Privacy Policy

Naborino Inc. ("Naborino")

Privacy Policy

Last modified: May 5, 2021

Effective date: May 5, 2021

1. TERMS OF USE

This privacy policy as well as our Terms of Use found here: www.naborino.com/legal/naborinoterms (“Terms of Use”) govern your access of the Naborino App and Website, whether:

(a) accessed on a computer connected to the internet at https://naborino.com/ (the “Site”);

(b) on the Naborino social media properties; or

(c) by mobile phone

(individually and collectively, (a), (b) and (c) are the “Naborino App and Website”), as owned and operated by Naborino, an Ontario corporation having its registered address at 305-760 Sheppard Ave W, Toronto, ON, M3H 0B3 (referred to in these Terms as “we”, “us” or the “Company”). Terms capitalized but not defined in this Privacy Policy have the meanings set out in the Terms of Use.

2. INTRODUCTION TO PRIVACY POLICY

Naborino is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) about our subscribers to the Site. The Company strives to support individuals and business owners with the Naborino App and Website, while respecting your privacy expectations and protecting your Personal Information. To demonstrate our commitment to protecting your privacy, we have developed this privacy policy (“Privacy Policy”), which describes how we will collect, use, disclose and protect your Personal Information through the Site.

By accessing and/or using the Naborino App and Website, you agree to all the terms and conditions of this Privacy Policy and the Terms of Use found here: www.naborino.com/legal/naborino-terms and which are incorporated here by reference. If you do not agree to all the terms and conditions of this Privacy Policy and the Terms of Use, do not use the Naborino App and Website.

3. AMENDMENTS TO THIS PRIVACY POLICY

The Company may amend or change this Privacy Policy at its sole discretion at any time, and in accordance with the amendment provisions set out in the Terms of Use. The use of the information we collect at any given point is subject to the Privacy Policy in effect at the time of collection. If we make any material changes we will notify you by email or by means of notice on the Naborino App and Website prior to the change becoming effective. We will post the most current Privacy Policy on the Naborino App and Website, and your use of the Naborino App and Website is subject to the most current Privacy Policy as posted on the Naborino App and Website at any time. We encourage you to periodically check our Privacy Policy for the latest information on our current policy.

4. CONTACT INFORMATION

If you have questions or concerns regarding our policy or practices, please contact our privacy officer by email at privacy@naborino.com or at the following address:

Naborino Inc.

305-760 Sheppard Ave W

Toronto, Ontario

Canada

M3H 0B3

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you can contact the Office of the Privacy Commisioner of Canada at:

30 Victoria Street

Gatineau, Quebec

Canada K1A 1H3

https://www.priv.gc.ca/

5. GENERAL

We may provide areas on our websites where you can post information about yourself and others and communicate with others or upload content. Such postings are governed by the Company's Terms of Use. In addition, such postings may appear on other Naborino App and Website or when searches are executed on the subject of your posting. We cannot control who reads your posting or what other users may do with the information you voluntarily post. Therefore, we encourage you to exercise discretion and caution with respect to your personal information.

6. COLLECTION OF PERSONAL INFORMATION
6.1 Collection of Information at Registration

Registration is required if you want to use the Naborino App and Website. Businesses may register at https://hey.naborino.com/partners. [Other users may either sign in through Facebook, Google and other social media sites or register using an online form located at https://naborino.com.] As part of this registration, we will require that you submit certain information that is relevant to the purposes of the Naborino App and Website. We collect the following information (“Personal Information”) from our subscriber’s registration information:

6.2 Mobile Device Location Information

Upon registration or the use of our location-enabled services on the Naborino App and Website (for example, when you access services from a mobile device), we may need to collect and process information about your actual Global Positioning System location (including the latitude, longitude or altitude of your mobile device) and the time the location information was recorded.

Some of these services require your personal data for the feature to work and we may associate location data with your device identification and other information we hold about you. If you wish to use the particular feature, you will be asked for your consent. If you do not want your location information collected when you use the Naborino App and Website, please contact your device manufacturer or platform provider to determine how to disable the collection of this information.

6.3 Collection of Information when you use the Naborino App and Website

When you use the Naborino App and Website, we automatically collect and store certain

information about your computer or device and your activities including:

6.4 Collection of information submitted by you

You may send electronic information or physical documentation to us in the following forms:

messages or transaction information relating to your interactions with our Merchants; receipts,

personal data in text and picture form; and other subscriber-generated content provided to us in

the normal course of your use of the Naborino App and Website, including but not limited to

posts, profiles, comments, suggestions, forwarded messages, feedback information, usage

information, transaction information and Traffic Data (as defined below).

