# RANGERIO PRIVACY POLICY **Version 1.0** **Effective Date: September 1, 2026** This Privacy Policy explains how **D2V Analytics Inc.**, a corporation incorporated under the *Canada Business Corporations Act* and carrying on business in Québec, doing business as **RangerIO** (“**D2V**”, “**we**”, “**us**” or “**our**”), handles personal information in connection with the RangerIO software, website and related services (the “**RangerIO Services**”). This Policy is governed by the *Act respecting the protection of personal information in the private sector* (Québec) and the *Personal Information Protection and Electronic Documents Act* (Canada). Capitalized terms not defined here have the meaning given in the RangerIO Software Licence and Terms of Use. --- ## 1. THE MOST IMPORTANT POINT **The documents, files, prompts and other content you process with RangerIO stay on your device.** RangerIO performs sensitive-information detection, transformation, tokenization and rehydration locally. **We do not receive, store, transmit or have access to that content.** It does not reach our infrastructure, and we cannot read it. This Policy is therefore mostly about a narrow set of information: what is needed to issue you a licence, to answer you when you write to us, and to fix the software when you choose to send us a diagnostic report. Two things to be clear about: - If you configure a **third-party AI provider**, information you send through that provider goes to them, not to us. See §7. - If you install RangerIO on a shared or managed device, your **employer or IT administrator** may have access to that device and to the local RangerIO data stored on it. That is outside our control. --- ## 2. INFORMATION WE COLLECT ### 2.1 Licence information To issue and validate a Licence Key we collect and hold: * the email address you provide; * your name or organization name, where you provide it; * the Licence Key issued to you, the edition it enables, and its status; * the date and time of activation and validation events, and the general technical context of those events (such as application version and operating system). Licence activation and validation require an internet connection. ### 2.2 Correspondence If you contact us — for support, a security report, a privacy request, or any other reason — we hold your message, your contact details, and our reply. ### 2.3 Diagnostic reports you choose to send RangerIO records application logs and operational events **locally on your device**. These record application activity, not the content you process, and they are **not transmitted to us automatically or in the background**. If you choose to send a diagnostic or crash report, we receive what that report contains. Because a report may in some circumstances include fragments of application state, you should review it before sending. We use these reports only to diagnose and correct faults. ### 2.4 Website When you visit rangerio.com, our hosting provider processes standard technical information such as IP address, browser type and pages requested, for the purposes of serving the site and maintaining its security. We do not use advertising trackers and we do not sell or share personal information for advertising purposes. ### 2.5 What we do not collect We do not collect: * the documents, files, prompts or other content you process with RangerIO; * the results of detection, tokenization or rehydration performed on your device; * your API keys or credentials for third-party AI providers, which are stored locally on your device; * payment information — RangerIO is currently a free public beta and we do not process payments. --- ## 3. WHY WE USE IT | Information | Purpose | |---|---| | Licence information | To issue, activate, validate and manage your licence; to prevent unauthorized use; to notify you of security or service matters | | Correspondence | To respond to you and keep a record of the exchange | | Diagnostic reports | To diagnose and correct faults in the software | | Website technical data | To deliver the website and maintain its security | We do not use your personal information to train artificial-intelligence models, and we do not use it for automated decision-making that produces legal or similarly significant effects. ## 4. LEGAL BASIS AND CONSENT We collect and use personal information with your consent, or where the law otherwise permits or requires it — including where the information is necessary to provide a service you have requested, to protect the security of our systems, or to comply with a legal obligation. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent to licence processing means we can no longer issue or validate a Licence Key, and the software will not activate. ## 5. WHO WE SHARE IT WITH We do not sell personal information. We disclose personal information only: * to service providers who process it on our behalf and under contract — currently our hosting, email and licence-delivery providers — and only to the extent needed for those services; * where required by law, court order, or a lawful demand from a public authority; * to protect our rights, safety, or the security and integrity of the RangerIO Services; * in connection with a merger, acquisition or sale of assets, in which case we will require the recipient to continue to protect the information in a manner consistent with this Policy and applicable law. ## 6. WHERE IT IS STORED, AND TRANSFERS OUTSIDE QUÉBEC Personal information we hold may be stored or processed outside Québec, including elsewhere in Canada, in the United States or in the European Union, by the service providers described in §5. Information stored in another jurisdiction may be accessible to the courts, law enforcement and national security authorities of that jurisdiction. Before entrusting personal information to a service provider outside Québec, we assess whether the information will receive adequate protection, having regard in particular to the sensitivity of the information, the purposes for which it is used, the protections in place and the legal framework of the receiving jurisdiction, and we require contractual protections. **This section concerns only the limited information described in §2.