PALLET CONNECT PLATFORM PRIVACY POLICY

Last modified: April 12, 2021.

INTRODUCTION

Pallet Connect Inc. (referred to as "Pallet Connect", "we" or “us”) respect your privacy and are committed to protecting it by complying with this policy.

This Privacy Policy describes:

· The types of information we may collect or that Platform users ("you") may provide when you purchase, download, install, register with, access, or use [Pallet Connect Website Address] (the “Pallet Connect Website”) and mobile application (collectively, the "Platform").

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

BY ACCESSING THE PLATFORM, YOU CONFIRM THAT YOU HAVE REVIEWED THIS PRIVACY POLICY FULLY, UNDERSTAND THE CONTENT AND AGREE TO ABIDE BY THE TERMS AND CONDITIONS CONTAINED IN THE PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT ACCESS, DOWNLOAD, REGISTER WITH, OR USE THIS PLATFORM.

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

This policy applies only to information we collect in this Platform.

This policy DOES NOT apply to information that:

· We collect offline or on any other Pallet Connect apps or websites, including websites you may access through this Platform.

· You provide to or is collected by any third party (see Third-Party Information Collection).

Our other websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, do not download, register with, or use this Platform. By downloading, registering with, or using this Platform, you indicate that you understand, accept, and consent to the practices described in this privacy policy. This policy may change from time to time. Your continued use of this Platform after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect information about you through:

· Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us.

· Automated technologies or interactions, when you use the Platform, for example, usage details, IP addresses, and information collected through web beacons, local storage and other technologies.

The types of information that we collect may include:

· Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, internet protocol (IP) address, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information”).
We provide an opportunity for any user to unsubscribe from our email correspondences by using the unsubscribe mechanism at the bottom of our e-mails.

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

· Technical information, including your login information, device type, time zone setting, and usage details.

· User Data that you provide for publication or display.

Information You Provide to Us

When you download, register with, or use this Platform, we may ask you to provide:

· Information by filling in forms in the Platform. This includes information you provide when registering to use the Platform, subscribing to our service, posting material, and/or requesting further services. We may also ask you for information when you report a problem with the Platform.

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

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

User Data

You may also provide information for publication or display ("posted") on the Platform accessible by other users (collectively, "User Data"). User Data may include confidential company information including information relating to products, technologies, customers or administrative, sales, marketing, or financial activities of your company (“Confidential Business Information”). You post and transmit User Data and Confidential Business Information to others at your own risk. Please be aware that no security measures are perfect. We cannot control the actions of third parties with whom you may choose to share your User Data. Therefore, we do not guarantee that unauthorized persons will not view your User Data and Confidential Business Information.

Our Commitment to Non-Competition and Non-Solicitation

We agree that under no circumstances shall we utilize Confidential Business Information submitted as User Data to compete with our client’s pallet supply companies, directly or indirectly, nor shall we utilize User Data to solicit the employment, directly or indirectly, of employees, contractors, suppliers and the like of our clients. For clarity, Confidential Business Information does not include any information which we may establish to have: (i) become publicly known through no action on our part; (ii) been known by us prior to receipt of the User Data; (iii) been independently developed by us; (iv) been approved for public release by your/your company’s written authorization; or (v) been required to be disclosed by law, or to a competent court, government or regulatory body having the right to same.

Automatic Information Collection and Tracking Technologies

When you download, access, and use the Platform, it may automatically collect:

· Usage details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including location data, logs, and other communication data and the resources that you access and use on or through the Platform.

· Device information. We may collect information about your mobile device and internet connection, including the device's unique operating system, browser type and mobile network information.

· Location information. This Platform collects real-time information about the location of your device if permission is granted to the Platform on your mobile device. Note that by declining permission for the Platform to collect location information will cause its location-based features to be disabled.

The technologies we use for this automatic data collection may include:

· Local Storage. It may be possible to disable local storage by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Platform.

· Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Pallet Connect, for example, to count users who have visited those pages or opened an email and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).

The information we collect automatically is statistical information and may include personal information. We may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. This usage information helps us to improve our Platform and to deliver a more personalized service, including by helping us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences and customize our Platform according to your individual interests.

· Speed up your searches.

· Recognize you when you use the Platform.

If you do not want us to collect this information do not download the Platform or delete it from your device.

Third-Party Information Collection

When you use the Platform or its content, certain third parties collect information about you or your device. These third parties may include:

· Advertisers, ad networks, and ad servers.

· Analytics companies.

· The Platform store and/or platform providers.

· Your mobile device manufacturer.

· Your mobile service provider.

We do not control these third parties' tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

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

· To provide you with the Platform and its contents.

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

· To provide notices about your account/subscription, including expiration and renewal notices.

· To carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements.

· To notify you when Platform updates are available, and of changes to any products or services we offer or provide though it.

· For any other purpose with your consent.

Usage information that we collect helps us to improve our Platform and to deliver a better and more personalized experience, including by enabling us to:

· Estimate our audience size and usage patterns.

· Store information about your preferences, allowing us to customize our Platform according to your individual interests.

· Recognize you when you use the Platform.

We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

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

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

· To our subsidiaries and affiliates.

· According to applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pallet Connect's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pallet Connect about our customers and users is among the assets transferred.

· To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers target a specific audience. We may use the personal information we collect from you to display our advertisers' advertisements to their target audiences.

· To contractors, service providers, and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We only work with contractors, service providers and other third parties that have similarly reasonable security measures in place to safeguard the security of the Platform.

· To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "message" feature within the Platform, we will transmit the contents of that email and your email address to the recipients.

· For any other purpose we disclose when you provide the information.

· With your consent.

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

· To enforce our rights arising from any contracts between you and us.

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pallet Connect Inc., our customers, or others.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide us to contractors, service providers, and other third parties we use to support the Platform (such as analytics providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to other countries with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information. We only engage with service providers that have similarly reasonable security measures in place and that comply with applicable Canadian laws.

You are welcome to contact us to obtain further information about Pallet Connect policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

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

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

· Tracking Technologies. You can set your browser to block local storage. If you disable or refuse local storage or block the use of other tracking technologies some parts of this Platform may not be accessible or may not function properly.

· Location Information. You can choose whether to allow the Platform to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Platform may be inaccessible or not function properly.

· Promotional Offers from Pallet Connect. If you no longer wish for us to use your email address to promote our own or third parties' products or services, you can opt-out by clicking the unsubscribe link we have included in each email.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers and use 256 bit encryption for your connection to the server.

The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping it confidential. We ask you not to share your password with anyone and we encourage you to be careful about giving out confidential information in User Data which other users can view.

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any Platform privacy settings or security measures.

DATA RETENTION

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

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Platform and visiting your account profile page.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our at info@palletconnect.com

If you delete your User Data from the Platform, copies of your User Data may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Data, is governed by our Terms of Use Terms and conditions

WITHDRAWING YOUR CONSENT

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

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page with a notice that we have updated the privacy policy. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and an in-Platform alert the first time you use the Platform after we make the change.

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

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

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

Email: info@palletconnect.com

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