Privacy Policy

Last Updated: October 19, 2023

Introduction
MediaValet Inc. and its affiliates (collectively “MediaValet”, “we,” “our,” or “us”) are committed to respecting and protecting your privacy and the confidentiality of the information that you have entrusted to us and that we collect about you The purpose of this global privacy policy (the “Policy”) is to explain how and for what purposes we collect, use, share or otherwise process your personal information and how we safeguard its confidentiality, whenever you (“you” or “users”) use our Website, our Applications and our Products (the “Services”). By visiting and/or by using any of the Services, you agree to the terms of the present Policy.

MediaValet’s Privacy Policy is part of its wider terms of service that also include our Terms and Conditions.

Scope
This Policy applies to the handling of personal information and to other non-identifiable information gathered by MediaValet when you are using or accessing the Services. It does not apply to any applications or websites developed by third parties that MediaValet does not own or control (“Third-Party Apps”). If you follow a link to a third-party website, that third party will have its own privacy policies, which you should review before submitting any personal information.

What types of Personal Information do we collect, and how?
When used in this Policy, personal information means “any information about an identifiable individual”. We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. We collect personal information, as defined below, in a variety of ways either directly from you, automatically through our websites and mobile applications or from other sources.

Directly from you

When you create a MediaValet account and then update your user profile, we may collect some personal information such as:

• name, username, and email address;
• password, in connection with your account and your log-in facility;
• geographic area where you use your computer and mobile devices; and
• other optional information as part of your account profile.

MediaValet may also gather personal information via various methods (phone, email, online forms, in-person meetings) should you voluntarily communicate such information to us.

Through Our Websites and our Platforms
System and Device Information
MediaValet automatically collects and receives certain information from your computer or mobile device, including the activities you perform while using the Services, the type of hardware and software you are using (such as, your operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable) (collectively referred to as “traffic data”). We may link this traffic and usage data to your unique MediaValet user ID to better understand your needs and the needs of users, diagnose problems, analyze trends, provide services, improve the features and usability of our Services, and better understand and market to our customers and website users.

MediaValet also makes use of non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services and Website pages in order to introducing improvements and improve usability of our Services. We may share this type of statistical data so that our partners may also understand how often people use our Services, so that they, too, may provide you with an optimal experience.

Cookies and Related Technologies
MediaValet uses tracking technology (“cookies”) on the Website, in the Applications, and in the Products. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text files placed on your device when you visit a web site, in order to track use of the Services and to improve your user experience. For more information, you can consult our Cookie Policy.

From Other Sources
We may receive personal information from other sources with your consent, such as from our Affiliates and Business Partners, or if the law requires or permits us to do so (e.g., to meet our anti-money laundering compliance or other legal and regulatory obligations).

In order to ensure the accuracy of the contact information that you provide us, such as your name, email address and phone number, we may retain the services of a service provider to verify and, if necessary, update, complete or otherwise supplement your contact information by providing us with such additional information. This helps us protect you against error and fraud, and to manage our business operations by ensuring that we can reach you in case of an issue in connection with our programs, products or services, or as otherwise permitted by applicable law, as described below in the “How Do We Use Personal Information” section.

How do we use your Personal Information
MediaValet uses the collected information for the following purposes:

• To provide you with the Services, including upgrades and related services and support;
• To maintaining business relationships and communicating with you as a business contact, about MediaValet’s activities and services;
• To provide you with targeted advertising to promote our Services, if you have shown such interest;
• To trace any fraudulent or criminal activity or any activity in violation of the Terms, and thus, prevent unauthorized access to your personal information.

When do We Share your Personal Information?
Except as provided in this Policy, MediaValet does not share any personal information gathered via the Services to third parties. As such, we may share information we have collected about you or that you have submitted when authorized by law, with our partners and service providers that are retained to perform work on our behalf or who participate in the provision of our services, as well as in the context of a business transaction.

MediaValet may transfer your personal information to third party service providers, partners and affiliates located abroad, including in the United States. These service providers assist us with the operation of the Website and the provision of our Services as well as with our marketing and business communications effort. As a result, your personal information may be accessed by the courts, law enforcement and public authorities of such countries pursuant to local legislation.

More details

• Affiliates and Business Partners.
  Subject to the user’s rights under Your Rights section of this Policy, MediaValet may share personal information with its affiliates, subsidiaries and partners.We may also share your professional contact details with our technology partners when you have indicated that you may be interested in one of their products or services.
• Third Party Service Providers.
  We may hire service providers to perform services on our behalf. We provide them with a limited amount of information which is necessary in order for them to provide the services required. We ensure that they have entered into contractual arrangements that provide adequate protection of your personal information. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide.
• As Permitted or Required by Law.
  From time to time, MediaValet may disclose your personal information if such disclosure is necessary for the establishment, exercise or defense of legal claims, as part of the administration of our loss prevention program, or as otherwise permitted by law. For example if MediaValet is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid summons, search warrant, government investigation, other legally valid request or investigation or if reasonably necessary to protect the rights, property and safety of others or ourselves. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or to law enforcement and emergency services providers, in an emergency or where required or permitted by law, or if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights of any person.
• Business Transactions.
  We may disclose personal information to a third party in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business, business unit or property, or other fundamental corporate change, whatever form it may take. However, in the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information.
• Other third parties
  We may also disclose personal information when you explicitly consent to its disclosure to a third party. For exemple, when connecting to a third-party service that asks you if you consent to such sharing or when we organise joint events with a third-party.

What are your privacy choices?
You have choices about the way MediaValet handles your personal information.

