Privacy Policy

Last Updated: 21 July 2025

This privacy policy (“Privacy Policy”) describes how 9371-8971 Québec inc., doing business as Stable (“our”, “us” or “we”), collects, uses, shares, and stores personal information of clients and users of its website, web application, products and services (collectively, the “Services”) on or in which this Privacy Policy is posted, linked, or referenced.

We are committed to protecting your privacy rights and recognize the importance of protecting the information that we collect about you. We have prepared this Privacy Policy to describe our practices regarding the personal information we collect.

By using the Services, you accept the terms of this Privacy Policy and our Termes and Conditions, and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms and Conditions. The Terms and Conditions contain provisions that limit our liability to you. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS AND CONDITIONS, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email or other electronic message or offline. We encourage you to carefully review the privacy policies of any third-party website you access.

What we Collect

Information You Give Us. Information we collect from you may include:

• Contact information, such as your name, email address, billing address, phone number or social media;
• Profile information, such as your password, preferences, feedback and survey responses;
• Transaction information, such as certain billing information, payment dates, billing cycle dates, products or services purchased, which authorized payment provider you use, or other consuming histories or tendencies. We do not collect any payment data when you are using an authorized payment service provider (except in circumstances where the payment is made directly to us and not processed through another authorized payment service provider);
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them; and
• Other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-Party Sources. We may obtain personal information about you from third-party sources, including, without limitation, Amazon Web Services (“AWS”), where you have authorized such access or where such access is necessary for the provision of the Services. We may add this to the data we have already collected from or about you through the Services. Stable does not collect or store your end data, including personal information about your clients or any data stored in your AWS environment, despite having access to your environment as authorized by you for the purpose of providing the Services.

Automatic Data Collection. We may automatically record certain information about how you use the Services (we refer to this information as “Log Data”). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features available through the Services to which a user browsed and the time spent on those pages or features, the frequency with which the Services are used by a user, search terms, the links made available through the Services that a user clicked on or used, the time zone setting and location, and other statistics. We use this information to improve and enhance the Services by expanding its features and functionality and tailoring it to our users’ needs and preferences.

If you have consented to their uses (to the extent required under applicable laws), we may use cookies, local storage or similar technologies to analyze trends, administer the pages made available through the Services, track users’ movements around the pages made available through the Services, and to gather demographic information about our user base as a whole. Users can control the use of cookies and local storage at the individual browser level.

Information We Will Never Collect. We do not collect any other personal information outside of what is outlined in this Privacy Policy, unless you give it to us directly, such as filing out a form, giving feedback, communicating via third-party social media websites or any other means.

Use of Personal Information

We use the collected personal information for various purposes or as otherwise described at the time of collection:

Service Delivery. We use your personal information to:

• provide, operate and improve the Services and our business;
• register you as a user of Services;
• enter into and perform contracts under which we provide services to you;
• communicate with you about the Services, including by sending announcements, updates, security alerts, and support and administrative messages; and
• provide support for the Services, and respond to your requests, questions and feedback.

Research and Development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you.

Compliance and Protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the Terms and Conditions that govern the Services; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent. We may use, share or collect your personal information with your consent, such as when required by law.

Disclosure of Your Data

We may share your data with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates (i.e., our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy and our Terms and Conditions.

Authorities and Others. We may disclose your personal information for law enforcement purposes, with government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the “Compliance and Protection” purposes described above.

Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, reorganization, divestiture, or in the event of bankruptcy or dissolution.

Professional Advisors and Service Providers. We may share personal information with those who need it to work for us. These recipients may include our employees as well as third-party companies and individuals to administer and provide the Services on our behalf, as well as lawyers, bankers, auditors, and insurers.

We will never rent or sell your personal information or use this information to send you spam. We are based in Québec, Canada. The personal information we collect is stored and processed in Canada, or where we or our partners, affiliates and third-party providers maintain facilities. As some of our service providers are located outside of Canada, your personal information may be transferred to, accessed from, or processed in jurisdictions outside of your own. In such cases, your information may be subject to the laws of those jurisdictions, which may grant access rights to competent authorities to access your personal information. We require, through contractual commitments, that the security measures employed by these third parties comply with applicable legislation and are aligned with our way of collecting, using and disclosing your personal information. By providing us with your personal information, you consent to the disclosure to these third parties, in jurisdictions where privacy laws may not be as protective as those in your jurisdiction. EU users should read the important information provided below about the transfer of personal information outside of the European Economic Area.

