Privacy Policy — Pratiqo

Version: 2.0 · Last updated: May 2026

⚠️ Important: This document is a preliminary template that should be reviewed by a Quebec privacy lawyer before launch. It supplements the other applicable legal documents and does not constitute legal advice. If a mandatory law conflicts with anything below — in particular Quebec's Act Respecting the Protection of Personal Information in the Private Sector (CQLR, c. P-39.1, "Law 25") and the federal Personal Information Protection and Electronic Documents Act (PIPEDA) — the law prevails.

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1. Purpose and scope

This Privacy Policy (the "Policy") describes how Cours Pratiqo Inc. ("Pratiqo," "we," "our"), operating the Pratiqo platform, collects, uses, discloses, retains, protects, and destroys personal information.

It applies to:

• students, teachers, parents and legal guardians, visitors, and other Pratiqo users;
• the marketplace activities (teacher profiles, search, matching, bookings, online or in-person lessons, messaging, payments, payouts, reviews, support, and security);
• the self-paced learning product YoPratiqo when users access it.

The Policy supplements the other legal documents listed in section 22 and does not waive any mandatory rights of a consumer, an independent worker, or a parent.

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2. Person responsible for the protection of personal information

In accordance with section 3.1 of Law 25, Cours Pratiqo Inc. designates the following person as the person responsible for the protection of personal information (privacy officer):

Marc-André Théberge Cours Pratiqo Inc. marc-andre.theberge@pratiqo.ca

You may contact this person to, as applicable and subject to applicable law:

• ask a privacy-related question;
• request access to your personal information;
• request correction of inaccurate, incomplete, or ambiguous information;
• withdraw consent where permitted;
• file a complaint or request an internal review.

For general inquiries you may also write to info@pratiqo.ca. For support: support@pratiqo.ca.

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3. Categories of personal information collected

Depending on how you interact with Pratiqo, we may collect, directly from you or automatically, the following categories:

• Account: name, email, phone number, authentication identifiers, locale, time zone.
• Profile: for teachers, biography, disciplines, specialties, languages, photo, experience, and any titles, certificates, or credentials voluntarily provided.
• Student / lesson: learning goals, level, selected subjects, lesson preferences, booking details.
• Parent or legal guardian: name, contact information, and relationship context, where the user is a minor or where the parent books for the minor.
• Location: city, approximate area, service zone, address used for in-person lessons, and saved private location, where applicable.
• Communications: messages exchanged on the platform, support requests, reviews and ratings, reports, and related attachments.
• Payments and transactions: amounts, booking references, payment status, receipts, payout information, and limited payment metadata (such as the last four digits and the card brand). Pratiqo does not store full card numbers, which are processed by the payment provider.
• Identity and verification (where applicable): status of a verification, metadata, and the result returned by an external provider. Pratiqo does not claim to universally verify the identity or credentials of every user.
• Technical information: IP address, device identifier and type, browser data, logs, cookies, analytics events, and security events.
• YoPratiqo / self-paced learning (where applicable): module progress, quiz activity, completion, learning preferences.
• Preferences and consents: communication preferences, cookie choices when a mechanism is provided, and consent records where required by law.

We do not actively seek sensitive information (e.g., health, origin, political opinions) and ask that you not post any in public fields or messages.

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4. Purposes of collection and use

Subject to applicable law, we use your personal information to:

• create and manage your account and enable authentication;
• connect students and teachers and display profiles and search results;
• manage bookings, lessons, cancellations, refunds, payments, payouts, receipts, support, and adjustments;
• enable communication between users (students, teachers, parents/guardians, support);
• personalize the experience, language and locale, matching, recommendations, and the YoPratiqo learning experience;
• support safety, eligibility, fraud and abuse prevention, and platform integrity;
• handle disputes, reports, chargebacks, legal obligations, and policy enforcement;
• improve the product, analytics, debugging, security, and reliability;
• send transactional messages and, with the consent required where applicable, marketing communications;
• comply with our legal, tax, accounting, regulatory, and contractual obligations.

