privacy policy

Privacy Policy

Effective upon: June 30, 2025

Last updated: June 27, 2025

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We at 2353098 Alberta Ltd. dba oolu are strongly committed to transparency, and we want you to understand how we collect, use, disclose and protect your personal information, as well as how you can manage the information we collect from you.

This Privacy Policy applies to your use of our website, www.oolu.ai, and any related software, platforms and applications including the technology platform and/or application known as oolu (collectively, the “Platform”), webpages, and any information and content relating to the foregoing, including without limitation, HTML, software, code, data, text, documents, images, photographs, videos, icons, and designs (collectively, the “Content”), and all associated services (together with the Platform and the Content, the “Services”)

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By using the Services, you are accepting the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services. If you do not understand, or if you have questions about, this Privacy Policy, please contact us before using, or continuing to use, the Services.

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The date on which the Privacy Policy was last amended is indicated above. We reserve the right to change our Privacy Policy from time to time. If we choose to amend this Privacy Policy, we will revise the “last updated” date at the top of this policy when we post the updated version. We will display a prominent notice that the Privacy Policy has been amended on our Platform for a period of thirty (30) days. The amended Privacy Policy is effective when posted. Your use of the Services after we have made changes to our Privacy Policy will mean that you have accepted those changes.

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INFORMATION

Personal information means information about an identifiable individual (collectively, “personal information”), and does not include information that cannot be attributed to an identifiable individual, such as information of an anonymous nature (collectively, “non-personal information”). We will only collect, use, and disclose the personal information that we need in order to provide you with the Services.

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CONSENT

We will obtain your express consent prior to or when collecting, using, or disclosing your personal information for any purpose not described in this Privacy Policy, or for a purpose that was not identified to you nor reasonably expected at the time of collection, unless we are required or permitted by law not to obtain your consent.

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We may rely on your implied consent in certain circumstances, after taking into account factors such as the sensitivity of the personal information and your reasonable expectations. We will limit the collection, use, and disclosure of your personal information to only that which is necessary for the purposes identified, unless you have otherwise consented, or when such collection, use, and/or disclosure is permitted or required by law.

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You can always refuse to provide your personal information, except that it may prevent you from using our Services or receiving responses to your inquiries or other information of interest.

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TYPES OF PERSONAL INFORMATION WE COLLECT

We may collect various types of personal information from you, depending upon how you interact with us or use or interact with our Services. This personal information may include your:

• Contact Information. Full name, phone number, mailing address and email address.
• Purchase/Billing Information. Credit card information, account number, record of purchases, and other information as requested to facilitate or complete delivery of the Services (which is personal information to the extent it can identify an individual, but not if it only identifies another entity like a corporation).
• General Location Data. Information generated from your IP address that permits us to determine your general location.
• Device Information. IP address, operating system and platform, browser type and version, browser plug-in types and versions, device type, device identifiers, and other information about how you use the Services.
• Inferences. Inferences drawn from or created based on any of the personal information identified in this list.

We strive to uphold data minimization principles and only seek to collect personal information from you for the purposes described in this Privacy Policy.

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When we combine non-personal information with personal information, we treat the combined information as personal information. You can always refuse to provide your personal information, but please note that such refusal may lessen your experience when using the Services.

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HOW WE COLLECT PERSONAL INFORMATION

We need to collect personal information from you in order to provide you with our Services, as well as to improve your experience using our Services.

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You may provide us with personal information in several ways, including, for example when you:

• use our Services;
• correspond with us;
• sign up to receive our newsletter or promotional information;
• ask for customer service, support or other assistance; or
• interact with us in any other way, online or offline, including through our Services.

We may also collect personal information from other sources (such as from third party service providers) to, among other things, enable us to complete, verify, or update personal information contained in our records, to provide background checks and personality and behavioral assessments or otherwise facilitate that review process, and to better customize the Services we provide.

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If you change your mind about receiving our newsletters or marketing materials, you can unsubscribe with a simple click at the bottom of the message.

