PRIVACY POLICY

Last Updated: June 22, 2026

Effective Date: June 22, 2026

1. INTRODUCTION

Watchly Inc. ("we," "our," or "us"), a company incorporated under the laws of Quebec, Canada, is committed to protecting your privacy and the privacy of your children. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our parental control platform for YouTube content ("Service").

This Privacy Policy complies with:

• Quebec's Act respecting the protection of personal information in the private sector (Law 25)
• The Personal Information Protection and Electronic Documents Act (PIPEDA)
• The Quebec Consumer Protection Act
• The Children's Online Privacy Protection Act (COPPA) for US users
• The California Consumer Privacy Act (CCPA) for California residents

OUR COMMITMENT: We NEVER share any data on children's watching habits with third parties for commercial purposes. Any data collected is purely for the functioning of the product and for product improvements. We take children's privacy seriously and comply with all applicable privacy laws.

2. PRIVACY OFFICER

In accordance with Quebec Law 25, we have designated a Privacy Officer responsible for ensuring compliance with privacy laws and handling privacy-related inquiries:

Privacy Officer
Watchly Inc.
Email: privacy@watchlyplayer.com
Alternative Contact: support@watchlyplayer.com

3. INFORMATION WE COLLECT

3.1 Information You Provide Directly

• Account Information: Email address, password (encrypted), and name when you create an account
• Child Profile Information: Names, birth years, and avatar preferences for child profiles (managed entirely by parents, no direct collection from children). When you create profiles through our quick setup flow, we collect your child's first name with your explicit consent to create their personalized viewing profile. This information is used solely for profile creation and can be deleted at any time from your parent dashboard.
• Payment Information: Processed securely through Stripe; we do not store credit card details on our servers
• Content Preferences: Videos and libraries you select for your children
• Communications: Information you provide when contacting support

3.2 Information Collected Automatically

• Watch History: Videos watched, duration, and progress (stored locally within your family account only, never shared externally)
• Usage Data: Features used, time spent, and interaction patterns (aggregated for product improvement)
• Technical Information: Browser type, operating system, IP address (for security and fraud prevention), device identifiers
• Log Data: Access times, pages viewed, and general geographic location (country/province level only)

3.3 Information We DO NOT Collect

• Personal information directly from children under 14 (Quebec) or 13 (US)
• Biometric data or facial recognition information
• Precise geolocation data
• Social media accounts or contacts
• Health or medical information
• Financial information beyond subscription billing

4. LEGAL BASIS AND PURPOSES FOR PROCESSING

We process your personal information based on the following legal grounds:

• Contract Performance: To provide the Service you've subscribed to
• Legal Obligations: To comply with applicable laws and regulations
• Legitimate Interests: For security, fraud prevention, and service improvement
• Consent: Where required by law, particularly for minors' data

We use collected information ONLY for the following purposes:

• Service Delivery: To provide, maintain, and improve the Service
• Account Management: To manage your account, subscription, and billing
• Content Curation: To save and display your selected videos and libraries
• Functionality: To track viewing progress and provide "continue watching" features
• Customer Support: To respond to your requests and provide assistance
• Security: To detect and prevent fraud, unauthorized access, and protect user safety
• Legal Compliance: To comply with legal obligations and respond to lawful requests
• Analytics: To understand usage patterns and improve our Service (aggregated data only)

5. CHILDREN'S PRIVACY

Age of Consent: In Quebec, parental consent is required for processing personal information of children under 14 years of age. For US users, we comply with COPPA requirements for children under 13.

Our Practices:

• We do not knowingly collect personal information directly from children
• Child profiles are created and managed entirely by parents or guardians
• Children cannot create accounts, make purchases, or provide personal information
• All data associated with child profiles is under complete parental control
• Parents can review, modify, or delete child profile data at any time
• We do not use children's data for behavioral advertising, profiling, or tracking
• Watch history is used solely for functionality within your family account

Parental Consent for Child Names: When creating child profiles during registration, we ask parents to provide explicit consent by checking a consent checkbox before submitting their children's names. This ensures compliance with COPPA and gives parents full control over what information is collected.

Parent Rights Regarding Children's Information: Parents can at any time: (1) Review their children's profile information, (2) Delete children's profiles and associated names, (3) Refuse to allow further collection of their children's information, and (4) Request deletion of all data associated with their children's profiles. These rights can be exercised directly from the parent dashboard or by contacting privacy@watchlyplayer.com.

If we discover that we have inadvertently collected personal information from a child without parental consent, we will delete that information immediately. Please contact privacy@watchlyplayer.com if you believe we have collected information from a child without proper consent.

6. DATA SHARING AND DISCLOSURE

WE NEVER SELL OR RENT YOUR PERSONAL INFORMATION OR CHILDREN'S DATA.

We may share information only in the following limited circumstances:

• Service Providers: With trusted third parties who assist in operating our Service:
  • Stripe (payment processing - adult account information only)
  • Email service providers (transactional emails only)
  • Hosting and infrastructure providers (data encrypted)
• Legal Requirements: When required by law, court order, or governmental request, including Quebec's Commission d'accès à l'information
• Protection of Rights: To protect the rights, privacy, safety, or property of Watchly, our users, or others
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with advance notice to users)
• With Consent: With your explicit consent for specific purposes

We explicitly DO NOT share data with:

• Advertising networks or data brokers
• Social media platforms
• Marketing companies
• YouTube or content creators
• Any third parties for commercial purposes

7. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than Canada, including the United States, where our service providers operate. When we transfer information internationally, we ensure appropriate safeguards are in place:

• Contractual clauses with service providers ensuring data protection
• Encryption of data in transit and at rest
• Limited access on a need-to-know basis
• Compliance with PIPEDA requirements for international transfers

By using our Service, you consent to the transfer of your information to countries outside of Canada, understanding that data protection laws may differ from those in your jurisdiction.

8. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your information in accordance with industry standards and Quebec Law 25:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)
• Secure password storage using bcrypt hashing algorithm
• Regular security audits and vulnerability assessments
• Access controls with multi-factor authentication for administrative access
• Employee training on data protection and privacy
• Incident response procedures and breach notification protocols
• Regular backups with encrypted storage
• Firewall protection and intrusion detection systems

While we strive to protect your information, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security but will notify you of any breaches as required by law.

9. DATA BREACH NOTIFICATION

In accordance with Quebec Law 25, if a confidentiality incident occurs that presents a risk of serious injury to you, we will:

• Notify you promptly of the incident
• Provide information about the nature of the incident
• Describe the personal information involved
• Explain the measures taken to reduce the risk of injury
• Provide steps you can take to reduce the risk of injury
• Notify the Commission d'accès à l'information du Québec as required

10. DATA RETENTION

We retain your information only as long as necessary to provide the Service and fulfill the purposes outlined in this Privacy Policy:

• Account Information: Until account deletion plus 30 days for recovery purposes
• Child Profiles: Until deleted by parent or account termination
• Watch History: 12 months rolling window or until manually cleared by parent
• Payment Records: 7 years as required for tax and legal compliance
• Support Communications: 2 years from last interaction
• Security Logs: 90 days for security monitoring
• Aggregated Analytics: Indefinitely (non-identifiable)

After the retention period, data is securely deleted or anonymized. You can request early deletion of your data at any time, subject to legal retention requirements.

11. YOUR PRIVACY RIGHTS

Under Quebec Law 25 and PIPEDA, you have the following rights regarding your personal information:

• Right to Access: Request a copy of the personal information we hold about you
• Right to Correction: Update or correct inaccurate information
• Right to Deletion: Request deletion of your personal information
• Right to Portability: Receive your data in a structured, machine-readable format
• Right to Restriction: Limit how we process your information
• Right to Object: Object to certain processing of your information
• Right to Withdraw Consent: Where processing is based on consent
• Right to De-indexing: Request removal from search engine results
• Right to Know About Automated Decision-Making: Information about any automated processing

How to Exercise Your Rights:

• Email: privacy@watchlyplayer.com
• Response Time: Within 30 days of your request
• Verification: We may request information to verify your identity
• No Fee: Unless requests are manifestly unfounded or excessive

Complaints: If you are unsatisfied with our response, you may file a complaint with:

Commission d'accès à l'information du Québec
Phone: 1-888-528-7741
Website: www.cai.gouv.qc.ca

12. COOKIES AND TRACKING TECHNOLOGIES

We use only essential cookies and similar technologies necessary for the Service to function:

• Session Cookies: To maintain your login session
• Preference Cookies: To remember your settings and preferences
• Security Cookies: To prevent fraudulent activity
• Performance Cookies: To monitor service performance (aggregated only)

We do NOT use:

• Third-party tracking cookies
• Advertising or marketing cookies
• Social media tracking pixels
• Cross-site tracking technologies

You can control cookies through your browser settings. Disabling essential cookies may affect Service functionality.

13. THIRD-PARTY SERVICES

Our Service integrates with the following third-party services:

• YouTube API: To access and display video content (subject to YouTube's Terms of Service)
• Stripe: For secure payment processing (PCI compliant, no card data stored by us)
• Email Services: For transactional emails only (account notifications)

These services have their own privacy policies and data practices. We encourage you to review them. We carefully select service providers who demonstrate strong privacy and security practices.

14. AUTOMATED DECISION-MAKING

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Any content recommendations or features are based solely on your explicit selections and preferences, not algorithmic profiling.

15. PRIVACY IMPACT ASSESSMENTS

In compliance with Quebec Law 25, we conduct privacy impact assessments when:

• Implementing new technologies that process personal information
• Making significant changes to how we handle personal information
• Developing new features that involve personal information

These assessments help us identify and mitigate privacy risks before implementing changes.

16. CALIFORNIA PRIVACY RIGHTS (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information held by us
• Right to opt-out of sale of personal information (we do NOT sell personal information)
• Right to non-discrimination for exercising privacy rights

To exercise these rights, contact privacy@watchlyplayer.com. We will verify your request and respond within the timeframes required by law.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes:

• We will update the "Last Updated" date at the top
• We will notify you by email at least 30 days before the changes take effect
• We will post a prominent notice in the Service
• For changes affecting children's data, we will obtain parental consent if required

Your continued use of the Service after the effective date constitutes acceptance of the updated Privacy Policy. If you disagree with changes, you should discontinue use of the Service.

18. CONTACT INFORMATION

For questions, concerns, or requests regarding this Privacy Policy or our privacy practices:

Privacy Officer
Watchly Inc.
Montreal, Quebec, Canada
Email: privacy@watchlyplayer.com
Alternative: support@watchlyplayer.com
Website: https://staging.app.watchlyplayer.com

For COPPA-Related Inquiries (Parents of US Children):
Parents can contact us to:

• Review information collected about their children
• Request deletion of their children's information
• Refuse further collection or use of their children's information

For Privacy Complaints:
Commission d'accès à l'information du Québec
Phone: 1-888-528-7741
Website: www.cai.gouv.qc.ca

By using Watchly, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your information as described herein. This Privacy Policy is available in English. You confirm that you have requested and agree to receive this Privacy Policy in English.