Privacy Policy

1. Introduction

Lodomi Ltd. ("Lodomi", "we", "our", or "us") is a federal corporation registered in the Province of British Columbia, Canada. We are committed to protecting the privacy and security of your personal information in accordance with:

• Canada's federal Personal Information Protection and Electronic Documents Act (PIPEDA);
• Quebec's Act respecting the protection of personal information in the private sector (Law 25 / Bill 25); and
• Other applicable provincial privacy legislation.

This Privacy Policy applies to all personal information collected through the Lodomi website and platform.

2. Privacy Officer

We have designated a Privacy Officer who is responsible for our compliance with this Privacy Policy and applicable privacy legislation.

Quebec residents may contact our Privacy Officer as their designated point of contact under Law 25 for all privacy-related requests.

3. Information We Collect

We collect the following categories of personal information:

4. Why We Collect It

We collect and use your personal information for the following purposes:

• To create and manage your user account;
• To match borrowers with lenders based on location and search criteria;
• To display your listings to other registered users;
• To send transactional emails (account activation, password reset, transaction notifications);
• To protect the platform from fraud, spam, and automated abuse (via Cloudflare Turnstile CAPTCHA);
• To generate AI-assisted search keywords for your item listings (see Section 5 — Anthropic);
• To maintain records of consent to our Terms of Use;
• To improve and maintain the platform.

We collect only the personal information necessary for these purposes.

5. Third Parties We Share Data With

We use the following third-party service providers, each of whom may process some of your personal information in order to deliver their services to us:

6. Where Your Information Is Processed

Lodomi operates in Canada. However, some of the third-party service providers described in Section 5 store or process personal information on servers located outside Canada, including in the United States.

When personal information is processed outside Canada, it may be subject to the laws of the jurisdiction in which it is held, and may be accessible to the courts, law enforcement, and government authorities of that jurisdiction.

Lodomi remains accountable for your personal information under PIPEDA when it is transferred to a service provider for processing. We use contractual and other reasonable safeguards to require our service providers to protect your personal information and to use it only for the purposes for which it was provided. Before entrusting personal information to a provider that processes it outside Quebec, we conduct the privacy assessment described in Section 10.

7. Location Data

The location information (city name and coordinates) that you provide when listing items or setting a search location is used solely to enable proximity-based search matching — showing you listings near your chosen location, and showing your listings to users searching near you. Lodomi does not track your device's real-time location.

8. Data Retention

We retain your personal information for as long as your account is active. If you request deletion of your account, we will delete or anonymize your personal information within 30 days of your request, except where we are required by law to retain certain records (for example, financial or transaction records).

Listing content and anonymized transaction data may be retained in aggregated, non-identifiable form for platform analytics and improvement.

9. Your Rights

Under PIPEDA and applicable provincial privacy laws, you have the following rights regarding your personal information:

• Right of access — You may request a copy of the personal information we hold about you.
• Right to correction — You may request correction of inaccurate or incomplete information.
• Right to deletion — You may request deletion of your personal information ("right to be forgotten"), subject to our legal retention obligations.
• Right to withdraw consent — You may withdraw consent to our collection and use of your personal information at any time. Note that withdrawal of consent may require deletion of your account.

To exercise any of these rights, contact our Privacy Officer at privacy@lodomi.com.

10. Quebec Residents — Law 25

Quebec's Act respecting the protection of personal information in the private sector (Law 25) provides additional privacy rights for Quebec residents:

• Right to data portability — You have the right to receive your personal information in a structured, commonly used technological format.
• Right to be informed of automated decision-making — Where we use automated tools that make decisions affecting you, we will disclose this upon request.
• Privacy impact assessments — We conduct privacy impact assessments before introducing new technologies that process personal information and before communicating personal information outside Quebec.
• Breach notification — In the event of a privacy breach that presents a risk of serious injury to Quebec residents, we will notify the Commission d'accès à l'information (CAI) and affected individuals within the timeframes required by Law 25.

To exercise your rights under Law 25, contact our Privacy Officer at privacy@lodomi.com.

11. Cookies

Lodomi uses only essential session cookies that are required for the platform to function. These cookies maintain your login state while you are using the platform. They are not used for advertising, tracking, or analytics purposes.

We do not currently use non-essential cookies. If this changes, we will update this policy and, where required by law, obtain your consent.

12. Children

The Lodomi platform is not intended for use by persons under 18 years of age. We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected personal information from a minor, we will promptly delete it.

13. Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• HTTPS encryption for all data in transit;
• Hashed (not stored plaintext) passwords;
• Rate limiting to protect against brute-force attacks;
• Bot protection via Cloudflare Turnstile.

No method of electronic transmission or storage is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

14. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will notify users by requiring re-acceptance at login. Continued use of the platform after changes constitutes acceptance of the updated policy.

15. Contact Us

To exercise your privacy rights, ask questions about this policy, or report a concern, contact our Privacy Officer using the details in Section 2 (Privacy Officer).

We will respond to access, correction, and deletion requests within 30 days of receipt.