Privacy Policy

1. WHO WE ARE AND WHO IS RESPONSIBLE

Universal Soul Service Corporation is responsible for the personal information under its control and has designated a Privacy Officer to oversee its privacy program and receive questions, complaints, and rights requests.

For purposes of privacy laws that use the terms "controller" or "business," USSC is the controller or business responsible for the personal information described in this Privacy Policy unless a different entity is identified in a supplemental notice.

Our contact details are provided in Section 21.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information collected through or in connection with:

• Any website, webpage, subdomain, landing page, online store, event-registration page, mobile application, member portal, community platform, or other online service owned or operated by or on behalf of USSC that links to this Privacy Policy (collectively, the "Digital Properties").
• USSC products, services, memberships, subscriptions, courses, programs, events, retreats, communities, campaigns, communications, and customer-support activities.
• Interactions with USSC by email, telephone, videoconference, social media, postal mail, at an in-person event, or through another channel where this Privacy Policy is provided or referenced.

This Privacy Policy is designed to apply across USSC's current and future websites, brands, programs, campaigns, and services without being limited to a single domain.

Separate or supplemental privacy notices may apply to a particular product, program, activity, jurisdiction, or type of personal information. If a supplemental notice conflicts with this Privacy Policy, the supplemental notice will apply to the relevant activity. This Privacy Policy does not apply to employee or job-applicant information where a separate notice is provided.

Where the law in your location provides additional or stronger protections, we will apply those protections to the extent required by law.

3. CANADIAN PRIVACY FRAMEWORK

As a Canadian organization, our privacy program is based on Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy legislation. Depending on the circumstances, provincial laws in Alberta, British Columbia, Quebec, Ontario, or another province or territory may also apply.

Our practices are guided by the Canadian fair information principles of accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access, and the ability to challenge compliance.

We collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances and as otherwise permitted or required by applicable law.

4. WHAT PERSONAL INFORMATION WE COLLECT

"Personal information" means information about an identified or identifiable individual. The information we collect depends on how you interact with us and may include:

• Contact and identification information, such as your name, email address, telephone number, postal address, country, age or age range, and similar details.
• Account and registration information, such as login credentials, profile information, preferences, membership details, application information, and information provided when registering for an event, course, program, community, or service.
• Transaction and commercial information, such as products, programs, events, memberships, or services considered or purchased; billing and delivery information; transaction dates; payment status; and related customer-service records. Payment-card information is generally processed directly by payment-service providers, and USSC may receive only limited payment or transaction details.
• Communications and content you provide, including emails, messages, questions, support requests, survey responses, reviews, testimonials, comments, community posts, photographs, audio, video, and other material you submit.
• Event, course, and participation information, such as attendance, engagement, progress, interests, goals, applications, bookings, and participation in USSC programs, events, communities, or services.
• Sensitive information you voluntarily provide, which may include information concerning health or wellbeing, religious or philosophical beliefs, spiritual practices, or other information considered sensitive or a special category under applicable law. We ask that you not provide sensitive information unless it is requested and reasonably necessary for a stated purpose.
• Marketing and communication preferences, such as subscriptions, consent records, language, interests, and choices about how we contact you.
• Technical and usage information, such as Internet Protocol address, browser type, device type, operating system, device identifiers, approximate location derived from an IP address, referring pages, pages viewed, links selected, access dates and times, and interactions with our Digital Properties and electronic communications.
• Inferences and preferences, such as likely interests or preferences derived from your activity, purchases, survey responses, or other interactions, where permitted by law.

The categories above also describe the categories of personal information that we may have collected, used, or disclosed during the preceding 12 months where a lookback disclosure is required by applicable law.

5. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information:

• Directly from you when you create an account, complete a form, make a purchase, register for or attend an event, submit an application, subscribe to communications, contact us, participate in a community, or otherwise interact with USSC.
• Automatically through cookies, pixels, web beacons, software development kits, server logs, and similar technologies when you use the Digital Properties or interact with our electronic communications.
• From service providers and business partners, such as payment processors, event and videoconferencing platforms, marketing platforms, analytics providers, customer-support providers, social-media platforms, referral or affiliate partners, and organizations with which we offer a collaborative program.
• From another person acting on your behalf or purchasing, registering, or making an inquiry for you.
• From publicly available sources where collection is permitted by applicable law.

