Privacy Policy

Effective Date: June 30, 2020

This Privacy Policy describes how Test 222 VerticalScope Inc. and its subsidiaries and corporate affiliates (collectively, "VerticalScope", "we", "us" or "our") collects information through our websites and mobile or other applications on which this Privacy Policy is posted (collectively, the "Sites") and, subject to the privacy policies of those third party platforms, through our accounts on various third party social media platforms. This Privacy Policy also describes how we may use and disclose this information and the rights you have with respect to your information.

Quick Links

Click on one of the links below to jump to the listed section:

1. Information we collect
2. How we use the information we collect
3. Cookies, tracking technologies and interest-basedadvertising
4. How we disclose your information
5. How we store and protect your information and information retention
6. Links to external content
7. Children
8. Your Rights and Choices
9. International Users
10. Notice for California Residents
11. How to contact us

1. Information we collect

We collect different categories of information from and about you from different sources, as described in more detail in this section.

Information Provided By You

We collect information you provide to us directly when you use our Sites. This includes:

• Account Information: To create an account, we collect your username, email address and/or telephone number, and password. For some Sites you may be required or permitted to provide additional information such as your date of birth, gender, age or other similar information. We collect additional information that you choose to add to your account or public user profile, such as a profile picture or information about your hobbies, interests, activities, or property (such as the type of vehicle you own). Your username is public, and other account information may be public depending on how your account profile is configured.
• Transactional information: We may collect your name, contact information and payment card information when you purchase a product or service through our Sites (such as a subscription or classified advertisement). Payments are processed and stored by third-party payment processors (e.g., Stripe and Braintree), so please refer to the applicable processor's terms and privacy policy for more information about how payment information is processed and stored.
• Content you post or submit: Our Site may offer public forums or communication platforms that allow you to communicate with other users, post information (e.g., questions, project descriptions, information about your job/role), content, images, photos or videos, post your opinions on surveys, or submit reviews or ratings (collectively, your "Content"). Your Content will be associated with your public user profile. Your Content and public user profile is public, unencrypted and non-confidential. This means that it can be read and used by others, including advertisers. We are not responsible for the information you choose to submit in these public areas. You should exercise caution when deciding to disclose information in public areas of our Site. We strongly recommend against disclosing any sensitive information that could directly or indirectly be traced to any individual, including yourself.
• Other information: We may collect information with your consent, where required or permitted by law, or when you choose to provide other information directly to us. For example, we may collect information when you fill out a form, participate in a survey, poll, contest or promotion, apply for a job, request customer support or otherwise communicate with us.

Information We Collect Automatically

When you use or access our Sites, we may also automatically collect information about you from your device. This includes:

• Geographic Location: We collect general geographical location information if the Site you are using is location-enabled and your device transmits location data and/or your IP address. This enables us to provide location-specific information to you.
• Usage Data: We may log certain information when you access and use our Sites. This may include your IP address, user-agent string, browser type, operating system, referral URLs, device information (e.g., device IDs), pages visited, links clicked, the requested URL, hardware settings, and search terms. See Cookies, tracking technologies and interest-based advertising below for more information.
• Information collected from cookies and similar technologies: We, our service providers and third-party advertising partners also collect information about users of the Sites automatically using cookies and other tracking technologies. See Cookies, tracking technologies and interest-based advertising below for more information.

Information We Collect From Third Parties

We collect the following information about you from third parties:

• Third Party Networks: If you use a third party network (including a social media account) to create an account on our Site, to log-in to our Site, or if you otherwise interact with a third party network through our Site (such as by using a plug-in offered by that third party), we will receive information from the third party network, such as your username, email address, gender, public profile information and any other information that you have agreed to disclose to us, whether explicitly or through your privacy settings. You should consult the respective privacy policies of these third-party networks for information about their practices.
• Other sources: We may also obtain information about you, such as demographic information, from various third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you with our brand and improve our products, analytics, and advertising.

2. How we use the information we collect

We generally use the information we collect about you to operate, manage and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including:

• to administer and manage our Site and provide our services, such as to create and administer accounts and facilitate the use and enjoyment of forums and communication platforms;
• to enable geographic-specific features, such as geographic-specific information;
• to provide the product, service, feature or information you have requested and to fulfill your transactions, including to process payments;
• to send you administrative messages, updates, legal notices, technical notices or security alerts;
• to customize your user experience and to personalize the services of VerticalScope and our ad partners and provide you with content of interest, including by tailoring the advertisements that are displayed to you to make them more useful and relevant to you;
• to conduct research and development, analyze and understand trends and user behaviour and to improve our Sites, products and services;
• to provide customer service, technical and other support;
• to protect the safety of VerticalScope and our users, including to ensure compliance with our Terms of Use and other policies, block suspected spammers, address abuse, and detect and prevent fraud;
• to provide you with newsletters, information, promotional offers and other advertising about us or our advertising partners;
• to facilitate your participation in a contest or similar promotion, or a survey or poll;
• to meet contractual obligations;
• to facilitate corporate transactions;
• to exercise our rights, defend legal claims and comply with law, legal process and internal policies; and
• for other purposes with your consent or as permitted or required by law.

