Privacy and Data Governance Policy

1. Introduction

This Privacy and Data Governance Policy (the "Policy") sets out the principles and guidelines that Cookmoi Group Inc. (hereinafter referred to as 'Cookmoi') follows to protect the personal information of our users, customers, influencers, partners, and employees. This Policy complies with the requirements of Quebec's Act respecting the protection of personal information in the private sector (Bill 25).

2. Scope

This Policy applies to all employees, consultants, contractors, and other stakeholders who process personal information in the course of their activities on behalf of Cookmoi, as well as to all users of our services.

Cookmoi is offered in Canada and the United States only. Anyone can read the recipes and videos that are public, without an account, and members can sign in from anywhere; a new account can be opened only from Canada or the United States (see section 9), and a purchase on our website needs a card issued in one of these two countries.

3. Roles and Responsibilities

Management: Provides overall supervision of personal data management, approves data protection policies and practices, and supports the implementation of compliance measures.

Data Protection Officer (DPO): Oversees the development and implementation of data protection practices, ensures compliance with applicable laws, and acts as a point of contact for regulatory authorities and users with privacy concerns.

Staff: Adhere to established policies and procedures for managing personal information, participate in mandatory training, and report any data breaches to the DPO.

4. Collection and Use of Personal Information

Cookmoi collects essential personal data such as name, email address, and culinary preferences to personalize your experience and provide you with the best recipes. Personal information shall be collected fairly and lawfully, with the express consent of the user concerned, except where otherwise permitted by law.

The information collected is used to:

• Provide and improve our services
• Personalize content and recommendations
• Communicate with you regarding news or services related to our recipes
• Process transactions and fulfill requests
• Maintain the security and functionality of our platform

Personal information will only be used for the specific purposes for which it was collected or for compatible purposes that you have consented to.

Notifications on your phone. If you use the Cookmoi app on iPhone or Android and agree when the app asks, we keep a notification identifier for your phone (a token issued by Google Firebase Cloud Messaging), linked to your account, together with the type of phone (iPhone or Android) and the app version. We use it only to tell you about new messages in your Cookmoi conversations: the notification shows the sender’s name and the beginning of the message, or a short line such as “Photo”. We also keep a record of which notifications were sent to which phone, without the message text, for 30 days. You can turn notifications off at any time in your phone’s settings; when you sign out of the app, when your phone no longer accepts notifications, or when the app has not been opened on that phone for 270 days, we deactivate that identifier, and we delete it 30 days later. We never use it for advertising.

Online status. On Cookmoi, you can choose to show your friends when you are online: a green dot then appears on your profile picture. This setting stays off until you turn it on yourself: Cookmoi offers it to you once, and you can change it at any time in your account (“Online status”). While it is on, we keep a single piece of information: the time of your last activity on Cookmoi, which is simply replaced as you browse; we never keep a history of it. Only your accepted friends who have also turned the setting on can see the dot, and only if you have used Cookmoi in the last 3 minutes; we never show them when or for how long you were online. When you turn the setting off, we erase that time right away, and you no longer see your friends’ dots either. We never use it for advertising.

Data from your watch. In Camp de base, you can add an activity to one of your events, either by sending a file exported from your watch (GPX, TCX or FIT) or, in the Cookmoi app, by choosing one workout in Apple Health or Health Connect after you allow it. From that activity we keep only the distance, the duration, the calories burned, your average and maximum heart rate, the elevation gain, the start time and a simplified route (at most 2,000 points). The file itself is not kept. The app reads only the workout you choose, never in the background, and writes nothing to Apple Health or Health Connect. This information is visible only to you; we do not share it with anyone, we never sell it and we never use it for advertising. You can remove it at any time from the event’s page; it is also deleted when you delete the event’s discipline or your account.

Importing your Facebook videos. If you choose “Import from my Facebook videos” and allow it on Facebook, Cookmoi reads the list of the videos you uploaded to your own Facebook account (title, description, date, length and thumbnail) so it can show them to you. We copy only the video you choose, with a picture taken from it, into the cookbook you pick; it is private unless you choose to make it public. We never read other people’s videos and we never post anything on Facebook. Access to your Facebook account is kept, encrypted, in your session for at most one hour and is never stored in our database; “Disconnect Facebook” ends it at once. When you delete an imported video in Cookmoi, we erase our copy of the video and of its picture from our servers and our storage; the backup copies our storage keeps are erased automatically within 30 days, and copies kept temporarily by our content delivery network expire within 24 hours. A recipe you made from that video stays in your account until you delete it.

