Surveillance and Monitoring Policy

Last Updated on July 5, 2026

Welcome to Marketeq Digital Inc. (hereinafter referred to as "Marketeq," "we," "us," or "our"). This Surveillance and Monitoring Policy (the "Policy") describes the circumstances in which Marketeq may monitor the use of its systems, networks, and services, and the safeguards it applies when doing so. Monitoring supports the security, integrity, and proper functioning of our systems, but Marketeq conducts it in a manner that respects the rights and expectations of individuals. This Policy supplements our Privacy Policy and GDPR Compliance and Data Protection Statement and should be read together with them. If you have any questions about this Policy, you may contact us at legal@marketeqdigital.com.

1. Purpose and Scope

The purpose of this Policy is to explain how and why Marketeq monitors the use of its systems and services and the protections that apply. This Policy applies to monitoring activities carried out by Marketeq in relation to its website, networks, systems, and digital products. Monitoring is undertaken for legitimate purposes such as security, compliance, and the proper operation of our services. This Policy reflects our commitment to conducting monitoring proportionately and transparently. It should be understood in the context of the specific systems and activities to which it applies.

2. Purposes of Monitoring

Marketeq may monitor the use of its systems and services for a range of legitimate purposes. These include protecting the security and integrity of our systems, detecting and preventing unauthorized access or misuse, ensuring compliance with our policies and applicable law, and maintaining the availability and performance of our services. Monitoring also supports the investigation of suspected security incidents and the protection of the rights, property, and safety of Marketeq, its users, and others. We conduct monitoring only for purposes that are legitimate and proportionate. We do not use monitoring for purposes that are incompatible with those disclosed.

3. Types of Monitoring

The monitoring carried out by Marketeq may include the logging of system and network activity, the review of access and usage records, and the use of automated tools to detect anomalous or malicious behavior. We may monitor traffic and events across our infrastructure to identify potential security threats. The nature and extent of monitoring vary depending on the system involved and the risks associated with it. We seek to limit monitoring to what is necessary for the relevant purpose. Automated monitoring is designed to focus on security and operational indicators rather than the content of communications, except where necessary and permitted.

4. Legal Basis and Proportionality

Where monitoring involves the processing of personal data, Marketeq relies on an appropriate legal basis, such as its legitimate interests in securing and operating its systems, and conducts the monitoring in a proportionate manner. We consider the impact of monitoring on the individuals concerned and seek to minimize intrusion. We balance the purposes of monitoring against the rights and reasonable expectations of individuals. Where required, we conduct assessments to evaluate the necessity and proportionality of monitoring activities. Our approach is designed to ensure that monitoring is justified and does not exceed what is necessary.

5. Transparency

Marketeq seeks to be transparent about the fact that it may monitor the use of its systems and services. This Policy, together with our Privacy Policy and other notices, informs users that their use of our systems may be logged, reviewed, and analyzed to the extent permitted by applicable law. Where specific monitoring gives rise to additional notice obligations, we will provide appropriate information. Transparency regarding monitoring supports trust and enables individuals to understand how their use of our systems may be observed. We aim to avoid covert monitoring except where it is strictly necessary and legally justified.

6. Handling of Monitoring Data

Data generated through monitoring is subject to appropriate security measures and is accessed only by authorized personnel with a legitimate need. We use monitoring data only for the purposes for which it was collected, such as security and compliance, and we do not use it for unrelated purposes without an appropriate legal basis. Monitoring data is retained only for as long as necessary to fulfill its purpose or as required by applicable law, in accordance with our Data Retention Policy. We handle monitoring data with the same care applied to other categories of data. The confidentiality of monitoring data is protected against unauthorized access.

7. Use in Investigations

Where monitoring identifies a potential security incident, policy violation, or unlawful activity, Marketeq may use the resulting data to investigate and respond to the matter. In the course of an investigation, we may review relevant records and, where appropriate, take action such as restricting access or notifying authorities. We conduct investigations fairly and in accordance with applicable law. Data used in investigations is handled confidentially and shared only with those who need it for legitimate purposes. Our use of monitoring data in investigations is limited to what is necessary and proportionate.

8. Individual Rights

Individuals may have rights in relation to personal data processed through monitoring, including rights of access and, where applicable, objection. We facilitate the exercise of these rights in accordance with our Privacy Policy and applicable law, subject to any limitations necessary to protect the purposes of monitoring, such as security and the prevention of misuse. Where a right cannot be fully satisfied due to such limitations, we will explain the reasons to the extent permitted. Individuals may contact us to exercise their rights or to raise concerns regarding our monitoring practices.

9. Changes to This Policy

Marketeq reserves the right to modify or update this Surveillance and Monitoring Policy at any time to reflect changes in our practices or legal requirements. Any changes will become effective upon posting the revised Policy, and we encourage you to review it periodically. Where changes are material, we will endeavor to provide additional notice through appropriate means.

10. Contact Information

If you have any questions, concerns, or requests regarding this Surveillance and Monitoring Policy, please contact us at legal@marketeqdigital.com. We are committed to conducting monitoring responsibly and to addressing your inquiries promptly and transparently.