Privacy Policy - Highlights

ARI TECHNOLOGIES INC. and our corporate affiliates (the “Company”,“we”, “us”, “our”) understands that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy. You can obtain more information about how we collect, use ,disclose and protect your personal information by reviewing our full PrivacyPolicy below.

What personal information do we collect?

·       We collect personal information directly from visitors to our website https://ari.life (the “Website”) and users of our social shopping community application “[Ari Life]”, and such other applications as may be made available from time to time (collectively, the “Application” and together with theWebsite and any software related thereto, the “Services”), including name, email address, postal address, online identifiers, and account name. Users may also provide additional information by choosing to fill out free-form fields on our Services, if any, and we may also collect and  generate information from your access and use of the Application such as performance data of the Application or Website (the “Usage Data”) (collectively, the “personal information”).

·     By using our Services, you are choosing to provide us with your personal information and you acknowledge and consent to the processing of your personal information in Canada.

·     We also use cookies on ourServices and automatically collect certain information about the way ourServices are used.

·     Our Services also collect users’ location information, [purchasing information, characteristics, preferences, and inferences drawn from other personal information].

Why do we collect personal information and how is it used?

·     We collect personal information to facilitate the use of our Services.

·     We also use the Usage Data in aggregate and de-identified form for research and evaluation purposes.

Is personal information shared or disclosed?

·     Personal information provided to us is never sold or rented to other organizations.

·     We also use certain third party service providers who may access to the information we collect.

·     We may also disclose or share personal information for fraud prevention, and other permitted disclosures under applicable law.  

How do we protect personal information?

·       We have implemented safeguards to protect personal information under our control, and regularly review our practices to ensure they align with reasonable practices appropriate to the level of sensitivity of the information, in order to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

What are the risks?

·    Although we take steps to safeguard the personal information under our control, "perfect security" does not exist online or elsewhere. In particular, we cannot guarantee the security of information posted or transmitted using our Services or via email. It is possible that third parties may unlawfully intercept or access such information.

What are your choices?

·       You may request access to and review of your personal information in our possession, subject to certain limitations.  

·      You may also request that we change or delete your personal information in our possession. We will make best efforts to comply with such requests, subject to certain limitations.

What else should you know?

·      We may use cloud services provided by third party service providers who may be outside Canada to store the personal information that we collect. This means that your information may be transferred to, or stored in, another country and accessible to foreign courts, law enforcement and national security authorities.

·       We may amend our PrivacyPolicy from time-to-time. Although we will notify you of major changes, we encourage you to check for updates.

·      You can contact us with questions, complaints or to access your personal information.


Privacy Policy

ARI TECHNOLOGIES INC. and our corporate affiliates (the “Company”,“we”, “us”, “our”) respect and uphold individual rights to privacy and the protection of personal information while balancing such rights with our need to process your personal information to manage our business and deliver our services to you.  Based on applicable privacy and data protection principles common to Canada and other jurisdictions to which we are subject to, we have developed this privacy policy (the “Policy”) to explain our practices for processing your personal information.  This Policy does not apply to our employees’ personal information or any anonymized information.

This Policy describes our practices with respect to how we may collect, use, disclose, retain, dispose and otherwise process (collectively, “process”) and how you may correct, update and access your personal information that you provide as a user of (a)our social shopping community application “Ari Life”, and such other applications as may be made available from time to time (collectively, the “Application”, (b) the website operated at [INSERT LINK], and other locations from time to time‎ (the “Website”), (c) any front-end software we provide you that interacts or interfaces with the Application or the Website (the “Software”),excluding third party software that may interact with the Application, Website or the Service as defined below, and (d) the services we provide through theApplication, Website and/or the Software (collectively, the “Service”). This Policy references the general Terms of Use for the Company delivered to you through email prior to your use of our Application, Website, Software or Service, and forms an integral part of it. All capitalized terms not otherwise defined herein have the meaning provided in our Terms of Use.

Our Application, Website and Software may contain links to other applications or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting anotherInternet resource. We have no responsibility or liability for, or control over, those other Internet resources or their collection, use and disclosure of your personal information.  We encourage you to read the privacy policies of those other Internet resources to learn how they collect and use your personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.  By using our Application, Website, Software, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in Canada in accordance with this Policy and as may be further identified when the personal information is collected. If you are located or residing outside of Canada, please be aware that our Application, Website, Software and Service are intended for and directed to users in Canada, and the privacy laws and principles in Canada may differ and not offer the same level of protection as those in your location or residing country/region.  Through your continued use of our Application, Website, Software or Service, you are transferring your personal information to Canada and you expressly consent to that transfer. We will use this consent as the legal basis for such data transfer, unless otherwise stated in this Policy.  

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Application, Website, Software or Service or otherwise provide any personal information to us.