Converting a video into a recipe. When you use “Convert to Recipe” on one of your videos, the video (images and sound) and its title and description are sent to Google (Gemini API) to write the recipe’s ingredients and steps, which you can then edit. The copy sent to Google is deleted right after it is read (if that deletion fails, Google removes it within 48 hours). We never use your videos for advertising and we never sell them.

5. Consent and Prior Information

Cookmoi seeks your explicit consent when collecting personal data. We inform you of:

• The types of information we collect
• How we use your information
• Your rights to access, modify, and delete your data
• The security measures in place to protect your information

In the event of transmission to third parties, we undertake to maintain confidentiality in compliance with current legislation.

6. Sharing with Third Parties

Your personal data is only shared with third parties when necessary, for example:

• To process payments
• When required by law
• With service providers who help us operate our platform
• With partners to offer you the best possible services and improve your user experience

This sharing is always done with your prior consent or in accordance with our legal obligations.

To deliver notifications to your phone, the notification identifier, the sender’s name and the beginning of the message pass through Google (Firebase Cloud Messaging) and, on iPhone, Apple (Apple Push Notification service); this information may be processed outside Canada.

When you import a video from Facebook, Meta Platforms provides the list of your videos and the video you choose. When you use “Convert to Recipe”, the video and its text are sent to Google (Gemini API) to read the recipe. Videos and pictures are stored with Amazon Web Services in Canada (Montréal) and delivered through Amazon CloudFront, which keeps temporary copies in locations around the world; this information may be processed outside Canada.

Additionally, if you share a recipe, or if a recipe is copied by a friend, these shared or copied recipes cannot be deleted from the recipient's account. This ensures that all parties retain access to the recipes exchanged, reinforcing the community and user-friendliness of our platform.

7. Retention and Destruction of Personal Information

Retention: Personal information shall be retained only as long as necessary for the fulfillment of the purposes for which it was collected. This period shall be documented in Cookmoi's retention records.

Server logs: Our servers keep technical log files to run and protect Cookmoi, for example the address a visit came from, error messages and sign-in attempts. They are deleted automatically: most after 30 days, the others (payment notifications, our hosting control panel's own logs and the system's security logs) after at most 90 days.

Destruction: Personal information that is no longer required must be destroyed in a secure manner that prevents further retrieval or use. Destruction methods must be approved by the DPO and may include shredding, magnetic erasure, or incineration.

8. User Access and Control

You can access, modify, or request the deletion of your data at any time via your user account or by contacting us through the Cookmoi.com website. We will respond to such requests within a reasonable timeframe as required by applicable law.

Your Facebook videos. You can delete a video you imported from Facebook at any time with the delete button on the video in Cookmoi; our copy is then erased (see section 4). You can end Cookmoi’s access to your Facebook account at any time with “Disconnect Facebook” or, on Facebook, in Settings & privacy > Settings > Apps and websites, by removing Cookmoi. To ask us to delete any other information that came from your Facebook account, write to DPO@Cookmoi.com.

9. Security

We take rigorous measures to protect your data from unauthorized access, including computer security protocols and ongoing training for our staff. These measures are regularly reviewed and updated to maintain the highest standards of data protection.

Protection against automated sign-ups. To protect our sign-up form from bots and abuse, we use Cloudflare Turnstile, a service provided by Cloudflare, Inc. When you open the sign-up page, Turnstile processes technical information about your connection and browser (your IP address, technical characteristics of your browser and its user agent) only to check that a real person is signing up. According to Cloudflare, this information is not used to identify, profile or target you, and it may be processed outside Canada. We also keep a scrambled (hashed) form of your IP address for up to 48 hours to limit the number of accounts that can be created from the same connection; it is not linked to your account and is then deleted automatically.

Country at sign-up. When a new account is opened, we check that the connection comes from Canada or the United States: we look up the country of the connection’s IP address in a country table kept on our own server. For this check, the address does not leave our server and is not kept. We keep only the result of this check with the account, never the address, because some of the account’s free allowances depend on it. This country table comes from DB-IP’s free “IP to Country Lite” database (IP Geolocation by DB-IP), used under the Creative Commons Attribution 4.0 International License (CC BY 4.0).