1. Changing your communication preferences
   You can always choose not to receive marketing or promotional messages from MediaValet by email by clicking on “unsubscribe” in any email you receive.Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you a customer service message, important product information, service notification or recall). In addition, it may take up to ten (10) business days to register a change of preference across all our records.
2. Changing your browser settings on your device
   We use technology to enhance your client experience and present you with offers, including personalised advertising. Through technologies such as cookies, our websites recognize you when you use or return to them and can provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features on our websites.Please refer to your browser instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device. You can also use the quick links below, depending on the type of browser that you are using: Internet Explorer, Google Chrome, Microsoft Edge, Firefox and/or Safari.Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Services. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.Please review our Cookie Policy for additional information.
3. Restricting collection, use and disclosure of your personal information
   You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Policy at any time upon reasonable notice to MediaValet in writing, subject to legal or contractual restrictions.The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing consent.

How do we protect your personal information?
MediaValet has implemented reasonable technical, organisational and administrative measures to protect your data from unauthorized access, loss or theft, modification and other threats. Personal information is protected by security safeguards that are appropriate to its sensitivity. Our employees, affiliates and third party providers are required to sign contracts obliging them to protect the privacy and confidentiality of personal information provided to them and to observe the intent of this Policy. Appropriate controls are in place over our systems and these controls are reviewed on an ongoing basis to ensure compliance with this Policy.

Children
Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of Minimum Age, depending on where the individual accesses the services. By default, MediaValet considers such Minimum Age to be 18 years old. However, if applicable laws require that you must be older than 18 in order for MediaValet to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.

How long do we keep your Personal Information?
We only retain your personal information for as long as necessary to fulfill the purposes identified in this Privacy Policy. However, some personal information may need to be retained by MediaValet for a period of time following cancellation of your account where it is necessary for our legitimate business purposes or required by applicable law.

Your Rights
You can contact our Privacy Officer to obtain a copy of the personal information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct that information. As mentioned above you have a right to change your email preferences at any time.

In addition, in some cases you may ask us to delete your personal information. You can also object to specific personal information being processed and request that the processing of your personal information be limited. Please note that the limitation or deletion of your personal information may mean we will be unable to provide the Services described above. You also have the right to receive your personal information in a machine-readable format and have such data transferred to another party responsible for data processing. If you disagree with how we process your personal information, you are also entitled to report this to the competent supervisory authorities in the European Union.

EU Notice
If you are in the European Union, please note that this section applies to our processing of your personal information in addition to the other terms of this Privacy Policy. Any reference to “personal information” in this notice should be understood as referring to “personal data”, defined under the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

MediaValet as a data controller processes your personal information in compliance with the requirements of the GDPR, as amended from time to time.

In addition to the rights mentioned under Your Rights, you have the following rights:

• Delete your personal information: You can ask us to erase or delete all or some of your personal information (for instance, if it is no longer necessary to provide our services to you).
• Object to or restrict our processing of your personal information: You can ask us to stop using all or some of your personal information (for instance, if we have no legal right to keep using it) or to restrict our use of it (for instance, if your personal information is inaccurate).
• Right to portability: You can ask us to provide a copy in machine-readable form of the personal information that you have provided us.

If you wish to exercise any of these rights, please use the contact information listed in the Contact us section below. You also have the right to file a complaint with the supervisory authority in the EU Member State where you are located or where the relevant

California notice
This California notice supplements the Policy set forth above with respect to specific rights granted under the California Consumer Privacy Act (“CCPA”) to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.”

Terms used in this California notice have the meaning ascribed to them in the CCPA. We are a “business”, and “Personal information” for the purposes of this section has the same meaning as in the CCPA. For purposes of this California notice, personal information does not include deidentified information, aggregate consumer information, or publicly available information as those terms are defined in the CCPA.

California Residents’ Rights under the CCPA
The CCPA provides California Residents with certain rights related to their personal information. This section explains those rights. If you are a California Resident and would like to exercise any of those rights, please see How to Exercise Your CCPA Rights below for more information on how to submit a request, subject to certain exemptions and other limitations under applicable law.

• Notice: You have the right to be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
• Right to Know: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months.
• Right to Delete: You have the right to request that we delete some of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with federal, state, local and non-U.S. laws, rules and regulations.
• Right to Non-discrimination: We will not discriminate against you for exercising of any rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
• Opt-Out of Sale: You have the right to opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. For more information about how we collect, use and disclose this information, please refer to our U.S. Privacy Policy. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA.

How to Exercise Your CCPA Rights
If you are a California Resident and would like to exercise any of the CCPA rights identified above, you may submit a request by writing to privacy@mediavalet.com.

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Right to Know or a Right to Delete request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, [your name and email address.] Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Right to Know or a Right to Delete request on your behalf and have that authorized agent submit the request through the aforementioned methods. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

We will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election. Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. Keep in mind that we are not required to provide information in response to Right to Know requests more than twice in a 12-month period and any response to a Request to Know will only cover the 12-month period preceding the verifiable request.

Additional California Privacy Rights
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our sites are not currently set up to respond to those signals.

Changes to the Policy
We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our websites. If we make any significant changes to the Policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The “Effective Date” at the top of this Policy indicates when it was last updated. The current version of the Policy can be found here.

Contacting us
MediaValet uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You can manage your email preferences, such as opting-out or unsubscribing from emails sent by contacting support@mediavalet.com. You may also opt out or unsubscribe from any future email communications from using a link provided in each email correspondence that we send you.

If you have any questions about this Policy, please contact our Privacy Officer at:

MediaValet Inc.
990 Homer Street, 5th Floor
Vancouver, BC V6B 2W7
Canada

Attention: Privacy Officer
Email: privacy@mediavalet.com