The Sorbara Group of Companies (the “Group”) values your business and respects your right to privacy. We are committed to collecting, using and disclosing your personal information in a responsible manner, and only to the extent necessary for the services we provide. In order to demonstrate our commitment to the protection of individual privacy, we have outlined our Privacy Policy below.

This Privacy Policy has been developed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applies to the Group and those organizations using the Group’s trademarks. The following discloses the personal information collection, use and disclosure practices of the Group.

For the purposes of this Privacy Policy, “personal information” means information about an identifiable individual. “Non-identifiable information” means information that cannot be associated with or traced back to specific individuals with any certainty.

1. The Group collects personal information from individuals on a voluntary basis through surveys, contest entry forms, registration forms, questionnaires and transaction documents both online and off-line. The personal information we collect includes contact information (for example names, mailing addresses, email addresses and telephone numbers), demographic information, household information, preference information and transaction-related information.

Use of personal information by the Group:

1. The Group uses personal information that it collects for the following purposes:

a. To communicate with individuals;

b. To understand individual needs;

c. To promote and offer products, services and special offers that meet individual needs or that might be of interest to individuals based on information provided and approved by the Group;

d. To comply with applicable statutory or regulatory requirements;

e. To provide individuals with products or services that are requested or that is part of The Group’s ongoing service with the customers; and

f. To conduct, process and complete transactions with the Group’s customers.

 If the Group uses personal information for any other purposes other than those set out above, such purpose will be identified to you at the time the personal information is collected. Alternatively, the Group will contact you to obtain your consent to use your personal information in any new or different manner. Personal information collected by the Group enables us to develop and customize our products and services to better meet the needs and preferences of customers. The Group may, from time to time, contact individuals by electronic format, regular mail or telephone for any of the purposes set out above.

1. The Group does not sell, rent or trade personal information that it collects. The Group will not knowingly disclose personal information to any third parties except in the following circumstances:

a. When the Group has received consent to do so or under limited circumstances specifically described at such time as personal information is collected;

b. When the Group, in good faith, believes the law permits or requires such disclosure;

c. To affiliated and associated companies within the Group and only for the purposes described in section 2 above. Such affiliated and associated companies and their respective employees are restricted from using the personal information for any other purpose other than as described in section 2 above;

d. To its agents, professional advisors, promotional and marketing agencies, and to any other third parties in order to complete transactions, to process data and to service customers. Such third party organizations and their respective employees are only provided with such personal information as is necessary to perform the services for which they had been contracted and are restricted from using the personal information for any other purpose other than as described in section 2 above; and

e. In the event of a sale involving an organization of the Group, personal information may be used or disclosed.

1. When personal information collected by the Group is no longer required for any of the purposes stated in this Privacy Policy, such personal information will be disposed of in a manner that is secured and which respects your privacy.

1. The Group collects and uses Non-identifiable information to assess the effectiveness of website content and traffic. This allows the Group to improve the quality of visits to websites managed by it by streamlining the ability of website visitors to navigate the sites and develop future programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analysis of the collective characteristics and behaviour of individuals, and to measure demographics and interests.

2. The Group also uses aggregate non-identifiable information it collects to inform its current and prospective sponsors and advertisers about the number of visits to its websites, the demographic characteristics of these visitors and the number of times visitors have viewed and “clicked” on their advertisements. The Group also discloses to advertisers the overall demographics available regarding visitors who “clicked” on their advertisement. Aggregate non-identifiable information may be used to describe the Group’s services and products to third-party such as prospective business partners and financial institutions. In any of these circumstances, no personal information is disclosed.

1. Websites operated by the Group may contain links to other websites that may collect personal information. This Privacy Policy does not extend to the data collection, disclosure, use and retention practices of such third parties and the Group cannot assume liability for the privacy policies, policies or actions of such third parties. Individuals should read the privacy policies of such third parties, and make an informed decision whether or not to visit such websites and/or provide personal information to such third parties based upon the privacy practices and individual discretion.

1. The Group takes all reasonable precautions protect the security and confidentiality of personal information, whether the information is kept electronically or otherwise. Personal information is stored in confidential data bases and locations in the greater Toronto area. These sites have appropriate security measures in place to protect against the loss, misuse and alteration of personal information under the care and control of the Group. Any information transmitted via the Internet, however, may be intercepted by third parties. The Group does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. The Group’s employees are restricted from using and disclosing personal information collected by the Group other than in accordance with this Privacy Policy.

Individuals have the right to access, verify and correct or amend all of their personal information collected by the Group. The Group believes that it is imperative that personal information be accurate, complete and up-to-date as is necessary for the purposes of which it is collected. Accordingly, to help keep personal information as current as possible, the Group encourages individuals to amend inaccuracies and make corrections to the personal information collected by the Group as often as necessary. To access, verify and correct or amend personal information, please send an email to the Privacy Officer at privacy@sorbara.com or call 905.850.6154.

1. If you wish to make a formal complaint with the Group concerning the collection, use and/or disclosure of your personal information or our privacy practices, please send an email to the privacy officer at the Group at privacy@sorbara.com or call 905.850.6154. All complaints will be investigated by the Group’s Privacy Officer as soon as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints clearly and promptly and will be notified of any relevant steps taken or to be taken as a result of the complaint. If you are not satisfied with any decision reached by the Group regarding your privacy complaint, or if you have any concerns about our compliance with PIPEDA, you may contact the Information and Privacy Commissioner of Canada at 1-800-282-1376 or info@privcom.gc.ca

1. Your personal information is obtained and used only with the consent that may be expressed or implied depending on the circumstance. Individuals always have the choice whether or not they wish to supply the Group with personal information. Individuals wishing to “opt-out” of receiving certain informational and promotional materials from the Group or who otherwise object to the collection, use and disclosure policies as provided under this Privacy Policy, are asked to contact the privacy officer at the Group at privacy@sorbara.com or call 905.850.6154. Opt-out opportunities are also provided in other circumstances, such as in certain promotional mailings. Individuals are reminded that the decision to withhold personal information or to object to the use and/or disclosure of personal information as provided in this Privacy Policy or in any agreement between such individuals and the Group may, in certain instances, limit their ability to complete purchases of the Group’s products and services and limit their ability to access or take advantage of certain promotions and features.

Any comments or questions about this Privacy Policy should be addressed to the Group in any of the following manner:

By mail:

Sorbara Group

3700 Steeles Ave. West, Suite 800

Vaughan, Ontario L4L 8M9

Attention: Privacy Officer

By email:

privacy@sorbara.com

By phone:

905.850.6154

Effective date of Statement

This Privacy Policy was last revised by the Group as of May, 2018. The Group reserves the right to further amend this Privacy Policy at any time, and we encourage you to refer back to this Privacy Policy regularly. This Privacy Policy will also be available for viewing on our website at www.sorbara.com