Personal information is not used for purposes incompatible with those described above, except with consent or as authorized by law.

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5. Consent and legal basis

We collect, use, or disclose your personal information with your consent where required, or as otherwise permitted by applicable law.

• Consent may be express or implied depending on the context and the nature of the information.
• For sensitive information, we seek express consent where the law requires it.
• You may withdraw consent to the extent permitted by law. Withdrawal may limit or make impossible certain features (e.g., delivery of an already-paid lesson, in-progress accounting or tax obligations).
• Other bases may apply, including performance of a contract, compliance with a legal obligation, fraud prevention, security, legitimate interest, or another basis recognized by applicable law.

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6. Information about minors

Pratiqo may be used for lessons involving minors as students.

• Depending on age, context, and applicable law, the involvement of a parent or legal guardian may be required for account creation, booking, payment, or communication.
• We do not encourage concealed communications between adults and minors on the platform; see the Code of Conduct.
• A parent or legal guardian may contact the privacy officer with any question, access request, correction request, or deletion request concerning a minor, to the extent permitted by law.

We avoid stating specific age thresholds in this Policy except where they are explicitly framed elsewhere on the platform. Any applicable threshold, where relevant, is communicated through the appropriate configuration tools.

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7. Cookies, analytics, and similar technologies

This section is intended to clearly explain our practices and may be adjusted after legal review.

Pratiqo uses cookies, local storage, and similar technologies to operate and secure the platform. Depending on the case, we may use:

• essential cookies (authentication, session, security, load balancing);
• preference and localization cookies (language, time zone, displayed currency);
• optional analytics and performance cookies, with your consent;
• security and fraud-prevention cookies;
• no behavioral marketing cookies at launch.

7.1 Necessary (always on)

These items support sign-in, security, language, and core functionality. They cannot be turned off in the preferences panel without breaking normal use of Pratiqo.

7.2 Optional analytics — PostHog

With your explicit consent, we may send aggregate events to PostHog (configured host, e.g. us.i.posthog.com) to understand general usage (page views, aggregated search flows). We do not use PostHog for:

• session replay;
• behavioral advertising;
• profiling of minors or students;
• collecting emails, names, addresses, message content, or payment data.

You can refuse this category via “Necessary only” or the “Manage choices” panel (footer link).

7.3 Technical diagnostics — Sentry (errors only)

As a technical reliability measure, we may send technical error reports to Sentry. At launch:

• no session replay;
• no video recording;
• no email or name sent by default;
• messages and metadata are filtered to remove secrets, tokens, addresses, and other sensitive data where possible.

7.4 Change your choices

Use the “Privacy preferences” footer link to reopen your preferences. You can also configure your browser to block or delete certain cookies; this may limit some features.

Questions: support@pratiqo.ca.

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8. Third-party service providers

We use service providers that may, depending on the case, act on our behalf or under their own terms. Typical categories:

• Payment processors (e.g., Stripe) for payment collection, payouts, and related functions.
• Hosting, database, and storage.
• Authentication (e.g., third-party sign-in where offered).
• Email and notifications (transactional and operational).
• Analytics, monitoring, and error logging.
• Maps, address autocomplete, and location services (e.g., Google services where used).
• Identity verification (e.g., Stripe Identity) where used.
• Customer support and operational tools.

Depending on the service, the provider may process your information on Pratiqo's behalf or under its own terms, in particular for compliance, security, or fraud prevention. We select providers offering reasonable safeguards and use contractual commitments where required.

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9. Disclosure of personal information

We may disclose your personal information:

• between students and teachers to the extent necessary to book, deliver, adjust, or cancel a lesson;
• to a parent or legal guardian where appropriate and permitted by law;
• to our service providers (see section 8);
• to payment processors and financial institutions to the extent required to handle payments, payouts, refunds, disputes, or chargebacks;
• to review a dispute, safety report, fraud event, policy violation, or internal investigation;
• to comply with the law, a court order, a request from a competent authority, a tax or accounting obligation, or any other applicable legal obligation;
• in connection with a business transaction (financing, merger, acquisition, reorganization, sale of assets, or insolvency), subject to appropriate safeguards;
• with your consent or as otherwise permitted by law.