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Web Beacons & Cookies

Like many websites and apps, we use web beacons and “cookies”, which are small text or image files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions, including how you use a website. Some cookies enable you to navigate the Platform and use its functionalities. These cookies cannot be turned off because then the Platform cannot function properly. Other cookies may: (a) enable the Platform to provide enhanced functionalities and personalization, e.g., user location; (b) collect data on the use of the Platform and help us improve the Platform. For example, to help us to count the number of visitors to the Platform, which web pages are popular, and the time visitors spend on a specific web page; and/or (c) build a profile on your user interests and are based on identifying your browser and Internet devices. They enable us to make our advertisements more efficient and better adapted to your specific interests.

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You can set your browser or device to refuse beacons or cookies or to indicate when they are being sent. If you delete them or if you opt-out, or if you set your browser or device to decline these technologies, some Services may not function properly. This website describes the method used to refuse or disable/turn off cookies for commonly used browsers. The Services do not currently change the way they operate upon detection of a Do Not Track or similar signal.

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Online Analytics

We also use various types of online analytics including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Platform. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Platform, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here. You may opt-out of Google’s use of cookies by visiting Google’s Ads Settings.  

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Social Media Integration

The Services may, from time to time, contain links to and from social media platforms. You may choose to connect to us through a social media platform, such as Instagram, Facebook, YouTube, LinkedIn, or X (formerly Twitter), and when you do, we may collect additional information from you, including the information listed in the Types of Personal Information We Collect section above. Please be advised that social media platforms may also collect information from you. When you click on a social plug-in, such as X’s “Tweet” button, that particular social network’s plugin will be activated, and your browser will directly connect to that provider’s servers. We encourage you to review the social media platforms’ usage and disclosure policies and practices, including the data security practices, before using them.

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‍HOW WE USE PERSONAL INFORMATION

Unless otherwise consented by you in advance, or as may be permitted or required by law, we will only use and disclose your personal information to fulfill the purposes for which it was collected (and in accordance with this Privacy Policy).

We primarily use personal information to provide, maintain, and improve the Services, but we may also use personal information to do any or all of the following:

• facilitate your interactions and transactions with us, such as requests for support or additional Services;
• administer our relationship with you;
• respond to your requests, communications, suggestions, comments, and inquiries, including your feedback about the Services;
• analyze and measure performance, maintenance, and operations (such as our customer care interactions with you);
• develop new products and services and build products and features;
• conduct research to better understand the preferences of our customers like you;
• provide you with, and improve, relevant marketing offers or information from us or third parties;
• provide you with promotional items;
• develop and manage relationships with our business partners;
• respond to legally binding demands from law enforcement, regulatory authorities or other third
  parties;
• defend, protect, or enforce our rights or applicable terms of service;
• to prevent fraud or the recurrence of fraud;
• assist in the event of an emergency; and
• comply with applicable law.

We use artificial intelligence to provide or improve the Services (the “AI Services”). More specifically, our AI Services assist with matching candidates to companies, and may otherwise enhance the user experience and help our users perform actions and achieve objectives more efficiently in the Platform. We may also implement AI Services in our  business operations, so we may provide the Services efficiently and effectively. The AI Services use information provided by users to generate and output content from the Platform. The AI Services may also use information we collect from users to monitor functionality of our Platform, such as but not limited to usage and performance metrics.

We review the terms and conditions or have other written agreements with all third parties whose AI Services we use, except for open-source AI Services. We apply and maintain a risk management program to manage which third party AI Services we integrate into our Platform, Content, and business operations.

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We undertake privacy impact and/or algorithmic impact assessments to identify and mitigate potential or known impacts of our AI Services (or their use) on privacy and other fundamental rights. We do not use AI Services that violate any “No-Go Zones” identified by privacy regulators (such as for discriminatory profiling or generating content that otherwise infringes on fundamental rights), as well as potential emerging No-Go Zones (such as the creation of content for malicious purposes, e.g., deep fakes). We use anonymized, synthetic or de-identified information, rather than personal information, in the AI Services whenever possible.

