JC Holdings (legally 11893874 CANADA INC.)
Last updated: March 1, 2026
This Privacy Policy describes how 11893874 CANADA INC., operating as JC Holdings ("JC Holdings," "we," "us," or "our"), collects, uses, discloses, and protects personal information through our software platform, Exact Balance (exactbalance.ca) (the "Platform"), and our related websites, services, and communications.
We are committed to protecting your privacy and complying with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) ("PIPEDA") and Québec's Act respecting the protection of personal information in the private sector (CQLR, c. P-39.1), as amended by Law 25 (the "Québec Privacy Act").
By accessing or using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform.
In accordance with the Québec Privacy Act, we have designated the following person as responsible for the protection of personal information within our organization:
Privacy Officer
JC Holdings (11893874 CANADA INC.)
1130 Sherbrooke St W #1200
Montreal, Quebec H3A 2M8
Email: privacy@exactbalance.ca
You may contact our Privacy Officer for any questions, requests, or complaints regarding the handling of your personal information.
We collect the following categories of personal information:
Account Information: When you create an account, we collect your name, email address, company name, job title, phone number, and billing address.
Payment Information: When you subscribe to a paid plan, we collect payment details (credit card number, expiration date, billing address) through our third-party payment processor, Stripe, Inc. We do not directly store full credit card numbers on our servers.
Customer Data: Information you and your Authorized Users upload to or enter into the Platform, which may include identity verification recordings, bank account verification sessions, applicant personal information, and other documents containing personal information about third parties. You are responsible for ensuring you have the necessary consents and legal authority to upload such information to the Platform.
Usage Data: Information about how you interact with the Platform, including log data (IP address, browser type, operating system, referring URLs), pages visited, features used, timestamps, and click patterns.
Communication Data: Information from your communications with us, including support tickets, emails, and feedback.
Cookies and Tracking Technologies: We use cookies and similar technologies to operate the Platform, remember your preferences, and analyze usage. See Section 10 (Cookies and Tracking Technologies) for details.
We collect and use your personal information for the following purposes:
Providing the Platform: To create and manage your account, deliver the Platform's features, process verification requests, and provide customer support.
Billing and Payment: To process payments, send invoices, and manage your subscription.
Communication: To send you service-related notices, updates, security alerts, and support messages. We may also send you promotional communications about our products and services, from which you may opt out at any time.
Improvement and Analytics: To analyze usage patterns, diagnose technical issues, improve the Platform's functionality, and develop new features. We use aggregated and de-identified data for these purposes wherever possible.
Security: To detect, prevent, and respond to fraud, abuse, security incidents, and other harmful activity.
Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
We obtain your consent for the collection, use, and disclosure of your personal information at or before the time of collection, except where permitted or required by law without consent.
Express consent is obtained for the collection and use of sensitive personal information, including financial data processed through the Platform.
Implied consent may be relied upon where you voluntarily provide personal information for an obvious purpose (for example, providing your email address to create an account).
You may withdraw your consent at any time by contacting our Privacy Officer or, where applicable, by adjusting your account settings. Withdrawal of consent may limit or prevent your ability to use certain features of the Platform. We will inform you of the consequences of withdrawing consent.
We may disclose your personal information to the following categories of recipients:
Service Providers: We engage third-party service providers who process personal information on our behalf to help us operate the Platform. These include:
We enter into contractual agreements with our service providers that require them to protect personal information with security safeguards comparable to our own and to use the information only for the purposes for which it was shared.
Legal Requirements: We may disclose personal information if required to do so by law, regulation, legal process, or enforceable governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a government request.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of such transaction. We will notify you of any such transfer and any choices you may have regarding your information.
With Your Consent: We may disclose your personal information for other purposes with your express consent.
We do not sell personal information to third parties.
Your personal information may be processed and stored in jurisdictions outside of Québec and Canada, including the United States, where our service providers may maintain servers and facilities.
Before transferring personal information outside of Québec, we conduct a privacy impact assessment as required by the Québec Privacy Act to verify that the personal information will receive protection equivalent to that provided under Québec law. We implement appropriate contractual safeguards with our service providers to ensure the protection of your personal information.
