Privacy and Confidentiality Policy

Last updated: February 12th, 2026

1. Purpose and Scope

This Privacy and Confidentiality Policy (the “Policy”) describes how Humain Pluriel and its administrators (the “Organization”, “we”, “us”, “our”) collect, use, disclose, retain, and protect personal information in the operation of the Bulles platform (the “Site”).

The Site is primarily intended for elementary and secondary school students. It allows users to upload content and works protected by copyright that they have created in order to create a publicly accessible “bubble.”

No user account is created. In order to upload content and works, the user must provide their first name, nickname or pseudonym, their grade level, the name of their school, the name of the teacher responsible for their participation on the platform at their school, as well as the full name and email address of their parent(s) or legal guardian(s) (i.e., the holder(s) of parental authority).

This Policy is primarily addressed to teachers, parents or legal guardians, as well as users aged 14 and over (users under 14 must obtain parental or guardian consent in order to participate in and contribute to the Site in accordance with this Policy and the Site’s Terms of Use), where applicable.

2. Applicable Legal Framework

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5) and the Act Respecting the Protection of Personal Information in the Private Sector (CQLR c P-39.1), as well as all other applicable privacy and personal data protection laws and regulations in force in Québec (Canada).

You have the following rights:

• Access: Request access to the personal information we hold about you
• Rectification: Request correction of inaccurate or incomplete information
• Withdrawal of consent: Withdraw your consent to processing at any time
• Deletion: Request deletion of your personal information, subject to legal requirements
• Complaint: File a complaint with the Office of the Privacy Commissioner of Canada or the Commission d’accès à l’information du Québec
• Portability: Request that your personal information be provided to you or transferred to another organization in a structured, commonly used technological format
• De-indexing: Request the de-indexing or re-indexing of any hyperlink attached to your name that provides access to your information, where dissemination of such information violates the law or a court order

To exercise any of these rights, please contact us at:info@projetbulles.com

You may also contact the Office of the Privacy Commissioner of Canada:

• Website: http://www.priv.gc.ca
• Telephone: 1-800-282-1376

You may also contact the Commission d’accès à l’information du Québec:

• Website: https://www.cai.gouv.qc.ca
• Telephone: 1-888-528-7741

3. Personal Information Collected

3.1 Nature of the Information

In connection with the use of the Site, we may collect only the personal information strictly necessary, including:

• Information required prior to creating a user’s Bubble, namely their first name, nickname or pseudonym, grade level, school name, the name of the teacher responsible for their participation on the platform at their school, as well as the full name and email address of their parent(s) or legal guardian(s);
• Uploaded content and works (images, texts, drawings, photographs, poems, audio or video), which may contain personal information if the user chooses to include it;
• Technical and browsing information (IP address, device type, browser type and version, operating system, referring website, essential cookies, date and time of visit, session duration, bubbles viewed, geographic location, navigation path and clicks).

We do not knowingly collect:

• A minor’s full name, postal address, or telephone number;
• A minor’s email address for marketing purposes;
• Information enabling profiling or targeted advertising.

3.2 Parental Consent

Where required by law, use of the Site and the uploading of content by a minor under 14 years of age must be carried out with the consent of their parent(s) or legal guardian(s), who confirm that they have read this Policy.

4. Purposes of Collection

Personal information is used solely for the following purposes:

• To enable the uploading, public display, and distribution of creative bubbles;
• To ensure the proper functioning, security, and stability of the Site;
• To prevent abuse, unlawful use, or non-compliant content;
• To improve user experience and Site performance;
• To respond to valid requests from public authorities, including court orders, legal proceedings, and governmental or regulatory requests;
• To fulfill our legal and contractual obligations toward financial partners who wish to know, in anonymized form, the number of users, the number of schools, and their regional distribution.

5. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected.

6. Cookies

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and understand how you interact with the site.

The Site uses only essential cookies and similar tracking technologies necessary for:

• The technical operation of the Site;
• Security;
• Remembering navigation preferences.

No targeted advertising or behavioral profiling cookies are used. Analytical cookies, where applicable, are configured so as not to identify users.

You may control cookies through your browser settings. Most browsers allow you to:

• View cookies stored on your device;
• Delete cookies;
• Block cookies from specific websites or all websites.

Please note that disabling certain cookies may affect the functionality of our website.

7. Access and Disclosure of Information

Access to personal information is limited to authorized individuals within the Organization who require it in the performance of their duties.

We may disclose certain information to technological service providers (hosting, security, maintenance), who act on our behalf and are contractually bound by strict confidentiality and security obligations.

8. Policy Modifications

The Organization reserves the right to modify or update this Policy without notice. We may also, at any time, make improvements and/or changes to the Site and user experience. Continued use of the Site following such updates or changes constitutes acceptance of the revised terms.

Terms of Use of the Bulles Platform (the “Site”)

Last updated: January 16, 2026

Use of the Site is authorized for non-commercial, educational, or strictly personal purposes.

Humain Pluriel and its administrators (the “Organization”, “we”, “us”, “our”) ensure that the Site, the Bubbles, and the content and works displayed on the Site comply with the Site’s objective: to provide a space that fosters creativity while maintaining an environment where behavior and language are respectful, courteous, and consistent with public order, good morals, and applicable laws and regulations. Abusive behavior or language that infringes on reputation, image, or privacy rights will not be tolerated.

While the Organization makes its best efforts to ensure the security of the Site and the experience offered to users, as well as to provide accurate and up-to-date information, this cannot be guaranteed. Users are therefore responsible for exercising vigilance and taking necessary security measures to avoid any bug, virus, Trojan horse, or other malicious attack that may be transmitted to or through the Site by a third party. Information on our website is provided for informational purposes only and does not constitute professional advice.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, the Site is provided “as is” and “as available,” without warranty of any kind, express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, non-infringement, or availability. In no event shall the Organization, its directors, employees, partners, agents, or affiliates be liable for any indirect, incidental, special, consequential, or punitive damages arising from your use of, or inability to use, the Site.