6.5 Collection through interaction with the Naborino App and Website

We may collect your Personal Information when you communicate it to us by use of one of our

web forms or other interactions with the Naborino App and Website, by email, or by any other

means of communication.

The Naborino App and Website offers publicly-accessible blogs and allows you to create

personal profiles which can be seen by others (collectively, “Public Content”). This Public Content

and any of the information you post to the Site, such as reviews, are intended for public

consumption. You should be aware that any information you provide in this area may be read,

collected, and used by others who access them. We take no responsibility for any information

which you or your employees, agents, contractors and representatives post or publish on the

Naborino App and Website and you agree to indemnify and hold us harmless for any loss, cost,

complaint, damage, claim or liability whatsoever arising from any such post or publication. We

may post your testimonials along with your name on the Naborino App and Website from time to

time if such information is provided to us.

If you are logged into social media sites such as Facebook, Google, and you access but are not

logged into the Naborino App and Website, we may receive information from such social media

site to make it easier for you to create an account on the Naborino App and Website and show

you relevant content from your friends on such social media. This information personalizes your

experiences and helps you create an account. You can also connect your account on third party

social media like Facebook, Google, in which case we may collect and store information

identifying your account with the third party service.

We may collect and store information (including personal information) locally on your device

using mechanisms such as browser web storage and application data caches.

6.6 Traffic Data

"Traffic Data" is collected by the Naborino App and Website and our third-party traffic analysis

provider through the use of software that is included on the Naborino App and Website as well as

cookies that are stored temporarily on your computer. Together, these technologies help us

manage our content by identifying which content is effective.

6.7 Use of Cookies and Usage Data

Cookies are small data files that are stored on a subscriber’s computer for record-keeping

purposes. Cookies track where you travel on the Naborino App and Website and what you look

at. A session ID cookie expires when you close your browser. When you log into the Naborino

App and Website, your browser may ask if you want it to remember you as a registered

subscriber of the Naborino App and Website. If you accept, the session ID becomes a persistent

cookie, which remains on your hard drive for an extended period of time. Although cookies are

used by most major websites and are accepted by default by most web browsers, it may be

possible to disable cookies via your browser settings.We use session cookies and usage data to

make it possible to navigate the secure environment inside the Naborino App and Website and to

keep, and periodically track, information about you for the purpose of creating a personalized

web experience and improving the Naborino App and Website or measuring and conveying to

others the performance levels of the Naborino App and Website. We may link the information we

store in cookies to any personally identifiable information you submit while on the Naborino App

and Website. This is for the purpose of creating a personalized experience within the Naborino

App and Website, to assist the Company in understanding its users and subscribers and

designing improvements to the Naborino App and Website, and for the purpose of collecting

usage and performance metrics.

6.8 Online and Mobile Advertising

We may allow third parties to use cookies on the Naborino App and Website to collect the same

type of information for the same purposes as we do. Advertisers and advertising networks place

advertisements on our websites and mobile applications. These companies as well as data

analytics companies who service them may collect information, such as your computer’s IP

address, browser information, mobile device ID, and search queries as you use the Naborino App

and Website. These companies also may use cookies and other technologies to collect data

about you when you visit our Site. Cookies from advertising companies enable them to track your

activity across various websites where they display advertisements and record and associate

your activities, so they can show advertisements that they consider relevant to you. We do not

have access to or control over the cookies that these third-parties use.

6.9 Use of analytics tools

The Naborino App and Website may from time to time implement other third-party analytics

services that also use cookies. We will ensure that no personally identifiable information is

included in those cookies. If the use of cookies by any service provider differs materially from the

practices already listed, we will revise this document accordingly and notify existing customers

of the change(s). Other cookies created by the Naborino App and Website are used to secure

your login session and to help ensure the security of your account. Such cookies are unrelated to

the aforementioned traffic analysis and are never shared with third parties.

6.10 Location Data

When you access the Naborino App and Website using a web browser or other application, we

may gather and store certain types of information including: traffic data from your browser, your

IP address, location, GPS signals sent by a mobile device, cookie information, and the pages you

visit on the Naborino App and Website. Traffic data is helpful in identifying and fixing problems

with the Naborino App and Website.