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specifically:
Account Information: Retained for the duration of your account and for a period of twelve (12) months following account closure, after which it is securely destroyed or anonymized.
Customer Data: Upon termination of your subscription, Customer Data is available for export for thirty (30) days. After this period, Customer Data is securely deleted from our active systems. Backup copies may persist for up to ninety (90) days before being permanently destroyed.
Payment Information: Payment records are retained for the period required by applicable tax and commercial laws (generally seven (7) years).
Usage Data: Retained in identifiable form for up to twenty-four (24) months, after which it is aggregated and anonymized.
When personal information is no longer required, we securely destroy or anonymize it using methods appropriate to the sensitivity of the information.
We implement and maintain appropriate technical and organizational security measures designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction, including:
No method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.
We use cookies and similar tracking technologies on the Platform. In accordance with the Québec Privacy Act, we obtain your express consent before deploying non-essential cookies or tracking technologies.
Essential Cookies: Required for the Platform to function properly (e.g., session management, authentication). These do not require consent.
Analytics Cookies: Used to understand how users interact with the Platform, helping us improve functionality and user experience. These require your consent.
Preference Cookies: Used to remember your settings and preferences. These require your consent.
You can manage your cookie preferences through the cookie consent banner displayed when you first visit the Platform, or at any time through your browser settings. Disabling certain cookies may affect your ability to use some features of the Platform.
We configure our Platform to offer, by default, the highest level of confidentiality settings, in accordance with the Québec Privacy Act.
Under applicable Canadian privacy law, including the Québec Privacy Act, you have the following rights:
Right of Access: You may request access to the personal information we hold about you.
Right to Rectification: You may request that we correct any inaccurate or incomplete personal information.
Right to Deletion: You may request the deletion of your personal information, subject to certain legal exceptions (such as retention required by law).
Right to Data Portability: You may request that we provide you with your personal information in a structured, commonly used, and machine-readable format (e.g., CSV, JSON).
Right to Withdraw Consent: You may withdraw your consent to the processing of your personal information at any time.
Right to De-indexation: You may request that we cease disseminating your personal information or that we de-index any hyperlink attached to your name that provides access to your personal information, where the dissemination contravenes the law or a court order.
Right to Information About Automated Decision-Making: If we use automated decision-making processes that produce decisions affecting you, you have the right to be informed of such use and to contest the decision.
To exercise any of these rights, please contact our Privacy Officer using the contact information in Section 2. We will respond to your request within thirty (30) days of receipt. If we require additional time, we will notify you of the extension and the reasons for it.
We will not charge a fee for responding to access requests, except in cases of manifestly unfounded or excessive requests.
In accordance with the Québec Privacy Act, we conduct privacy impact assessments before:
In the event of a confidentiality incident (unauthorized access to, use of, or disclosure of personal information, or loss of personal information) that presents a risk of serious injury, we will:
The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact our Privacy Officer so that we can take appropriate action. In accordance with the Québec Privacy Act, the consent of a parent or tutor is required for the collection of personal information from minors under the age of 14.
The Platform may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party website or service you visit.
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on the Platform and updating the "Last updated" date at the top of this page. For significant changes, we may also provide notice through the Platform or by email. Your continued use of the Platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy.
If you have a complaint about our handling of your personal information, please contact our Privacy Officer. We will investigate and respond to your complaint within thirty (30) days.
If you are not satisfied with our response, you may file a complaint with the Commission d'accès à l'information du Québec (CAI):
Commission d'accès à l'information du Québec
Website: www.cai.gouv.qc.ca
Telephone: 1-888-528-7741
You may also file a complaint with the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
Website: www.priv.gc.ca
Telephone: 1-800-282-1376
This Privacy Policy is drafted in the English language. La présente politique de confidentialité est rédigée en langue anglaise.
For any questions or concerns about this Privacy Policy or our privacy practices, please contact us:
JC Holdings (11893874 CANADA INC.)
1130 Sherbrooke St W #1200
Montreal, Quebec H3A 2M8
Email: privacy@exactbalance.ca