OWNSPACE

WEB SITE PRIVACY POLICY (“Policy”)

1. Introduction

At OwnSpace Solutions Inc. (‘’we’’, “us” ‘’our’’ or ‘’Company’’), we respect your privacy and are committed to protecting it through our compliance with this Policy.

This Policy describes the types of information we may collect from you or that you may provide when you visit our website www.ownspace.com ("Website") and/or when you use the Company’s services via our online platform ("Platform") (Website and Platform hereinafter collectively the “Services”). This Policy also summarizes our practices for collecting, using, maintaining, protecting, and disclosing that information, and of the choices you can make in this regard.

2. Definition and Scope

For purposes of this Policy, "Personal Information" means any information about an identifiable individual, including information that can be used alone or with other information to identify, contact or locate a single individual. This may include, for example, your name, home address, telephone number, email, demographic or household information or any other information relating to your inquiry with us. It may also include other types of more technical information such as User’s IP addresses, User’s username(s) who visited our Website on an anonymous and/or aggregated basis in order to understand User’s interests and improve Services; and may provide analyses based on such anonymized and/or aggregated information to third parties.

This Policy applies to information we collect in connection with the use of our Platform and Services, whether the information is collected via:

• the Website
• When you use our Services as prospective sellers (“Sellers”), prospective buyer (“Buyers”), licensed brokers and or ambassadors (hereinafter collectively “Brokers”), as applicable, when such use is made in compliance with our Terms of Use (Sellers, Buyers, or Brokers, collectively or individually a “User”).
• Email, text, and other commercial electronic messages between you and us;
• Our social media accounts (“Social Network Accounts’’), including the following:
  • Facebook: https://www.facebook.com/getownspace
  • Instagram: https://www.instagram.com/getownspace/
  • LinkedIn: https://www.linkedin.com/company/getownspace/
• Our customer service (when contacted via Websites, telephone, chat, email);
• Job application forms and requests; or
• Your interactions with our selected business partners (“Business Partners”), such as our financial partners, services providers, Personal Information processors. For a list of our Business Partners, see HERE

This Policy does not apply to third-party websites or third-party services which may be accessed by clicking on links appearing on such websites, and we are not responsible for such third-party websites or services. If you follow a link to a third-party website, that third party will have its own privacy policies which you should review before submitting any personal information. This Policy may change from time to time. Your continued use of the Website and the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

If you do not agree, your choice is not to use our Website and not to use our Services. By interacting and/or doing business with us and/or submitting information to us in connection with the Services offered via the Platform, you are providing your consent to the collection, use and disclosure of Personal Information as set out in this Policy.

1. What type of Personal Information (as defined below) do we collect?

We collect several information about you including:

• Information by which you may be personally identified, and which may include sensitive information, such as name, date of birth, address of the Buyers, gender, passports, driver’s license and social insurance number (SIN), as well as any information required for you to submit (and us to process) your Purchase Offer (as defined hereunder) via the Platform, with your express consent ("Personal Information’’);
• Information that is about you but individually does not identify you, such as such as household demographic, gender; and/or
• Information about your internet connection, the equipment you use to access our Website and usage information; such as your computer’s internet protocol address (i.e. IP address), browser type, browser version, the pages of our Services that you visit, the time and date or your visit, the time spent on those pages, unique device identifiers and other diagnostic information including information collected through cookies, web beacons, and other tracking technologies ("Usage Information’’).

2. How do we collect your Personal Information?

We collect your information:

• Directly from you when you provide it to us, via our Website or our Platform.
• Automatically as you navigate through the Website. Information collected automatically may include Usage Information. For more information in this regard, please refer to the section "How we use “cookies” and other tracking technologies" of this Policy.
• From third parties, for example from our Business Partners, as they may share information with us you will have provided to them, with your prior consent, in order for them to provide you with their services.

For example, the information we collect may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of creating an account with us, or registering to use our Services, or receive our newsletters (as applicable), when you post or upload material or documents via our Platform or when you are interacting with us, for instance when you make an inquiry through our Website and/or when you request further services or to apply for a position to work for the Company.
• We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website or contact our customer support (via telephone, email or chat). When you use our chat services, we will also collect your messaging content.
• Your responses to surveys that we might ask you to complete for research purposes.
• Information of transactions or Purchase Offers (as defined hereunder) you submit through our Platform, as well as any ancillary documentation related to this (individually, “Purchase Offer”). You may be required to provide additional information before submitting a Purchase Offer through our Platform, such as information related to bank account, financial institution, credit card and pre-approval financing letter.
• When you apply for a position with us, via our Careers section on the Website, we may collect the information you have included in your resume and in certain circumstances, additional Personal Information required in the context of a background check (such as employment records, credit records and criminal records).