Data Retention

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this Privacy Policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the Internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

Your Rights

Depending on applicable laws, you may have the following rights with respect to your personal information:

• the right to ask us for an overview of your personal information that we process;
• the right to ask us to transfer your personal information directly to you or to another entity, including in a structured, commonly used and machine-readable format. This may apply to personal information that we process by automated means and with your consent or on the basis of a contract with you. We will transfer your personal information where it is technically feasible;
• the right to have your personal information deleted if we no longer need it for its original purpose, if you object to us processing your personal information for our own legitimate interests or for personalized commercial messages, if you withdraw your consent for processing your personal information, if we unlawfully process your personal information, or if a law requires us to erase your personal information;
• the right to object to us using your personal information for our own legitimate interests. We will consider your objection and whether processing your personal information has any undue impact on you that requires us to stop doing so. You cannot object to us processing your personal information if we are legally required to do so (for example if we are obliged to fulfill a contract with you);
• if your personal information is incorrect, you have the right to ask us to rectify it. If we shared such data about you with a third party in compliance with this Privacy Policy, it is our obligation to notify this change to the third party;
• the right to ask us to restrict using your personal information if in your opinion the information is inaccurate, if we are processing the data unlawfully, or if you have objected to us processing your personal information for our own legitimate interests; and
• should you not be satisfied with the way we have responded to your concerns, you have the right to submit a complaint to us using the contact information in the “Contact us” section below in this Privacy Policy. If you are still unhappy with our reaction to your complaint, you can also contact the data protection authority in your country.

Please note that deletion of your personal information may make it impossible for you to use the Services.

Third Party Payment Service Provider

The Services include functionality that enables you to make payments using any authorized payment method, including, without limitation, payments made via the AWS Marketplace. When you use such a payment method to remit funds to us, your personal information is collected directly by the third-party provider of that payment method, and not by us. The collection, use, and disclosure of your personal information by such provider are governed by its own privacy policy, not this Privacy Policy. We do not control and are not responsible for the privacy practices of any third-party payment service provider.

Limitation of Liability

We, and/or our respective officers, directors, shareholders, owners, officials, partners, partnership, principals, employees, affiliates and other related entities, servants, agents, representatives, successors and assigns, will not be held liable for any losses or damages (pecuniary or otherwise) resulting from the misuse of any information collected through the Services not in violation of this Privacy Policy or any applicable laws.

Compliance with Canada Privacy Laws

This Privacy Policy and our practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) and Québec’s An Act Respecting the Protection of Personal Information in the Private Sector (R.S.Q. c. P-39.1) and any amendments thereof.

Changes to this Privacy Policy

We may change this Privacy Policy at any time. We encourage you to periodically review this page for the latest information about our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact us

If you have any question or comment about this Privacy Policy, please do not hesitate to contact us at support@stableapp.cloud.

Notice to California Residents

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).

For more details about the personal information we collect from you, please see the “What we Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Disclosure of Your Data” section above. We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@stableapp.cloud. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requesters’ valid government issued identification, and the authorized agent’s valid government issued identification.

Notice to European Users

The information provided in this notice applies only to individuals in the European Economic Area, Switzerland, and United Kingdom (collectively, “EU”) and “personal information” as used in this Privacy Policy is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

Sensitive Data. Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.

Legal Basis for Processing. We only use your personal information as permitted by law. We are required to inform you of the legal basis of our processing of your personal information, which are described in the table below. If you have any questions about the legal basis under which we process your personal information, contact us at support@stableapp.cloud.

Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for a related purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

Your Rights. Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you service-related and other non-marketing communications;
• Access. Provide you with information about our processing of your personal information and give you access to your personal information;
• Correct. Update or correct inaccuracies in your personal information;
• Delete your personal information;
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice;
• Restrict. Restrict the processing of your personal information; and
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to support@stableapp.cloud. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at support@stableapp.cloud or submit a complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfer. We process personal data in Canada and the United States and data protection laws may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to Canada and the United States as set forth in this Privacy Policy by using our Services.

Whenever we transfer your personal information out of the EU to Canada and the United States or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EU.