Pointricity’s Privacy Policy

Last modified: December 1, 2021

Pointricity Inc. (“Pointricity”, “we”, “our”) respect your privacy and are committed to protecting it by complying with this privacy policy.

This policy describes:

· How we collect, use, disclose, and protect the personal information of our users (“you”).

· Other types of information we may collect from you or that you may provide when you visit our website www.pointricity.com (our “Site”) or sign up for our Pointricity points accumulation and redemption service (the “Service”).

· Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. This policy forms part of our Terms of Service. By accessing our Site or using the Service, you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information. Your continued use of the Site and the Services after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

When Does This Policy Apply

This policy applies to information we collect, use, or disclose about you:

· On our Site.

· Through signing up for or use of the Service.

· In email, text, and other electronic messages between you and us, or the vendor partners we work with that offer points through the Service (collectively, “Partners”).

The Site may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. This policy does not apply to information that you provide to or is collected by any third party, through any application or content (including advertising) that may link to or be accessible from the Site. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Information We Collect About You

We collect and use several types of information from and about you, including:

· Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name, or other similar identifiers, billing and account information, and any other identifier we may use to contact you (“personal information”).

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

We provide an opportunity for any user to unsubscribe from the Service or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our marketing e-mails.

· Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Site feature.

· Technical information, including your login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.

· Non-personal details about your Site interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Site (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How We Collect Information About You

Information You Provide to Us

The information we collect directly from you on or through our Site may include:

· Information that you provide by filling in forms on our Site. This includes information provided at the time of subscribing to our Service. We may also ask you for information when you enter a promotion sponsored by us, and when you report a problem with our Site.

· Information collected through your use of the Service.

· Records and copies of your correspondence (including email addresses), if you contact us.

· Your responses to surveys that we might ask you to complete for research or Service improvement purposes.

· Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site, which is processed by a third-party payment processor. We encourage you to read the privacy policy on our payment processor’s website regarding the use, storage, and protection of your credit card information before submitting any payment information.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

· Details of your visits to our Site, including traffic data, location data, and other communication data and the resources that you access and use on the Site.

· Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information. We may maintain it or associate it with personal information that you provide to us, or that we receive from third parties. This helps us to improve our Site and to deliver better and more personalized service, including by enabling us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences, allowing us to recognize when you return to our Site and customize our Site according to your individual interests.

We use certain technologies for automatic data collection, such as browser cookies, web server logs, web beacons (also known as “action tags” or “one-pixel .gif files”), or other statistics programs. A “cookie” is a small file that is stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. We do this on our Site (including mobile apps) and in emails that we send to you. We collect information about users over time when you use this Site (including mobile apps). For more information about how you can disable cookies, see Choices About How We Use and Disclose Your Information.

Third Party Use of Cookies

Some content or applications on the Site, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

We do not control these third parties tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt-out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

· To present our Site and its contents to you and to provide the Services to you.

· To fulfill the purposes for which you provided the information or that were described when it was collected, such as provide you with the Service, or any other purpose for which you provide it.

· To provide you with notices about your account, including expiration and renewal notices.

· To notify you about changes to our Site or any products or services we offer or provide through it.

· To improve our Site, products or services, marketing, or customer relationships and experiences.

· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

· For any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data, adjust your user preferences in your account profile, or use the unsubscribe mechanism at the bottom of our e-mails. For more information, see Choices About How We Use and Disclose Your Information.

Disclosure Of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

· To our subsidiaries and affiliates.

· In accordance with applicable law, to a buyer or other successor in the event of a merger, restructuring, dissolution, or other sale or transfer of some or all of Pointricity’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pointricity about our users is among the assets transferred.

· To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users.

· To Partners to market their products or services to you if you have consented to these disclosures. We contractually require these Partners to keep personal information confidential and use it only for the purposes for which we disclose it to them.

· To suppliers, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

· To fulfill the purpose for which you provide it, or any other purpose disclosed by us when you provide the information.

· With your consent.

We may also disclose your personal information:

· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

· To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pointricity, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not give, rent or sell your personal information to any organization or individual other than our suppliers contracted to process and manage transactions, redemption requests, research, analysis, and communications and in all cases only, to fulfill the specified purposes. Personal and transaction information is not disclosed from one Partner to another.

Transferring Your Personal Information

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country.

Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Site, you consent to this transfer, storage, or processing.

Choices About How We Use and Disclose Your Information

We have created mechanisms to provide you with the following control over your information:

· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Site may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.

· Promotional Offers from Pointricity. If you have opted in to receive certain emails from us but no longer wish to receive emails promoting our own or third parties products or services, you can opt-out by logging into the Site and adjusting your user preferences in your account profile. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to us as part of a product purchase, product service experience points redemption, or similar transactions.

We do not control third parties collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of several third-party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of

Data Security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal

information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Minors

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features/register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@pointricity.com.

Accessing And Correcting Your Personal Information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you have the right to request access to and to correct the personal information that we hold about you. You can review and change your personal information by logging into the Site and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at privacy@pointricity.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If

we cannot provide you with access to your personal information, we will inform you of the reasons why subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@pointricity.com.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@pointricity.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and through a notice on the Site home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

If you do not agree to the changes, then you must stop using the Service and the Site. Your continued use of the Service or the Site means you agree to the changes.

Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: privacy@pointricity.com.

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above