6. WHY WE COLLECT AND USE PERSONAL INFORMATION

We may collect and use personal information to:

• Provide, operate, maintain, personalize, and improve our Digital Properties, products, programs, events, communities, and services.
• Process registrations, applications, orders, payments, subscriptions, sacred offerings or donations where applicable, refunds, and other transactions.
• Create and manage accounts, memberships, profiles, access permissions, and participation records.
• Communicate with you about your account, purchases, registrations, events, programs, support requests, service updates, and administrative matters.
• Deliver newsletters, announcements, offers, and other marketing communications in accordance with your choices and applicable law.
• Understand interests and engagement, conduct surveys, improve user experiences, and develop or evaluate products, services, content, and programs.
• Measure audience trends and the performance of our Digital Properties, communications, campaigns, and advertising.
• Moderate communities, enforce community standards, and protect participants and the integrity of our services.
• Detect, investigate, prevent, and address fraud, misuse, security incidents, prohibited activity, and technical problems.
• Protect the rights, property, safety, and security of USSC, our users, and others.
• Comply with legal, tax, accounting, regulatory, and reporting obligations; enforce our agreements and policies; establish or defend legal claims; and respond to lawful requests.
• Carry out another purpose disclosed to you at or before the time of collection, or a purpose for which we obtain your consent.

We will not use personal information for a materially new purpose without providing any notice and obtaining any consent required by applicable law.

7. CONSENT AND LAWFUL BASES

Canada

Where required under Canadian law, we obtain meaningful consent for the collection, use, or disclosure of personal information. The form of consent may vary depending on the circumstances and sensitivity of the information. We seek express consent for sensitive information and other activities presenting a meaningful risk of harm, unless an exception under applicable law applies.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If withdrawing consent means we can no longer provide a requested product, service, or feature, we will explain that consequence where appropriate.

European Economic Area, United Kingdom, and Switzerland

Where the European Union General Data Protection Regulation, United Kingdom General Data Protection Regulation, or similar law applies, we rely on one or more of the following lawful bases:

• Performance of a contract with you or steps requested by you before entering a contract.
• Compliance with a legal obligation.
• Our legitimate interests or those of a third party, where those interests are not overridden by your rights and freedoms. These interests may include operating and improving our services, communicating with customers, securing our systems, preventing fraud, and understanding service performance.
• Your consent, which you may withdraw at any time without affecting processing that occurred before withdrawal.
• Protection of vital interests where applicable.

When we process sensitive or special-category information, we will rely on your explicit consent or another condition permitted by applicable law.

Other Locations

Where another privacy law applies, we will process personal information on a lawful basis recognized in that jurisdiction.

8. COOKIES, ANALYTICS, AND ADVERTISING

We and our service providers may use cookies, pixels, web beacons, analytics tools, software development kits, and similar technologies to:

• Operate and secure the Digital Properties.
• Remember settings and preferences.
• Understand how users engage with our services and communications.
• Improve performance and user experience.
• Measure campaigns and deliver or assess advertising.

Where required by law, we will ask for consent before using non-essential cookies or similar technologies and will provide a cookie banner, preference centre, or comparable tool. Your browser or device may also allow you to block or delete cookies. Disabling certain technologies may affect the availability or functionality of parts of the Digital Properties.

Some privacy laws may treat the use of advertising or analytics technologies as a "sale," "sharing," or use for targeted advertising even when no money is exchanged. Where applicable, you may opt out using our cookie or privacy controls, a recognized opt-out preference signal such as Global Privacy Control, or the contact details in Section 21.

9. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to:

• Service providers and contractors supporting website and application hosting, cloud storage, cybersecurity, payment processing, order fulfilment, event delivery, videoconferencing, communications, email and messaging, customer support, analytics, advertising, professional advice, and related operations.
• USSC-affiliated brands, teams, and entities where access is reasonably necessary to operate our organization and provide the relevant products, programs, events, or services.
• Business, referral, affiliate, and collaboration partners where we jointly provide or promote a product, program, event, campaign, or service. Where required, we will provide additional notice and choice at the point of collection.
• Analytics and advertising partners that help us understand engagement, measure performance, or deliver relevant advertising, subject to your choices and applicable law.
• Government authorities, courts, law-enforcement agencies, regulators, or other parties where disclosure is required or permitted by law or reasonably necessary to protect rights, property, safety, security, or the integrity of our services.
• Parties involved in a merger, financing, reorganization, acquisition, sale of assets, insolvency, or similar corporate transaction, subject to appropriate confidentiality and legal safeguards.
• Other parties at your direction, with your consent, or for a purpose disclosed when the information is collected.