Legal bases for use of your information: The laws in certain jurisdictions require us to tell you the "legal bases" on which we process your information. Our legal bases for using your information as set out in this Privacy Policy are as follows:

• Where use of your information is necessary to perform our obligations under a contract with you (for example, to comply with: the Terms of Use of our Sites or to fulfill a purchase you made)
• Where use of your information is necessary for our legitimate interests or the legitimate interests of others (for example, to provide security for our Sites and applications; operate our business and our Sites; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud and to know the customer to whom we are providing the Sites)
• Where we have a reason to process the data in accordance with applicable laws (e.g., to comply with applicable accounting rules and to make mandatory disclosures to law enforcement)
• Where we have your consent to engage in a particular processing activity (e.g., such as where legally required, we obtain your consent to send you marketing communications or newsletters, or to provide your information to specific third parties). With respect to users in Canada, we obtain your consent (express or implied) for all processing of your personal information, except where processing without consent is permitted or required by law. Note that your consent may subsequently be withdrawn at any time, subject to limited exceptions, (by emailing privacy@verticalscope.com ) without affecting the lawfulness of processing based on consent before its withdrawal.

We may aggregate and/or de-identify information collected through the Sites. To the extent permitted by applicable laws, we may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, promotional partners, sponsors, and/or others.

3. Cookies, tracking technologies and interest-based advertising

We, our service providers and third-party advertising partners use technologies that automatically collect information about Site visitors and their visits to the Sites, as described below.

Specifically, we automatically collect information about how you access, navigate and leave our Site, including the website you came from before visiting our Site, what browser type and operating system you are using, the internet protocol (IP) address you are accessing the Site from, your mobile device ID or Advertising ID if you visit our Site from a mobile device, the pages of our Site that you are navigating through, the date and time of your visit, how long you spend on our Site or certain pages of our Site, and what website you go to after visiting our Site. This information may be used to determine how many visitors visit our Site or certain areas of our Site, how long they remain on our Site, whether they use the hyperlinks we provide or respond to advertising and to tailor our advertisements to you. We may disclose this information to partners who referred you to our Site, and with advertising partners, who may use the information to optimize the traffic they send to us and for delivering targeted ads to you when you visit other websites.

We, our service providers and third-party advertising partners collect information about Site visitors using cookies and other tracking technologies (including browser cookies and pixels). We use these technologies to remember your preferences and facilitate your navigation of our Site. We and our service providers and third-party advertising partners also use these technologies to track your activities on our Site and other websites, including the websites and web pages that you visited, the ads or content that you clicked on, any items you may have purchased and the search terms you used, in order to deliver tailored advertising to you. We may also disclose a unique identifier linked to you (such as a hashed or encrypted version of your email address or telephone number) with advertising partners so that you may be served with tailored advertising on our websites or other third party websites. However, you may opt out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you by visiting Digital Advertising Alliance of Canada Opt-Out Page , Your Online Choices from the European Interactive Digital Advertising Alliance , NAI Opt-Out Page and the Ad Choices Opt-Out Page.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

We use Google Analytics to help us understand how our Site visitors use the Site, and as well as certain features of Google Analytics Display Advertising to advertise online, sell advertising and to develop content. You can opt out of your usage data being included in our reports from Google Analytics and customize Google's Display Network ads. Please visit Google's Ad Settings and Google Analytics Opt-out Browser Add-on . Please visit How Google uses data when you use our partners' sites or apps for a description of how Google uses information sent by our browser and for ways you can control the information sent to Google. We also use certain third parties to engage in certain targeted advertising activities across our Sites. To opt out of LiveRamp's targeted advertising activities, please visit https://liveramp.com/opt_out/ . To opt out of Google's Publisher provided identifier (PPID) targeted advertising , please click here . To opt out of Amazon's Targeted Advertising (Amazon ID) , please click here . To opt out of Liveintent Targeted Advertising (Liveinvent ID) please click here.

For additional ways to out of targeted advertising and related activities under applicable law, see the Your Rights and Choices section below.

4. How we disclose your information

We may disclose information we collect about you in the following circumstances.

Affiliates

We disclose information about you to our affiliates and subsidiaries under common ownership and/or control with us in accordance with applicable law.