We do not sell your personal information to third parties for marketing purposes.

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10. Public profiles and reviews

Teacher profiles are designed to be discoverable by other users and, where applicable, public.

• Visible information may include, depending on the configuration: display name, photo, discipline, city or area, biography, experience, languages, average rating and reviews, availability and price ranges.
• Reviews that are posted may be visible according to platform rules and the Code of Conduct.
• Do not write sensitive information, third-party personal information, or identifiers enabling private contact (phone number, full address, personal email) into public fields (profile, reviews, biography).
• Pratiqo may, at its discretion and consistent with platform rules, mask or abbreviate certain fields publicly (e.g., displaying only a first name or display name) for safety reasons.

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11. Location and in-person lesson privacy

In-person lessons may require sharing an address or a meeting place.

• Pratiqo may show an approximate location or service zone rather than an exact address for search and matching.
• The exact address should be shared only at the time and to the extent necessary for lesson logistics.
• Do not post a personal address in a public field (profile, biography, reviews).
• For lessons involving a minor, additional safety rules apply — see the Code of Conduct.

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12. Retention and destruction

We retain your personal information only as long as reasonably necessary for the purposes described in section 4, as well as to:

• comply with legal, tax, accounting, and contractual obligations;
• resolve disputes, reports, or chargebacks;
• support security, prevent fraud, and enforce our policies;
• maintain backups and service continuity.

Retention periods vary by the nature of the information. For reference, the main categories are:

These periods may vary depending on applicable legal obligations, disputes, backups, and technical constraints. When retention is no longer necessary, information is destroyed, deleted, anonymized, or de-identified.

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13. Security safeguards

We implement reasonable administrative, technical, and organizational safeguards to protect personal information, including:

• access controls and authentication;
• encryption in transit where applicable;
• restricted roles and privileges (least-privilege principle);
• monitoring and logging of relevant events;
• selection of providers offering reasonable safeguards;
• regular updates and vulnerability management.

No system is fully secure. We cannot guarantee absolute security. You help us by:

• protecting your login credentials and passwords;
• using two-factor authentication when offered;
• reporting suspicious activity promptly to support@pratiqo.ca.

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14. Confidentiality incidents

Pratiqo has an internal process for handling confidentiality incidents involving personal information.

When an incident is identified, we may, as applicable and to the extent permitted or required by law:

• take reasonable measures to reduce risk and limit impact;
• investigate the cause and scope of the incident;
• maintain a register of incidents where required by law;
• notify affected individuals and the Commission d'accès à l'information where required by law;
• take corrective measures to prevent recurrence.

If you believe an incident affects you, email marc-andre.theberge@pratiqo.ca with a factual summary.

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15. Privacy impact assessments and governance

Pratiqo may conduct privacy impact assessments (PIAs) for certain projects, in particular when creating or substantially modifying an information system or an electronic service involving personal information, where applicable.

We maintain governance practices proportionate to the size and activities of the company, which may include:

• internal roles and responsibilities for the protection of personal information;
• retention and destruction rules;
• a complaints process and an internal communication channel;
• security and incident-management measures;
• contractual commitments with providers.

The internal governance program continues to evolve as the platform grows; this Policy does not constitute a final compliance attestation.

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16. Your rights

Subject to applicable law, you may have, in particular, the following rights regarding your personal information:

• Access: obtain a copy of the information we hold about you;
• Correction: correct inaccurate, incomplete, or ambiguous information;
• Withdrawal of consent: where consent is the basis for processing and where the law allows it;
• Deletion / deactivation: to the extent permitted by law and in light of legal and operational limits;
• Portability: request that certain information be provided to you in a structured, commonly used technological format, where required or reasonably feasible;
• Information about purposes, recipients, and retention periods;
• Complaint: with the privacy officer and, in Quebec, with the Commission d'accès à l'information.