10. Cookies, Tracking and Statistics

Cookmoi uses tools such as Google Analytics to understand how you use our site and to improve your user experience. These tools collect anonymous data such as the number of visitors, the pages visited, the technology used, the referring sites, and the geographical origin of users.

Please be aware that this data may be stored and processed outside Canada. Cookmoi ensures that appropriate privacy standards are applied regardless of where data is processed.

11. Sharing and Public Use of Information

By sharing links, recipes, or other information on Cookmoi.com, you understand that this information enters the public domain and may be used by other users. Cookmoi is not responsible for the content or accuracy of information shared by users. It is your responsibility to ensure that any content shared is consistent with your expectations and does not cause you any harm.

Cookmoi is not responsible for defamatory, inaccurate, or misleading statements published by its users. Although we strive to maintain a respectful environment, we cannot control or verify all published content. Users who believe content is defamatory or inappropriate may report it through our reporting system, and we will take appropriate action in accordance with our internal policies.

12. Complaints Process

Receipt of complaints: Individuals may submit complaints about the handling of their personal information in writing to the DPO.

Investigation: The DPO will investigate each complaint and take appropriate action to resolve the situation. The individual will be informed of the results of the investigation within a reasonable period of time.

External recourse: If the user is not satisfied with the resolution, he or she has the right to file a complaint with the Commission d'accès à l'information du Québec.

13. Training and Awareness

All staff members will receive training on privacy practices and their specific role in protecting this information. Training will be repeated annually and whenever significant changes are made to the policy.

14. Policy Review and Changes

This policy will be reviewed at least every two years or following significant changes in applicable laws or in Cookmoi's operations. Any changes to this policy will be:

• Approved by management
• Communicated to all relevant personnel
• Posted on our website
• Communicated to users via email for significant changes

15. Approval

This Policy is approved by Management and comes into effect immediately. All staff members are required to comply with all the provisions of this Policy under penalty of disciplinary action, up to and including dismissal.

16. Contact

If you have any questions about our Privacy Policy, please contact us by visiting Cookmoi.com or by email at DPO@Cookmoi.com. We are committed to responding quickly and efficiently to all your concerns.

Updated November 5, 2026

Terms of Use

1. Introduction

Welcome to Cookmoi Group Inc. (hereinafter referred to as 'Cookmoi'). By accessing our website or our mobile application and using our services, you agree to be bound by the following terms and conditions, which govern our relationship with you as a user. These Terms of Use and our Privacy and Data Governance Policy together form the entire agreement between you and Cookmoi regarding your use of our services.

2. Use of the Services

Cookmoi is offered in Canada and the United States only. Anyone can read the recipes and videos that are public, without an account, and members can sign in from anywhere; a new account can be opened only from Canada or the United States, and a purchase on our website needs a card issued in one of these two countries.

Our services are for personal use only, unless we give prior written permission for a different use. It is strictly forbidden to reproduce, sell or exploit our content without our written consent. If you use the platform for any purpose other than creating food or drink recipes, we reserve the right to suspend or terminate your account without notice.

We reserve the right to suspend or terminate your access if you fail to comply with these terms. In addition, any inappropriate content will result in the immediate suspension or closure of the account concerned. Our ethical and community standards prohibit content that: is hateful, discriminatory, or harassing; promotes illegal activities; infringes on intellectual property rights; contains explicit violence; is sexually explicit or suggestive; includes false or misleading information; or violates the privacy of others. This list is not exhaustive, and Cookmoi maintains sole discretion in determining violations of our standards. Please be sure to abide by these rules to ensure a continued positive experience on our site.

By uploading video content to your account, you certify that you are the legitimate owner of this content and hold all necessary copyrights. It is strictly prohibited to publish videos for which you do not own the rights or have not obtained the required permissions. Any copyright violation may result in the immediate removal of the concerned content and may lead to the suspension or closure of your account.

2.1. User-Generated Content

Cookmoi acts solely as a hosting platform for user-generated content. We neither endorse nor verify this content, and disclaim any responsibility regarding its accuracy, legality, or quality. Users are solely responsible for the content they publish, share, or transmit through our platform.