Advertising partners

As described above in the Cookies, tracking technologies and interest-based advertising section, we may share certain information about your device and browsing habits with third-party advertising partners to present you with more relevant advertising about our Sites as you browse the Internet.

Service Providers

We may use service providers (including affiliates acting in this capacity) to provide services to us or to you on our behalf. For example, our service providers may host our Site, analyze data collected from our Site, provide customer service on our behalf, administer our promotions, facilitate and process transactions and payments, provide marketing or promotional assistance, distribute emails and other communications, post our advertisements (including online through targeted advertising campaigns), and collect your feedback on our Site and advertisements. We disclose your information to our service providers solely for the purposes of providing services to you and to us. They are not permitted to use your information for other purposes. Some of our service providers are located outside of Canada, including in the United States. While your information is located outside of Canada, it will be subject to legal requirements applicable to our service providers, for example, lawful requirements to disclose information to national security agencies or government authorities in certain circumstances. For Quebec residents, your personal information may be processed by us and our service providers outside of Quebec. Additionally, the parties to whom we may disclose your personal information as described in this privacy policy may also be located outside of Quebec.

Aggregate or de-identified information

As explained above, we may create aggregate or de-identified information that cannot reasonably be linked to you or your device. We may use and disclose this information for any purpose.

With your consent

We may disclose your information to third parties with your consent. For example, if you provide us with your contact information, such as an e-mail address, for the purposes of signing up for information, newsletters, contests, or marketing offers from a third party, or for receiving business offers or service quotes from a third party, we may disclose your information for that purpose. Once disclosed for these purposes, your information will be subject to the privacy policy of that third party.

Business Transactions

We may disclose your information to third parties in connection with the proposed or actual financing, securitization, insuring, merger, sale, assignment or other disposal of all or part of VerticalScope or our business or assets. These third parties may use the information for the purposes of evaluating and/or completing the proposed transaction and thereafter as a successor of our interests.

Other

We may disclose your information in other circumstances in good faith where permitted or required by law or other legal process. For example, we may disclose your information: (a) to collect a debt owed to us; (b) as necessary to comply with a subpoena, warrant, court order or other legal process; (c) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation or other legal process; or (d) if we have reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law, or to protect the personal safety of our users or defend our rights or property.

5. How we store and protect information and information retention

The security of your information is important to us. While we have implemented safeguards to protect the information we collect, no website or internet transmission is completely secure, and we cannot and do not guarantee the security of your information. We urge you to take steps to keep your information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when you have finished using a Site on a shared or unsecured device.

We maintain information on our servers (or those of our service providers). This information will be accessible to authorized employees, representatives and service providers as necessary for the purposes described in this Privacy Policy. Certain accounts you create on our Sites are password protected. If you create an account on the Site, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.

If you correspond with us by email, text message, or using web forms like a "contact us" feature on the Sites, you should be aware that your transmission might not be secure or considered confidential. A third party could view the information you send in transit by such means or we could disclose the information you send in accordance with this Privacy Policy. We will have no liability for disclosure of your information, including due to errors or unauthorized acts of third parties during or after transmission.

Information Retention: We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

6. Links to external content

Our Site may link or direct you to other websites, services or external content provided by third parties. We do not exercise any control over these third-party websites or services. We are not responsible for the privacy practices of such third-party websites or services. We recommend that you read the privacy policy for any third-party website that you visit or service that you use.

7. Children

Our Sites are not directed to and we do not knowingly request or collect "personal information" (as defined in applicable law) from children - persons under 13 years of age, or another age if required by applicable law - without prior verifiable parental consent. If we become aware that we have unknowingly collected personal information about a child without verifiable parental consent, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.

8. Your Rights and Choices

a. Information rights.

Depending on your jurisdiction, you may have the right to make certain requests regarding your "personal information" or "personal data" (as such terms are defined under applicable law, and collectively referred to herein as "personal information"). Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
• Provide you access to and/or a copy of certain personal information we hold about you.
• Correct or update personal information we hold about you.
• Delete certain personal information we have about you.

You may also have the right to opt out of "sales" of your information and "sharing/use of your information for targeted advertising" as described below in subsection c.

If you have an account with us, you can access and correct certain of the information in your account or public user profile by logging in to your account or profile and making the necessary edits.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our Sites to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request. If you would like further information regarding your legal rights or would like to exercise any of them, please submit your request using the information in the "How to contact us" Section below.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

b. Opting Out of Marketing Emails

You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions included in each communication and/or by selecting your communication preferences in your account or profile, if applicable. Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your account, activities, transactions and communications with us.

c. Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes

As explained in the "Cookies, tracking technologies, and interest-based advertising" Section above, we provide information about your device and online browsing activities to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our services, and related advertising analytics services. The disclosure of your information to these third parties to assist us in providing these services may be considered a "sale" of personal information under applicable law in the United States or the processing/sharing of "personal information" (as defined in applicable law) for targeted advertising purposes.

