Last revised: March 13, 2025

PRIVACY STATEMENT

NetNow Financial Inc. and its affiliates (collectively, “NetNow”, “we”, “our” or “us”)

recognize the importance of privacy. The purpose of this Privacy Statement is to inform you

about our privacy practices, including how we collect, use, and disclose your personal

information.

What This Privacy Statement Covers

This Privacy Statement covers the following topics:

 Personal Information We Collect

 How We Use Your Personal Information

 How We Share Your Personal Information

 Your Consent to the Collection, Use and Disclosure of Your Personal Information

 Our Use of Cookies

 Opting Out of Marketing Communications

 Retention, Storage, and International Transfer of Personal Information

 Information Security

 Accessing and Updating Your Personal Information

 Third-Party Websites and Services

 Children’s Personal Information

 Changes to this Privacy Statement

 How to Contact Us

Personal Information We Collect

“Personal information” means information about an identifiable individual as described under

applicable privacy laws.

Personal information does not include any business contact information that is solely used to

communicate with you in relation to your employment, business or profession, such as your

name, position name or title, work address, work telephone number, work fax number or work e-

mail address.

This Privacy Statement does not apply to the extent we process personal information in the role

of a processor or service provider on behalf of our customers. It is that customer’s privacy

statement that applies; we conduct such activities strictly in accordance with our customer’s

instructions and pursuant to our contractual arrangements with the customer. If you are an end

user or consumer with an existing relationship with one of our customers, you should refer to the

customer’s website to understand their privacy practices and policies.

We may collect, use, and disclose different types of personal information, depending on our

relationship with you. Generally, we collect the following types of personal information (not all

of which may apply to you):

 identity information, such as your name, username or similar identifier, and information

about the company you work for;

 contact information, such as your billing address, delivery address, e-mail address and

telephone numbers;

 financial information, such as your billing information, and payment card details used to

purchase products or services;

 technical and usage information when you use our website, such as your internet protocol

(IP) address, login data, browser type and version, time zone setting and location,

browser plug-in types and versions, operating system and platform and other technology

on the devices you use to access our website;

 event participation information, such as your enrollment and attendance at our events;

 information provided to us when you interact with us, including individuals who interact

with us, whether in person, by phone or e-mail, through social media or otherwise;

 information provided via surveys and contests; and

 marketing and communications information, such as your preferences for receiving our

newsletter.

We also collect, use, and share aggregated and anonymized data for any purpose, including

usage data relating to a group or category of services, features or functionality on our website or

technological application. Usage data helps us understand how our products and services are

being used and allows us to optimize and improve our product and service offerings or develop

new ones. Aggregated and anonymized data is not considered personal information because it

cannot be used to identify you.

How We Use Your Personal Information

We generally use your personal information for the following purposes:

 to determine your eligibility for our products and services in accordance with applicable

laws and our policies;

 if you use any of our technology applications, to administer your use of those

applications;

 to monitor the usage of our products and services to support their proper functioning and

further improvement;

 to respond to your inquiries, complaints or requests;

 to communicate with you through our newsletter or other forms of communication;

 to manage our business and our arrangements with our clients, including to detect and

prevent errors and fraud;

 to improve the effectiveness and efficiency of our operations, products, services, and

programs;

 to investigate legal claims and protect our rights, operations or property;

 to generate anonymized or aggregated information relating to your use of our products

and services;

 to send you marketing and advertising content (where we have consent to do so);

 for such other purposes as you may consent to from time to time; and

 as otherwise required or permitted by law.

How We Share Your Personal Information

We generally identify to whom, and for what purposes, we will disclose your personal

information (and we obtain your consent to such disclosure) at the time we collect your personal

information.

We may disclose your information when we believe such disclosure is required or permitted by

law. In addition, we may disclose your personal information to a third party in the event of any

significant business transaction, such as a merger or reorganization.

We rely on service providers to perform a variety of services on our behalf, such as payment card

processors, technical support providers, research and analytics providers, and data hosting,

storage and processing service providers. If we transfer your personal information to a service

provider, we require that they maintain the confidentiality of your personal information and keep

it secure. We do not authorize the service providers to disclose your Personal Information to

unauthorized parties or to use your Personal Information for their direct marketing purposes.

We may may share your Personal Information and other information to a third party in the event

of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all

or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business

transaction.

Your Consent to the Collection, Use and Disclosure of Your Personal Information

We collect, use, and disclose your personal information with your consent or as permitted or

required by law. How we obtain your consent, including whether it is express or implied, will

depend on the circumstances and the sensitivity of the personal information in question.

Generally, we will seek your consent at the time we collect your personal information, either

orally, electronically, or in writing.

If you provide personal information about another individual to us, it is your responsibility to

obtain the consent of that individual to enable us to collect, use and disclose their information as

described in this Privacy Statement.

If you wish to withdraw your consent to our collection, use or disclosure of your personal

information, please contact us using the contact information in the “How to Contact Us” section

below. We will accommodate your request to withdraw consent, subject to legal or contractual

restrictions. Withdrawal of your consent may mean that we will no longer be able to provide you

with certain products or services.