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As part of our matching services, your personal information is used to render a recommendation or decision based on automated processing. Upon request, we will disclose information explaining the recommendation or decision if it will have a significant impact on you, as well as information about whom such a decision has been made, the personal information used to render the decision (although you do not have the right to access specific personal information of other individuals), the reasons and the principal factors and parameters that led to the decision, and your right to have your personal information used to render the decision corrected. You will also be given an opportunity to submit any observations to a member of our team who is in a position to review the decision made by automated means. To do so, please  contact us.

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We may also combine your personal information collected through various sources, including information collected through the Services, and develop a profile that will be used for the purposes above.

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In some cases, we de-identify your personal information as soon as we collect it. In these cases, the de-identified information is non-personal information. We may use non-personal information for any legitimate business purpose.

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HOW WE DISCLOSE PERSONAL INFORMATION

Except as set forth in this Privacy Policy, or as required or permitted by law, we do not disclose your personal information to any parties other than to an employer(s) as part of our Services (i.e. information from your LinkedIn profile or your resume), our service providers and our affiliates that have a need to use your personal information to provide or improve our Services, to legal or regulatory authorities, as described below, or for other purposes for which you have provided your consent. In no event will we sell or rent your personal information.

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We may disclose personal information:

• to an employer as part of our Services (such as personal information from your LinkedIn profile or resume, and information contained in relevant background checks, such as a criminal record check, education, professional designations, credit, social media, references, vulnerable sector check, or personality and behavioral assessments);
• to our third-party service providers to help us with the uses described in the How We Use Personal Information section above, including to conduct relevant background checks (such as a criminal record check or a vulnerable sector check) or personality and behavioral assessments, where the third party will obtain your express consent to obtaining the background check or assessment;
• to comply with your directions or any additional consent you have provided us;
• to other parties where we are under a duty to disclose your personal information in order to comply with any applicable legal obligation including a regulatory process, or an order of a government institution, investigative body, regulatory body or judicial authority of competent jurisdiction;
• where we transfer or are considering transferring control of any or all of our assets, operations or services to a third-party acquirer of all or substantially all of our assets, including our rights and obligations relating to our Services, to a third party. The third party may continue to retain and use the personal information that you provided to us. We will act in a reasonable manner, including by contractual or other means, to ensure that the third party agrees to similarly be bound by this Privacy Policy or a privacy policy that provides substantially similar measures to those employed by us to protect the privacy and security of your personal information and to similarly comply with applicable privacy legislation with respect to your personal information, but we cannot guarantee such latter compliance by the third party acquirer; and
• where we merge, consolidate, or amalgamate with a third party, the merged, consolidated, or amalgamated entity may continue to use and disclose your personal information. We will use our best efforts to ensure that the merged, consolidated, or amalgamated entity agrees to similarly be bound by this Privacy Policy or a privacy policy that provides substantially similar measures to those employed by us to protect the privacy of your personal information and to similarly comply with applicable privacy legislation with respect to your personal information, but we cannot guarantee such compliance.

We disclose non-personal information to third parties as reasonably necessary to meet our business needs. We do not disclose your personal information to third parties for their own direct marketing purposes without your consent.

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HOW WE PROTECT PERSONAL INFORMATION

We are concerned about ensuring the security of your personal information, and we have taken appropriate measures to ensure its security and confidentiality. We exercise great care in providing secure transmission of your personal information from your browser or device to our servers. For example, we use: (a) organizational safeguards, such as limiting access to personal information on a “need to know” basis; (b) technical safeguards, such as passwords, cybersecurity software, and encryption; and (c) investigative safeguards, in situations where we have reasonable grounds to believe that the personal information is or has been inappropriately collected, used, or disclosed. Our safeguards also take into account risks specific to the AI Services, e.g. model inversion attacks and jailbreaking, which we attempt to mitigate or prevent through (for example) careful monitoring and access control. We will only retain your personal information for the period of time reasonably required to fulfill the purposes for which it was collected. We may retain non-personal information for as long as we have a business need to do so.