We require service providers that process personal information on our behalf to use it only for authorized purposes and to protect it through contractual, technical, and organizational safeguards appropriate to the circumstances.

10. SALE, SHARING, AND TARGETED ADVERTISING

We do not disclose personal information to third parties except as described in this Privacy Policy or otherwise disclosed to you.

Advertising and analytics activities may constitute a "sale" or "sharing" of personal information or targeted advertising under certain laws. Where such laws apply, we will provide the legally required notice and opt-out method. We will not knowingly sell or share for targeted advertising the personal information of individuals under 16 without the affirmative authorization required by applicable law.

If we offer a financial incentive or loyalty program involving personal information and applicable law requires a separate notice, we will provide that notice before you participate.

11. MARKETING COMMUNICATIONS AND CANADA'S ANTI-SPAM LAW

We send commercial electronic messages in accordance with Canada's Anti-Spam Legislation ("CASL") and other applicable marketing laws. Where required, we will obtain consent before sending a commercial electronic message, identify the sender, provide contact information, and include a working unsubscribe mechanism.

You may unsubscribe from marketing emails at any time by selecting the unsubscribe link in the message or by contacting us. We will process unsubscribe requests within the period required by applicable law. Even if you opt out of marketing, we may still send transactional, service, security, or other non-promotional communications where necessary.

12. PUBLIC AND USER-GENERATED CONTENT

Information you voluntarily post in a public or shared area of a Digital Property, such as a community, message board, comment area, profile, event chat, testimonial page, or livestream, may be visible to other users and may be collected, copied, or used by them. Please use care when deciding what information to make public.

Where we wish to use a testimonial, image, audio recording, or video for promotional purposes beyond the context in which it was submitted, we will obtain any permission required by applicable law.

13. DATA RETENTION AND DISPOSAL

We retain personal information only for as long as reasonably necessary for the purposes identified in this Privacy Policy or at the time of collection, including to provide services, maintain transaction and consent records, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect against fraud or misuse.

Retention periods vary depending on the nature and sensitivity of the information, the purposes for which it is used, legal limitation periods, and applicable recordkeeping requirements. When personal information is no longer required, we take reasonable steps to securely delete, destroy, or anonymize it, subject to applicable law and technical limitations. Anonymized information that can no longer reasonably identify an individual may be retained and used for legitimate purposes.

14. DATA ACCURACY

We take reasonable steps to keep personal information as accurate, complete, and up to date as is necessary for the purposes for which it is used. You may request correction of inaccurate or incomplete personal information by contacting us.

15. SECURITY AND PRIVACY INCIDENTS

We use reasonable administrative, technical, physical, and organizational safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, alteration, or disposal. Safeguards are selected based on factors such as sensitivity, quantity, format, and storage method.

No system, transmission, or storage method is completely secure, and we cannot guarantee absolute security.

If a privacy or security incident occurs, we will investigate and take appropriate steps to contain and remediate it. We will notify affected individuals, privacy regulators, and other parties where required by applicable law. Under PIPEDA, this includes reporting and notification where a breach of security safeguards creates a real risk of significant harm, as well as maintaining required breach records.

16. INTERNATIONAL AND CROSS-BORDER PROCESSING

USSC is based in Canada. We and our service providers may process or store personal information in Canada, the United States, and other countries in which we or our service providers operate.

When personal information is transferred to a service provider in another country for processing, USSC remains accountable for that information as required by Canadian law and uses contractual or other measures designed to provide a comparable level of protection. Personal information processed in another jurisdiction may be subject to that jurisdiction's laws and may be accessible to its courts, law-enforcement agencies, national-security authorities, or regulators in accordance with local law.

Where laws in the European Economic Area, United Kingdom, Switzerland, Brazil, Australia, or another jurisdiction require specific safeguards for international transfers, we will use a permitted transfer mechanism where applicable, such as an adequacy decision, approved contractual clauses, or another legally recognized safeguard.

You may contact our Privacy Officer for more information about relevant cross-border processing or safeguards.

17. YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live and subject to legal limitations and exceptions, you may have the right to:

• Be informed about our handling of your personal information.
• Request access to or a copy of personal information we hold about you.
• Request correction of inaccurate or incomplete personal information.
• Request deletion or erasure of personal information.
• Withdraw consent where processing is based on consent.
• Object to or request restriction of certain processing.
• Request portability of eligible personal information.
• Opt out of marketing, targeted advertising, profiling with legal or similarly significant effects, or the sale or sharing of personal information, where applicable.
• Request limitation of certain uses or disclosures of sensitive personal information, where applicable.
• Ask for information about automated decision-making and request human review where required by law.
• Request that we cease disseminating personal information or de-index or re-index a hyperlink associated with your name where such a right is provided by applicable law.
• Appeal a decision concerning a privacy-rights request, where applicable.
• Complain to an applicable privacy or data-protection regulator.
• Exercise your rights without unlawful discrimination or retaliation.