Our Use of Cookies

A “cookie” is a small text file that contains information and is stored on your computer. We use

cookies and similar tracking technologies, such as web beacons and pixels, to automatically

collect information about your use of our website and your interaction with our emails.

Information we collect may include your IP address (or proxy server), device and application

identification numbers, location, browser type, internet service provider and/or mobile carrier,

pages and files viewed, searches, operating system and system configuration information, and

date/time stamps associated with your usage.

We use this information to facilitate the use of our website, for our business or analytical

purposes (including to assess website traffic and track search criteria), and to personalize web

pages according to your choices and interests.

We may also use this information to engage in interest-based advertising (also known as targeted

We do not use your personal information to engage in interest-based or behavioral advertising of

our services across third-party websites or service offerings.

If you do not wish to accept cookies, you can adjust your web browser settings so that you

automatically deny the storage of cookies or are informed each time a website requests to store a

cookie. Previously stored cookies can also be deleted through your web browser. Please refer to

your web browser’s help pages for more information. Some areas or features of our website rely

on cookies and may not work if you delete or decline cookies. For more information about

cookies generally please visit www.allaboutcookies.org.

Opting Out of Marketing Communications

If you no longer want to receive marketing-related e-mails from us, you may opt out by clicking

the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by

contacting us directly using the contact information in the “How to Contact Us” section below.

If you opt out from receiving marketing-related e-mails, we may still need to send you

communications about your use of our products or services, or other matters.

Retention, Storage, and International Transfer of Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for

which we collected it, and as permitted or required by law.

We may transfer your personal information outside of Canada to fulfil the purpose for which we

collected it, including for processing and storage by service providers. While your personal

information is outside of Canada, it is subject to the laws of the country in which it is located,

which may have different data protection laws than Canada. Those laws may require disclosure

of your personal information to authorities in that country. For more information about our

policies and practices regarding service providers outside of Canada, contact us using the contact

information in the “How to Contact Us” section below.

Information Security

We have implemented physical, organizational, contractual, and technological security measures

in an effort to protect your personal information from loss or theft, unauthorized access, use, or

disclosure. For example:

 we train our employees and agents on the importance of safeguarding personal

information; and

 we restrict access to your personal information to those employees or agents who need

access for authorized purposes.

Despite these measures, we cannot guarantee that our safeguards will always be effective. A

breach of security safeguards can result in risks such as phishing and identity theft. In such cases,

we will act promptly to mitigate the risks and to inform you where there is a real risk of

significant harm, or as otherwise required by law.

We may also require that you assist us in safeguarding your personal information. For example,

if you create an account through our website or applications, you should use a unique and strong

password and not share your password with others.

If you have reason to believe that your personal information is no longer secure, please contact

us immediately using the contact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

We expect you to supply us with updates to your personal information, when required. We will

not routinely update your personal information unless such a process is necessary.

You may make a request to review any personal information about you that we have collected,

used, or disclosed, and we will provide you with any such personal information to the extent

required by applicable laws.

You may also challenge the accuracy or completeness of your personal information in our

records. If you demonstrate that your personal information in our records is inaccurate,

incomplete or equivocal, we will amend or delete your personal information as required. Where

appropriate, we will transmit the amended information to third parties to whom we have

disclosed your personal information.

We may require that you provide sufficient identification to fulfill your request to access or

correct your personal information. Any such identifying information will be used only for this

purpose. We will not charge you any fees to access your personal information in our records

without first providing you with an estimate of the approximate fees, if any.

If you object to how we handle your request, you may have the right to make a complaint to the

Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

If we are processing your personal information on behalf of our customer, we may refer your

access or correction request to that customer.

Third-Party Websites and Services

We may provide links to third-party websites for your convenience and information. We may

also make opportunities available to you to purchase, subscribe to, or use other products or

services from third parties with different privacy practices. Those other websites, products, or

services are governed by the privacy statements and policies of the respective third party. This

Privacy Statement does not extend to any websites, products, or services provided by third

parties. We do not assume responsibility for the privacy practices of third parties and we

encourage you to review all third-party privacy statements prior to using third-party websites,

products, or services.

Children’s Personal Information

Our products and services are not intended for children under the age of 13 and we do not

knowingly collect personal information from children under the age of 13. Children under the

age of 13 should not use our products and services and should not provide us with their personal

information.

Changes to this Privacy Statement

The Privacy Statement was last revised as of the date that appears at the top of this page. To

review a summary of recent changes, click here.

From time to time, we may make changes to this Privacy Statement. When changes are made,

they will become immediately effective when published in a revised Privacy Statement posted on

our website, unless otherwise noted. We may also communicate the changes to this Privacy

Statement by other means.

How to Contact Us

All comments, questions, concerns, or requests regarding your personal information or our

privacy practices should be forwarded to our Privacy Officer as follows:

Privacy Officer, NetNow Financial Inc.

info@netnow.io

339 Queen Street East, Toronto, Ontario M5A 1S9, Canada