1. PersonalInformation

For the purposes of this Policy, “personal information” means any identifiable information about an individual, including but not limited to an individual’s name, home address, telephone number, email address, except any other information otherwise exempted by the applicable laws of Canada and other jurisdictions.  For example, in Canada, personal information does not include any business contact information that is processed solely to communicate with that person about his or her employment or profession.

When you use our Application, Website, Software or Service, we may collect the following personal information from you:

·      Contact information such as name, email address, mailing address, and phone number;

·      Unique identifiers such as username, account number, and password;

·      Usage Data;

Your personal information may be collected when:

·      You register for an account with us;

·      You connect with us through social media;

·      You interact with and use the Application, Website, Software or Service or share information to others;

·      You shop using our Service;

·      We collect data from third parties or publicly available sources.

We only collect personal information that we need.  We encourage you to not provide us with any personal information beyond what is necessary and as requested by us.

Collection from Third Parties

We do not knowingly collect your personal information from a third party unless you consent or we are otherwise exempted, required or permitted by applicable laws to do so.  

If we collect your personal information from a third party, we will only process that information for the specific purpose for which it was provided to us in accordance with this Policy and the policy under which that information was collected.  

Links to Other Sites

To the extent that our Application orWebsite contains links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party applications.

Information about Minors

The Application and Website are intended solely for users who are not minors (19 years of age or older).

We do not knowingly collect personal information about any minor.No such minor, nor any parent or guardian as it relates to such minor, should submit such minor’s personal information to us through the Application,Website, Software or otherwise for any reason and under any circumstances.  

 

2. Purpose for Which Personal Information is Processed

We may process your personal information for the following purposes (the “Purposes”):

·      To verify and authenticate your identity;

·      To ensure that the Application, Website, Software or Service is optimized for your use and benefit;

·      To analyze user experience and improve the Application or Website;

·      To operate, maintain and provide to you the Service, features and functionality of the Application Website, or Software;

·      To improve the quality and design of the Service;

·      To create new features, functionality, and services;

·      To provide customized content and services, including advertising and promotional information, such as targeted ads, retargeted ads, recommend content you might like, and cross-app or cross-site functionality across third party applications and websites;

·      To market and promote our Services to you and others;

·      To communicate with you to provide you services, contacts, materials and/or recommendations for your needs as identified by you through phone, email, or the Application or Website;

·      To carry out our obligations arising from any contracts entered into between you and us;

·      [To process commissions, payments and reports];

·      [To create consumer profiles];

·      [To perform research and analysis on your use of the Services];

·      To comply with internal policies and procedures and other legal, accounting, or security requirements;

·      To share your personal information with our employees, contractors, consultants and other third party service providers such as application hosting providers, advertising agencies, payment processors or customer service agencies (“Third PartyProcessors”) who require this information to assist us with establishing, maintaining and managing our relationship with you and optimizing and providing the Application, Website, Software or Service for your use and benefit. Please note that we may change or add Third Party Processors at any time, in our sole discretion, either in Canada or elsewhere. We encourage you to reference thisPolicy from time-to-time, to obtain updated information. Given the nature of cloud services, personal information may be stored outside Canada, anywhere in the world, and may be accessible to foreign courts, law enforcement and national security authorities in the jurisdiction(s) where it is transferred or stored.

We will only process your personal information for the Purposes for which we intend to process such information.  Otherwise, we will not process your personal information without your consent.

3. Disclosure of Your Personal Information

We may disclose your personal information for the Purposes as described in this Policy in the following ways:

·      To our employees and contractors;

·      To our business partners;

·      To our service providers including application hosting providers, advertising agencies, payment processors and customer service agencies; and

·      To law enforcement, government or regulatory bodies, or other lawful authorities.

Your personal information that we collect may be processed outside of Canada but only in relation to the Purposes. As a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with other jurisdictions’ applicable laws.

4. LegalBasis for Processing Your Personal Information

Consent

We will process your personal information only with your knowledge and consent, except where exempted, required or permitted by applicable laws. The form of consent may vary depending on the circumstances and the type of information being requested.  Your consent may be express with clear options to say “yes” or “no”, such as by being asked to check a box to indicate your consent, or implied, such as when you provide us with your address through a form or email seeking information and we use those means to respond to your request.  Your consent can also be provided by your authorized representative. Taking into account the sensitivity of your personal information, purposes of collection, and your reasonable expectations, we will obtain the form of consent that is appropriate to the personal information being processed.  By using our Application, Website, Software, or Service, or otherwise by choosing to provide us with your personal information, you acknowledge and consent to the processing of your personal information in accordance with this Policy and as may be further identified when the personal information is collected.  When we process your personal information fora new purpose, we will document that new purpose and ask for your consent again.

If you do not consent to the processing of your personal information in accordance with this Policy, please do not access or continue to use any of the Application, Website, Software or Service or otherwise provide any personal information to us.  