If you are a U.S. resident and would like to opt out of our online disclosure such as through cookie and pixel technology of your personal information for purposes that could be considered "sales" for those third parties' own commercial purposes, or "sharing" for purposes of targeted advertising, please click on the "Your Privacy Choices" icon accessible on the footer of the Site. Please note that you will need to exercise your choice on each browser and each device you use to access the Sites. Also, if you have certain settings selected in your browser (including pop-up blockers) you may need to re-configure those settings to adjust your settings. You can also submit a request to opt out of our offline disclosures of information (i.e., those not based on cookie/pixel technology) that are subject to applicable opt out rights by emailing us at privacy@verticalscope.com . Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Please note that if you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

9. International Users

The information discussed in this Policy is processed in Canada and the United States by VerticalScope, whose principal office in Canada. Our contact information can be found below. Your information will be processed in Canada and the United States for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise disclose your data to, affiliates or service providers in countries other than your country of residence in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to third party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EU and other data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as detailed in the "How to contact us" section below.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you reside. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

10. Notice for California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information about: (1) the purpose for which we use each category of "personal information" (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) "share" personal information for "cross-context behavioral advertising," and/or (c) "sell" such personal information. Under the CCPA, "sharing" is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites, and "selling" is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. As discussed above in the "Cookies, tracking technologies, and interest-based advertising" Section, our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a "sale" or "sharing" under the CCPA.

The following chart details these activities:

Category of personal information	Purposes of use	Categories of Third Parties to Which We Discloses this Personal Information	Categories of Third Parties to Which We "Share" and "Sell" this Personal Information for Advertising / Analytics Purposes
Contact and account information	Provide the Sites; Communicate with you; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions	Online advertising partners
Financial Account Information (collected by 3rd party payment processors on our behalf)	N/A -- we do not store	N/A -- we do not store	N/A -- we do not store
Transactional Information	Provide the Sites; Communicate with you; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Online Advertising Partners; Payment Processors; Entities for legal purposes; Entities for business transactions	Online advertising partners
Demographic Information	Provide the Sites; Communicate with you; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Online Advertising Partners; Payment Processors; Entities for legal purposes; Entities for business transactions	Online advertising partners
Customer service interaction information	Provide the Sites; Communicate with you; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions	We do not share/sell
Content submitted in online forums or to complete your profile (including images and videos you post)	Communicate with you; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions	We do not share/sell
Surveys and sweepstakes information	Communicate with you; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions	We do not share/sell
Information collected through automated technologies regarding your device and use of the Sites (including general location information)	Provide the Sites; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions	Online advertising partners
Inference data based on other information collected from and about you	Provide the Sites; Marketing and advertising; Personalize the Sites; Improve the Sites; Business Operations; With your consent	Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions	Online advertising partners

For more information about the categories of personal information we collect, how we use it, and how we disclose it, please see the "Information we collect," "How we use the information we collect," and "How we disclose your information" sections above in our Privacy Policy.

Your Choices Regarding "Sharing" and "Selling": You have the right to opt out of our sale/sharing of your personal information for purposes of online advertising and related activities through the use of cookies and pixels by clicking here. Please note that you will need to exercise your choice on each browser and each device you use to access the Sites. Also, if you have certain settings selected in your browser (including pop-up blockers) you may need to re-configure those settings to adjust your settings. To opt out of the offline disclosure of your information to third parties for these purposes, please email us at privacy@verticalscope.com .

Other CCPA Rights.

Our services may offer opportunities to receive certain services or benefits such as discounts or free services, which may require the provision of personal information (such as in connection with a survey). Such opportunities could be considered a financial incentive under applicable law (each, an "Incentive Program"). When you participate in an Incentive Program, you agree to the terms of that Incentive Program, if applicable, and may revoke your participation depending on the Incentive Program (e.g., by opting out of emails or participation in future surveys). To the extent we can determine the value of your information, we consider the value of providing you with a more personalized experience as well as the expenses we incur in providing Incentive Programs that are reasonably related to the costs associated with offering the Incentives.

The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

Please see the "Your Rights and Choices" section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Retention of Your Personal Information. Please see the " How we store and protect information and information retention " section above.

California "Shine the Light" disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.

11. How to contact us

If you have any questions or comments about this Privacy Policy, please contact us at privacy@verticalscope.com , or send mail to:

Test 222 VerticalScope Inc.
Attention: Privacy
111 Peter Street, Suite 901
Toronto, Ontario, M5V 2H1, Canada