By sharing links, recipes, or other information on Cookmoi.com, you understand that this information enters the public domain and may be used by other users. It is your responsibility to ensure that any content shared is consistent with your expectations and does not cause you any harm.

Cookmoi is not responsible for defamatory, inaccurate, or misleading statements published by its users. Although we strive to maintain a respectful environment, we cannot control or verify all published content. Users who believe content is defamatory or inappropriate may report it through our reporting system, and we will take appropriate action in accordance with our internal policies.

Cookmoi reserves the right, without being obligated, to monitor, modify, or remove any content deemed inappropriate, offensive, or contrary to our terms of use.

3. Intellectual Property

The content of Cookmoi, including text, graphics, images, videos and interfaces, is protected by copyright. You may download and print content for personal use only. No ownership rights are transferred to you.

4. Liability

We make every effort to ensure the quality and availability of our services, but we cannot guarantee that they will be free from interruptions or errors. We are not liable for any damages arising from the use of our site or reliance on its content. We are not responsible for partial or complete loss of data.

Cookmoi is not responsible for allergic reactions, intolerances, food poisoning, foodborne illnesses, or any other health issues that may arise from using our recipes. Users are entirely responsible for:

• Verifying ingredients and their compatibility with their specific medical conditions
• Ensuring proper food safety practices, including appropriate cooking temperatures, safe food handling, and proper storage
• Using fresh, quality ingredients from reliable sources
• Following safe preparation methods, particularly when handling raw or undercooked ingredients such as eggs, meat, poultry, and seafood
• Understanding the risks associated with consuming raw or partially cooked foods

We strongly recommend that individuals with allergies, dietary restrictions, or health concerns consult a healthcare professional before using our recipes.

Recipes and instructions provided on Cookmoi are for informational purposes only. We do not guarantee the results obtained by following these instructions. The user assumes full responsibility for how they use this information. Preparation times, quantities, measurements, and cooking instructions may vary depending on the equipment used and other individual factors.

To the maximum extent permitted by applicable law, Cookmoi shall not be liable for any direct, indirect, incidental, special, or consequential damages resulting from the use or inability to use our services. This limitation applies regardless of the cause of the damages and even if Cookmoi has been advised of the possibility of such damages. By using our services, you expressly agree that the risk of such use rests entirely with you.

5. Personal Data and Privacy

Your personal data is collected and processed in accordance with our Privacy and Data Governance Policy. This policy explains:

• What personal information we collect
• How we use and protect this information
• When and how we share it with third parties
• Your rights regarding your personal information
• How to exercise these rights

We encourage you to read our Privacy and Data Governance Policy carefully, as it forms an integral part of these Terms of Use.

6. Modifications to the Terms

We may modify these Terms of Use at any time. Any changes will be communicated to you via our website or by email. Your continued use of the site after such changes constitutes your acceptance of the new terms.

7. Property Rights

Unless specifically agreed otherwise between Cookmoi and a user, customer, influencer, partner or employee, all recipes and content are the property of Cookmoi and may not be used for commercial purposes without our written consent.

8. Dispute Resolution

8.1 Privacy-Related Complaints

For complaints specifically related to the handling of your personal information, please follow the complaint process outlined in our Privacy and Data Governance Policy. This includes:

• Submitting complaints in writing to our Data Protection Officer (DPO)
• An investigation and resolution process conducted by the DPO
• The right to seek external recourse through the Commission d'accès à l'information du Québec if you are not satisfied with our resolution

8.2 General Disputes

For all other disputes relating to the use of our services, the parties agree to attempt an amicable resolution before any legal action. Any unresolved dispute will be subject to the exclusive jurisdiction of the courts of the Province of Quebec, Canada, according to the laws in force in that province. This provision applies to the fullest extent permitted by the applicable law in the user's place of residence.

9. Contact

If you have any questions about our Terms of Use, please contact us at DPO@Cookmoi.com. For privacy-related inquiries, you may also visit Cookmoi.com as detailed in our Privacy and Data Governance Policy. We commit to respond quickly and efficiently to all your concerns.

These Terms of Use provide a framework for the use of our site and services and protect both your rights as a user and our rights as a service provider. We encourage you to read them carefully.

Updated November 3, 2026