To exercise a right, contact us using the details in Section 21. Please describe your request and the Digital Property, product, program, event, or service involved. We may need to verify your identity before completing a request. We will use verification information only for that purpose. An authorized agent may submit a request where permitted by law, subject to verification of the agent's authority. We will make additional request methods, such as a web form or toll-free number, available where legally required.

We will respond within the time required by applicable law. Under PIPEDA, access requests are generally answered within 30 days, subject to permitted extensions and exceptions. If we cannot fulfil all or part of a request, we will provide an explanation where required.

18. ADDITIONAL REGIONAL INFORMATION

Canada

You may request access to personal information under our control, information about how it has been used and disclosed, and correction of inaccuracies. You may withdraw consent subject to legal or contractual restrictions and reasonable notice. You may also challenge our compliance by contacting our Privacy Officer.

If your concern is not resolved, you may have the right to complain to the Office of the Privacy Commissioner of Canada or an applicable provincial privacy regulator, including a regulator in Alberta, British Columbia, Quebec, or another province or territory.

European Economic Area, United Kingdom, and Switzerland

Where applicable, you may request access, correction, erasure, restriction, or portability; object to processing; and withdraw consent. You may lodge a complaint with the supervisory authority in the country where you live, work, or believe an infringement occurred.

YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO PROCESSING BASED ON OUR LEGITIMATE INTERESTS, INCLUDING PROFILING BASED ON THOSE INTERESTS. YOU ALSO HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING, INCLUDING RELATED PROFILING.

United States

Residents of California and certain other U.S. states may have rights to know or access, correct, delete, and obtain a portable copy of personal information, as well as to opt out of sale, sharing, targeted advertising, or certain profiling. They may also have the right to limit certain uses of sensitive personal information, appeal a denied request, use an authorized agent, and receive equal service and pricing when exercising privacy rights.

Where legally required, we recognize browser-based opt-out preference signals, including Global Privacy Control, as a request to opt out for the browser or device sending the signal.

Australia, Brazil, and Other Jurisdictions

If privacy law in your country applies to our processing, you may exercise the access, correction, deletion, objection, restriction, portability, consent-withdrawal, complaint, or other rights provided by that law. Contact our Privacy Officer so we can assess and respond to your request under the applicable legal framework.

19. CHILDREN'S PRIVACY

Our general-audience Digital Properties are not directed to children under 16, and we do not knowingly collect personal information from children under 16 without the authorization of a parent or guardian where required by applicable law.

If a particular USSC program or service is intended for minors, we may provide a separate notice and obtain parental or guardian consent or authorization appropriate to the child's age, maturity, the sensitivity of the information, and applicable law.

If we learn that we collected a child's personal information without required authorization, we will take reasonable steps to delete it. If you believe a child has provided personal information inappropriately, please contact our Privacy Officer.

20. THIRD-PARTY WEBSITES AND CHANGES TO THIS POLICY

Third-Party Websites and Services

The Digital Properties may contain links to or integrations with websites, platforms, products, and services operated by third parties. We do not control their privacy or security practices. Information you provide directly to a third party is governed by that party's privacy notice, and we encourage you to review it before providing personal information.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, services, technologies, or legal obligations. When we make changes, we will post the updated policy on the relevant Digital Properties and revise the "Last Updated" date. Where required by law, we will provide additional notice or obtain consent before a change takes effect.

21. CONTACT US AND PRIVACY COMPLAINTS

If you have questions, concerns, complaints, or requests concerning this Privacy Policy or our handling of personal information, please contact:

Privacy Officer
Universal Soul Service Corporation
30 Wertheim Ct
Richmond Hill, ON L4B 1B9
Canada

Email: info@drsha.com

Where applicable law requires USSC to appoint a representative in another jurisdiction, the representative's contact information will be made available through the relevant Digital Property or supplemental privacy notice.

Please include enough information for us to understand and respond to your inquiry, but do not send sensitive personal information by unsecured email. We will investigate privacy complaints and take appropriate corrective action where warranted.