** It does not concern the content you process with RangerIO, which stays on your device. ## 7. THIRD-PARTY AI PROVIDERS RangerIO can be configured to send information to third-party artificial-intelligence providers that you choose. **Those providers are not our service providers and do not act on our behalf.** When you route information to one of them: * the information goes directly from your device to that provider; * it does not pass through our infrastructure; * its handling is governed by that provider's own terms and privacy policy; * the provider may be located outside Québec and outside Canada. RangerIO is designed to reduce what is disclosed to those providers, but **no automated detection system is infallible**, and information the software does not detect may be transmitted. If you are subject to privacy, professional-secrecy, residency or sectoral obligations, assess the provider before enabling it. See §12 of the Terms of Use. ## 8. HOW LONG WE KEEP IT We keep personal information only as long as necessary for the purposes described in this Policy, or as required by law. * **Licence information** — for as long as your licence is active, and afterwards for the period needed to handle reactivation, disputes, and legal and accounting obligations. * **Correspondence** — for as long as needed to handle the matter and to keep a reasonable record of it. * **Diagnostic reports** — until the fault is resolved, after which they are deleted. * **Website technical data** — for the short period our hosting provider retains server logs. When information is no longer needed, we delete it or anonymize it. ## 9. YOUR RIGHTS Subject to the conditions and exceptions set out in applicable law, you have the right to: * **be informed** of the personal information we hold about you, and to **access** it; * **correct** information that is inaccurate, incomplete or ambiguous; * **withdraw consent** to our use of your information; * **request deletion** of information we are no longer authorized to keep; * **receive a copy** of the computerized personal information you provided to us, in a structured, commonly used technological format, and ask us to transmit it to another organization (data portability); * **request de-indexing** of information in the circumstances the law provides; * **be informed** of the reasoning behind, and the principal factors in, any decision based exclusively on automated processing — we do not currently make such decisions; * **file a complaint** with us, and with the Commission d'accès à l'information du Québec or the Office of the Privacy Commissioner of Canada. To exercise any of these rights, contact us at **info@rangerio.com**. We will respond within **30 days**. We may ask you to verify your identity before acting on a request. If we refuse a request in whole or in part, we will tell you why, tell you how to seek a review, and give you the time limit for doing so. ## 10. PERSON IN CHARGE OF THE PROTECTION OF PERSONAL INFORMATION The person responsible for the protection of personal information at D2V, and for compliance with this Policy, is: > **Vadim Shvarts** > Person in Charge of the Protection of Personal Information > D2V Analytics Inc. (d/b/a RangerIO) > 1580 Du Bordeaux, Saint-Lazare, Québec, Canada > **info@rangerio.com** Address privacy questions, access and correction requests, and complaints to this contact. ## 11. SECURITY We use technical and organizational measures intended to protect personal information against loss, theft and unauthorized access, disclosure, copying, use or modification. These include access controls, encryption in transit, and limiting access to those who need it. No system is completely secure. The architecture of RangerIO reduces this risk directly: because the content you process stays on your device, it is not exposed to a breach of our systems. **The security of your own device is correspondingly important**, since that is where your RangerIO data lives. ## 12. CONFIDENTIALITY INCIDENTS If a confidentiality incident occurs and presents a risk of serious injury, we will notify the Commission d'accès à l'information and the individuals concerned promptly, as required by law, and take reasonable measures to reduce the risk of injury and prevent recurrence. We maintain a register of confidentiality incidents. ## 13. COOKIES Our website uses only the cookies necessary for it to function and to remain secure. We do not use advertising or cross-site tracking cookies. Where any non-essential cookie is used, we will ask for your consent first and you will be able to refuse without losing access to the site. ## 14. CHILDREN The RangerIO Services are not directed at children and we do not knowingly collect personal information from a child under 14. If you believe we have, contact us and we will delete it. ## 15. CHANGES TO THIS POLICY We may update this Policy. The version number and effective date at the top identify the current version. Where a change materially affects how we handle your personal information, we will provide notice by email or in the software before it takes effect. ## 16. CONTACT > **D2V Analytics Inc.** (doing business as RangerIO) > 1580 Du Bordeaux > Saint-Lazare, Québec, Canada > **info@rangerio.com** You may also contact the **Commission d'accès à l'information du Québec** (cai.gouv.qc.ca) or the **Office of the Privacy Commissioner of Canada** (priv.gc.ca). --- **End of Privacy Policy — Version 1.0, September 1, 2026** © 2026 D2V Analytics Inc. All rights reserved.