3. Why do we collect and process your Personal Information?

We will collect and process your information for legitimate interests and only as required to fulfill our obligations with you. More specifically, we will only collect your information if it is required for us to process your Purchase Offer, or if our Business Partners need to have access to same, to provide you with the Services.

These “legitimate interests” may include:

• Preventing risk of fraud;
• Perform and administer the Services requested, and manage our relationship with you;
• Process Purchase Offer applications and related documentation;
• Answering questions or providing other types of support you request;
• Confirm your identity and the accuracy of information provided;
• Testing out features or additional services;
• Assisting with marketing, advertising, or other communications.
• Verify your credit, ability to pay, purchase history;
• Respond to legal inquiries or meet legal requirements;

We may also collect and use your Personal Information where you have provided your express consent. In particular, for example, where you direct us to transfer information to a third party. Please see below for more information about what we collect and the purposes for which it is collected.

Categories of information	Examples	Purposes of collection
Identification information	Name, address, email address, date of birth, gender, copies of identification documents (such as passports, driver’s license), profile picture	For account creation To verify identity of the User Information provided by you, with your express consent, via the Platform.
Professional information	For Broker: license number, license jurisdiction, license expiry date, brokerage firm as employer	To verify identity of the Broker Personal certification To verify identity of your employer Information provided by you, with your express consent, via the Platform.
Financial information	Credit card information, Bank account, financial institution, financing information	To initiate financing and/or process payments in connection with a Purchase Offer submitted through the Platform (including credit check). Information provided by you, with your express consent, via the Platform
Employment information	Name, address, email address, date of birth, gender, bank account, social insurance number (SIN)	To process your job application with us To maintain your employment relationship To allow us to pay your salary and comply with our legal obligations as employer Information provided by you, with your express consent, to our HR department.

4. Electronic Communications and Notifications

You may receive the following types of electronic communications and notifications from us:

Electronic Notifications. Communication sent to confirm a transaction via the Platform, important information and/or milestones during the completion of a transaction via the Platform. This includes User’s account creation, completion of a Purchase Offer and information about any incident regarding the security of your information or in order to comply with legal obligations, as appliable.

Commercial Electronic Messages (“CEM”). You may receive CEMs from the Company if we have your express or implied consent to send you such CEMs. Such communications may include promotional and targeted advertising. You may unsubscribe from these promotional communications at any time by either: (i) clicking on the unsubscribe link at the bottom of each CEMs; or (ii) contacting us by email at privacy@ownspace.com.

Please note that even if you unsubscribe from such promotional communications, we may still need to contact you when required by law or if we need to inform you about critical issues related to the Services or your account with us, as applicable.

5. How do we share your Personal Information?

We may disclose your information when required by law. We may also share your personal information with third parties including, Sellers, Buyers, Brokers and Business Partners for purposes related to the Services. If you submit an employment application, we may share your information with one of our employees, as needed to evaluate your candidacy and on a need-to-know basis. See table below for categories of third parties with whom we may share your information in connection with the Services.

Categories of third parties	Purpose
Credit investigation firms	To initiate credit validation process in connection with a Purchase Offer submitted through the Platform.
Financial partners	To communicate with Buyer’s financial institution to confirmation status of pre-qualification in connection with a Purchase Offer submitted through the Platform.
Hosting service providers	Hosting of Personal Information collected as required for the Services. Information is currently hosted in Canada.
Telecommunication service providers	To communicate with User (e.g. Broker to Buyer, Seller to Broker)
Payment processing & identity verification service providers	To process payments for a Purchase Offer submitted through the Platform To verify identity of Buyer and prevent fraud
Contract generation service providers	To allow preparation of contract, and related documentation, in connection with a Purchase Offer submitted through the Platform.

6. Where do we host/process your Personal Information

In order to provide you with the Services, Personal Information may be hosted and/or processed on servers operated by our service providers located in Canada, such as Stripe, DocuSign, Google Analytics Microsoft Azure, SendGrid (“Service Providers”). If you are based in Quebec (Canada), this may involve the need to transfer your Personal Information outside Quebec, Canada.