How to exercise a right: write to marc-andre.theberge@pratiqo.ca describing the nature of your request. We may need to verify your identity before responding. We endeavor to respond within the timelines provided by applicable law.

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17. Transfers outside Quebec or Canada

Some of our providers may store or process personal information outside Quebec or outside Canada, including in the United States or the European Union.

• Before a transfer outside Quebec where an assessment is required by applicable law, Pratiqo conducts a privacy assessment and puts in place reasonable contractual or organizational measures.
• Transferred information may be subject to foreign law and accessible to foreign authorities to the extent permitted by such law.
• Pratiqo does not promise that all data permanently remains in Quebec or Canada.

For details about the location of major processing categories, you may write to the privacy officer.

For reference, the main providers or provider categories may include:

Privacy impact assessments are completed or in progress where applicable law requires them for these providers or processing activities.

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18. Automated decisions, matching, recommendations, and AI

Pratiqo may use algorithms, filters, ranking, search, recommendations, or AI-assisted tools to, among other things:

• match students and teachers;
• assist with drafting or classification of profiles, descriptions, or content;
• personalize the YoPratiqo learning experience;
• detect fraud, abuse, or policy violations;
• support internal operations.

Today, these tools assist Pratiqo and its users and are not systematically fully-automated decisions with significant legal effects. Where applicable law regulates automated decisions, you may request information from the privacy officer and, to the extent provided by law, request human review or submit observations.

The use of AI tools available on the platform must not be used to submit fake credentials, verifications, or reviews or to produce deceptive content — see the Code of Conduct and the Teacher Terms.

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19. Marketing communications

• You may receive transactional and service messages related to your account and your lessons (confirmations, reminders, security updates, invoices, legal notices); these messages do not require a separate marketing consent.
• Promotional messages (newsletter, offers, launches) may require your consent where required by Canada's Anti-Spam Legislation (CASL) or by any other applicable law.
• You may unsubscribe from promotional messages by following the link provided in the message or by writing to support@pratiqo.ca.
• Marketing unsubscription does not stop transactional messages necessary for the provision of the service.

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20. Minors, safety reports, and legal disclosures

Privacy may interact with our safety obligations under the Code of Conduct.

Pratiqo may, to the extent permitted or required by law, preserve, review, or disclose personal information where necessary to:

• protect a minor or a vulnerable person;
• protect the safety of users or of the platform;
• comply with the law, a court order, a request from a competent authority, or a reporting obligation;
• prevent imminent serious harm.

We handle these situations seriously and proportionately, without alarmism.

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21. Changes to the policy

We may update this Policy from time to time.

• The effective date and the last updated date appear at the top of the document.
• Material changes may be communicated by means consistent with applicable law, for example by email, by an in-platform notice, or on the Policy page itself.
• Continued use of Pratiqo after a change may be treated as provided by applicable law.

Earlier versions may be retained as an internal archive.

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22. Contact

Cours Pratiqo Inc. — Saint-Georges, Québec, Canada

• Person responsible for the protection of personal information: Marc-André Théberge — marc-andre.theberge@pratiqo.ca
• Support: support@pratiqo.ca
• General: info@pratiqo.ca

Relationship with other policies. This Policy must be read together with:

• the Terms of Service ("Terms");
• the Teacher Terms;
• the Cancellation Policy;
• the Code of Conduct;
• the Payments, Refunds and Payouts Policy;
• the Pro Member Terms;
• the YoPratiqo Refund Policy.

If there is a conflict between this Policy and another Pratiqo document on an administrative, contractual, or financial matter, the document specific to that matter governs, subject to mandatory applicable law. Nothing in this Policy limits rights that cannot be validly waived by contract (including those under Law 25, PIPEDA, and Quebec's Consumer Protection Act).

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This document was originally drafted in French in compliance with the Charter of the French Language of Québec. The English version is provided as a courtesy translation.