You may refuse to provide consent or may notify us at any time that you wish to withdraw or change your consent to the processing of your personal information without penalty, subject to legal or contractual restrictions and reasonable notice by (i) changing your privacy preferences through the Application, Website,  orSoftware, (ii) deleting your account with the Application, Website, or Software and stopping use of the Application, Website, or Software, (iii) opting out of the use of your personal information by contacting our Privacy Officer (seeSection 10 below).   However, if you withdraw or change your consent, we may not be able to provide you with theService through the Application, Website, or Software.

OtherLegal Bases

Aside from consent, we may also process your personal information under other legal bases, as permitted by the applicable laws.  

5. Cookies/ Opt Out

You have choices about how your data is collected, the ability to delete certain data, and the ‎ability to ‎close your account.‎ [NTD to Client: To confirm or advise as to applicability of cookies and tracking through Website andApplication]

Cookies,Flash Cookies and Other Tracking Technologies - You may be able to delete and/or turn off cookies, flash cookies or scripting‎functionality as your browser or device permits. ‎Unless ‎you block or control cookies or flash cookies going forward, deleting cookies will only address cookies or flash cookies on ‎your device at ‎that moment. If you disable cookies, flash cookies or scripting ‎functionality entirely, the Services may not ‎function properly. Please note ‎that other tracking technologies, such as device fingerprinting, are ‎not stopped or impacted by turning off ‎or deleting cookies, flash cookies, or scripting ‎functionality, respectively.‎‎

OptingOut from Interest-Based Ads - Depending on your jurisdiction and applicable law, you may be able to opt-out of interest-based advertising, by accessing and indicating your preference on the relevant opt-out platform.Your browser must accept third-‎party cookies before opting out. Please note that if you disable the display of ‎personalized ads ‎from us and other advertising partners, you will continue to receive ads that ‎are less ‎relevant to your interests/browsing behavior.‎

Effect of Opting Out - You will need to renew your opt-out choice if you use a different device, ‎use a ‎different browser, or erase cookies from your browser.‎ You may also choose to close your account at any time.‎

6. Security of Personal Information

The security of your personal information is important to us. We protect personal information using physical, technological and organizational safeguards. We regularly review our practices to ensure they align with reasonable industry practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

However, no method of transmission over the Internet, or method of electronic storage, is completely secure; as such, despite our safeguards and protocols, we cannot fully guarantee the security of your personal information and you should always exercise caution when disclosing personal information over theInternet.

7. Requests for Access to and Correction of PersonalInformation

Applicable privacy laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. You may request access to and review of your personal information in our possession. However, access may be declined where permitted or required by applicable law.

You may request that we change or delete your personal information in our possession. We reserve the right not to change any personal information if we do not agree that it is inaccurate or outdated, but will append any alternative text the individual concerned believes appropriate.

If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal. [NTD:will California or UK residents be accessing the services?]

8. CASL Policy

We are committed to compliance with Canada’sAnti-Spam Legislation (“CASL”).   Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including theCanadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting and updating thisPolicy, we undertake various transparency initiatives to ensure we comply with CASL, which include:

·      Consent—we do not send you CEMs without your consent. This consent typically must be“express” (expressly acknowledged by you), but in certain circumstances can be“implied” or specifically exempt from consent requirements.  We modified or adopted our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as per CASL.  When we collect your electronic contact information, you will know the exact purposes behind the collection.

·      Content—we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:

o   Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;

o   Provide you with our contact information; and

o   Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).

·      Clarity—we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.

If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within10 business days.  If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 11below.

9. Retention of Your Personal Information

We generally keep personal information for only as long as it is needed to accomplish the purposes for which it was collected, or as needed for authorized or legitimate purposes.  More specifically, we retain personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws or protect our interests. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, we will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We use reasonable industry practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to personal information.

10. Updates or Changes to this Policy

This Policy was last updated on March 18, 2021. We will occasionally update this Policy and revise the "last updated" date appearing in this paragraph.

If we make any material changes we will either (a) notify you by email (sent to the email address listed in your account), or (b) provide a notice on the Application, Website or otherwise through the Service before the change becomes effective. Any change to this Policy will apply to existing information, as well as information collected onwards from the date that thisPolicy is posted or on the date as specified in the notification. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you are aware of any changes.  Your continued use of the Service signifies your acceptance of any changes to this Policy.

11. ContactInformation for Privacy Officer

You can direct any questions or concerns regarding our compliance with this Policy and our processing of your personal information to our PrivacyOfficer by emailing privacy@ari.life.

If you are not satisfied with our Privacy Officer’s response to your question or concern, you may be able to file a complaint under applicable privacy laws.  Our Privacy Officer will provide you with the contact information to do so if requested. We strive to offer an accessible and simple complaint procedure. We will promptly investigate all complaints received, and if a complaint is justified, we will take the necessary steps to resolve the issue in question.

End of Policy