy incidents

A privacy incident may include unauthorized access, unauthorized use, unauthorized disclosure,
loss or any other breach of the protection of personal information.

In the event of a privacy incident, DOCUGO takes reasonable measures to limit the risk of harm
and prevent such an incident from recurring.

Where required by law, DOCUGO will notify the Commission d’accès à l’information du Québec and the persons
concerned if the incident presents a risk of serious harm. DOCUGO also keeps a register of privacy incidents
in accordance with applicable requirements.

16. Rights of the persons concerned

Subject to the exceptions provided by law, any person concerned may exercise certain rights with respect
to their personal information, including:

• request access to the personal information that DOCUGO holds about them;
• request the correction of inaccurate, incomplete or ambiguous personal information;
• withdraw their consent to certain uses or disclosures;
• request information about the categories of persons who have access to their information;
• request the applicable retention period;
• request that dissemination cease or that information be de-indexed, where the conditions provided by law are met;
• request the portability of certain computerized personal information, where this right applies.

Any request must be submitted in writing to DOCUGO’s person in charge of personal information protection,
using the contact information provided below.

DOCUGO will respond to requests within the time limits provided by law. Where a request is refused, in whole or in part,
DOCUGO will explain the reasons for the refusal, subject to applicable restrictions.

17. Handling complaints

Any person who wishes to file a complaint regarding the protection of their personal information or
the application of this policy may contact DOCUGO’s person in charge of personal information
protection in writing.

The complaint must include, as far as possible:

• the name of the person concerned;
• their contact information;
• the subject of the complaint;
• a description of the facts or concerns;
• any document or information useful for analyzing the complaint.

DOCUGO will handle any complaint confidentially and within a reasonable time. If additional information
is required, the person in charge may contact the person concerned to complete the file.

It is also possible to file a complaint with the Commission d’accès à l’information du Québec:

www.cai.gouv.qc.ca
.

18. Person in charge of personal information protection

DOCUGO’s person in charge of personal information protection is:

Denis Lachance
President
DOCUGO / Azur Média inc.

For any request, question, comment, access request, correction request or complaint regarding this
policy or the protection of personal information, please contact us:

Email: info@docugo.ca
Phone: 1-844-760-3434

19. Changes to this policy

DOCUGO reserves the right to amend this policy at any time to reflect changes to its
practices, services, technologies or applicable legal requirements.

The most recent version of the policy is published on DOCUGO’s website. The date of the last update
is indicated at the top of this page.

20. Version table

Appendix A — Categories of personal information collected

The following table provides examples of personal information that DOCUGO may collect, depending on the nature
of the file or the relationship with the person concerned.

Note: The use of the masculine in this policy is solely intended to make the text lighter.