Whenever Personal Information is transferred to a location outside Canada (as applicable), we ensure a similar degree of protection is afforded to it. This Personal Information may be subject to the laws of the countries where we send it. We take appropriate contractual steps to protect your information when we send your Personal Information across borders. By submitting your Personal Information or using the Services, you consent to this transfer, storage, use, or processing.

7. How long do we keep your Personal Information?

We keep your Personal Information only for as long as necessary to fulfill the purposes for which we have collected it. To determine the appropriate retention period, we consider the amount, nature and sensitivity of your Personal Information, the purposes for which we collected it initially, with your consent, and whether we can achieve those purposes through other means, as per applicable legal requirements.

We will retain your Personal Information to the extent necessary to comply with our legal obligations (for example, tax purposes). If you stop using our Services or if you delete your account with us, we will delete your Personal Information or store your Personal Information in an aggregated and anonymized format.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this Personal Information for longer period as it can no longer be associated with you.

8. How do we protect your Personal Information?

We use commercially reasonable administrative, technical and physical safeguards to ensure the security and integrity of our Platform and Services, in an effort to protect against unauthorized access, use, modification and disclosure of Personal Information in our control. All information you provide to us is stored on secured locations and on servers controlled by the Company or its Service Providers, located either at our facilities or at the facilities of our Service Providers, in Canada.

The safety and security of your Personal Information also depends on you. Where you have chosen a password for access to certain parts of our Website including to log in to your account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Please also ensure that while using our Services, you are in a safe and private environment where the confidentiality of your Personal Information and your privacy are adequately protected.

You acknowledge that: (i) there are internet security and privacy limitations beyond our control; (ii) the security, availability, integrity and privacy of information and Personal Information exchanged between you and us through our Website or platform cannot be guaranteed, as information may be tampered in transit by a third party, or triggered by an event out of our control. No collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure. Therefore, the Company is not responsible for circumvention of any privacy settings or security measures. The Company declines all liability if the Personal Information is subject to unauthorized use or access. In the event there is a security incident involving your Personal Information, as collected by us and under our control, we will notify you as per applicable privacy laws.

9. Compliance with Privacy Laws

We are committed to complying with applicable privacy and data protection laws, including but not limited to:

• Personal Information Protection and Electronic Documents Act (PIPEDA) – Canada: We adhere to PIPEDA’s principles regarding the collection, use, and disclosure of personal information for commercial activities in Canada.
• Québec Law 25 (formerly Bill 64): If you are a resident of Québec, we ensure compliance with Law 25, which imposes additional safeguards for handling personal information, including the obligation to appoint a privacy officer and conduct privacy impact assessments.
• California Consumer Privacy Act (CCPA) – United States: If you are a California resident, you have the right to know what personal information we collect, request deletion of your data, and opt out of the sale of personal information (OwnSpace does not sell personal data).

If you have questions regarding compliance with specific privacy laws, you may contact our Privacy Officer at privacy@ownspace.com.

10. How we use “cookies” and other tracking technologies

We use cookies and similar tracking technologies on our website and when providing our Services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies that we place when we power a merchant’s store, and an explanation of how you can opt out of certain types of cookies, please see our Cookie Policy.

11. Children and Personal Information

This Website, and the Services, are not intended for use by children and we do not knowingly collect Personal Information relating to children. If we become aware that we are holding any information about children under the age of 18, we will take any actions necessary to comply with Personal Information protection legislation, including if appropriate, deleting the information. If you become aware that your child (under 18) has provided their Personal Information to us, without your consent, please let us know as soon as possible by emailing privacy@ownspace.com so that we can take appropriate action.

12. Your rights over your Personal Information

Depending on where you live, and subject to certain exceptions, you may have some or all of the following rights:

• Right to Know: The right to request that we disclose to you the Personal Information we collect, use, or disclose about you, and information about our Personal Information practices.
• Right to Request Correction: The right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Request Deletion: The right to request that we delete Personal Information that we have collected about you.

Please note that to protect your information and the integrity of our Services, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as your email address or a government issued ID number or a picture of you.

You may access your Personal Information through your account profile at ownspace.com. You may also access the entirety of your Personal Information stored in any form by our Website or application by emailing our support team for assistance at privacy@ownspace.com.

13. How you can contact us

If you have any questions about how we process your Personal Information, or if you want to make a request relating to your Personal Information, please contact us at:

Privacy Officer: George Pamel
Address: 1176 Sherbrooke Street Ouest, Montreal QC H3A 1H6
Email: privacy@ownspace.com
Phone number: +1 (514) 312-0323