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An organization must protect personal information that is in its custody or under its control by making reasonable security arrangements against such risks as unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. All of our service providers and contractors are contractually obligated to employ appropriate use and data security measures with respect to your personal information.  However, we are not responsible for the actions and privacy policies of these third parties and their systems, programs, websites, solutions and/or applications. Check the privacy policies of these third parties for information on their privacy practices.

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We try our best to safeguard personal information once we receive it, but please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorized use or security breach of your information, please contact us as soon as possible.

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YOUR CHOICES

We offer you certain choices in connection with our Services.

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Access to your personal information

On your reasonable written request, we will provide you, not later than thirty (30) days from our receipt of your request, or such additional time as required by law, with access to our information about your personal information (if any) under our custody or control, and the names of persons to whom, and any circumstances in which, your personal information has been and is being disclosed by us. You must provide sufficient information in your request to allow us to verify your identity and identify the information you are seeking.

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If you request a copy of your personal information and the personal information can reasonably be reproduced, we will provide you with a copy of the personal information, or, if applicable, we will give you reasons for any delay in providing a copy of the requested personal information. All requests may be subject to minimal costs, in accordance with applicable privacy legislation.

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We reserve all rights not to disclose personal information, in whole or in part, in certain circumstances permitted or required by law, including but not limited to where:

• the personal information is protected by any legal privilege;
• the disclosure of the personal information would reveal confidential commercial information;
• the disclosure could reasonably be expected to threaten the life or security of another individual;
• the personal information was generated in the course of a formal dispute resolution process; or
• the personal information was collected by us without your knowledge and consent for reasonable purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.  

If access to your personal information is refused, in whole or in part, we will provide you with the reasons for the refusal, the provision of applicable privacy legislation on which the refusal is based, and the contact information of the Privacy Officer who can answer your questions about the refusal, and will inform you that you may ask for a review of the refusal in accordance with applicable privacy legislation.  

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To submit a request to access your personal information or designate an authorized agent to make a request to access your personal information, please contact us. Our security procedures mean that we may request proof of identity before we disclose your personal information to you.

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Updating your personal information

The accuracy of the personal information we have about you is very important. You are responsible for ensuring your personal information on the Platform is current and correct, and for updating it accordingly.

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To submit a request that we update your personal information, please contact us. On your request, we will make every reasonable effort to correct outdated personal information, or errors or omissions in your personal information where that personal information is in our custody or control. Such request must be in writing, signed by you, and include sufficient detail to enable us to identify any personal information in our custody or control in relation to the request.

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We will, as soon as reasonably practical and not later than thirty (30) days from our receipt of your request, or within such additional time as permitted or required by law, either correct the personal information and, if applicable and reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect personal information, or decide not to correct the personal information (i.e. if it is not shown to be factually inaccurate or incomplete), but we will annotate the personal information under our control to indicate that a correction was requested but not made.

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We will inform you of the action that we have taken in response to your request for correction, the contact information of the Privacy Officer who can answer your questions about your request for correction, and that you may ask for a review of the action taken in accordance with applicable privacy legislation.

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Email communications

You may have the opportunity to receive certain communications from us related to our Services. If you provide us with your e-mail address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails and adjusting your email preferences. Please note that certain emails may be necessary for the operation of our Services. You will continue to receive these emails, if appropriate, even if you unsubscribe from our optional communications.

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THIRD PARTY WEBSITES AND APPS

The Services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third-party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

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CONTACT US

If you have questions, concerns, or would like to update/change your personal information, you can contact us in the following ways:

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Email

support@oolu.ai

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Phone

587-200-0114

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Mail

Suite 2020, Rice Howard Place, Tower 1, 10060 Jasper Avenue

Edmonton, Alberta, Canada

T5J 3R8

Attention: Privacy Officer

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For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.