7. USE AND DISCLOSURE OF PERSONAL INFORMATION

7.1 General use

The Company will not use or disclose Personal Information for purposes other than the identified

purposes of the Naborino App and Website. We may use your Personal Information (defined

above) to:

7.2 Third-party disclosure

We may share personal information or feedback with affiliates, third-party vendors, consultants

and other service providers who work for us. We may share your first name and comments or

feedback with third-parties. We will not tie any other information, other than your first name, that

can identify you to your comments or feedback. However, third-parties may be able to tell who

you are from your comments, particularly if you provide your full name or your contact

information in the comments.

7.3 Surveys

From time to time, the Company may offer you the opportunity to participate in contests,

giveaways and other promotions. Any information submitted in connection with such activities

will be treated in accordance with this Privacy Policy, except as specifically set forth in the rules

for those contests, giveaways or promotions. From time to time, the Company may also ask you

to participate in surveys designed to help us improve the Naborino App and Website. Any

Personal Information provided to the Company in connection with any survey will be used only in

relation to that survey and as elsewhere set forth in this Policy.

7.4 Acquisition of the Company

In the event that the Company, or all or a portion of our business, or one or more of its divisions,

is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization,

consolidation, liquidation or another similar transaction, your Personal Information shall be one

of the transferred assets.

7.5 Retaining Information

We may retain your personal information while you have an account with us and thereafter for as

long as we need it for purposes not prohibited by applicable laws and subject to the provisions in

our Terms. This data may be retained for approximately 60 days after your relationship with us

has been terminated.

7.6 Legally compelled disclosures

Notwithstanding the foregoing, the Company reserves the right (and you authorize the Company)

to share or disclose your Personal Information when the Company determines, at its sole

discretion, that the disclosure of such information is necessary or appropriate:to enforce our

rights against you or in connection with a breach by you of this Privacy Policy or the Terms of

Useto investigate or respond to suspected illegal or fraudulent activity or to protect the safety,

rights, or property of us, our users, or others;to prevent prohibited or illegal activities; orwhen

required by any applicable law, rule, regulation, subpoena, or other legal process.

8. DISCLOSURE OF PAYMENT CARD INFORMATION

To use certain services on the Naborino App and Website, we may require credit or debit card

account information. By submitting your credit or debit card account information through the

Naborino App and Website, you expressly consent to sharing of your information with third-party

payment processors, other third-party service providers, and applicable businesses.

8.1 DATA RETENTION AND ACCOUNT TERMINATION

Businesses may terminate their account by pressing the unsubscribe button located in the

settings tab of their business dashboard panel. After 60 days of receiving a termination request,

or immediately after we terminate our relationship with you, the business profile, including all

offered promotions, will be removed from the Naborino App and Website, but we may retain

information about you for the purposes authorized under this Privacy Policy and our Terms

unless prohibited by law. For example, we may retain information to prevent, investigate, or

identify possible wrongdoing in connection with the Naborino App and Website or to comply with

legal obligations.

8.2 CONSENT AND PRIVACY SETTINGS

By using the Naborino App and Website, you consent to the collection, use and disclosure of your

Personal Information by us in the manner described in this Privacy Policy. You may always opt

not to disclose certain Personal Information, but which may restrict access certain features of

the Naborino App and Website. For example, your name and email address are necessary to

complete the registration process. At any time after registration, you may opt out of most email

communication from us by clicking on the opt-out link at the bottom of our emails, or by

contacting us at the contact details listed above. However, we may still contact you for

administrative purposes. Withdrawing consent will not apply to actions the Company has already

taken based on your prior consent.

By providing your mobile phone number, businesses expressly consent to receive direct dial calls,

from us for any urgent and administrative issues. When you sign up for an account, you are

opting in to receive emails and notifications from the Naborino App and Website and other

Naborino App and Website users such as businesses signed up with the Naborino App and

Website.

9. ACCURACY OF INFORMATION AND INDIVIDUAL ACCESS

The Company relies on you to ensure that the Personal Information you enter into our system is

as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

You may make changes or corrections to your Personal Information at any time. You may review

or update your personal information by clicking your settings tab in your business dashboard or

in the menu located within your personal profile.

When updating your personal information, we may ask you to verify your identity before we can

act on your request. Unless required by law, we may reject requests that are unreasonably

repetitive, require disproportionate technical effort, risk the privacy of others, or would be

extremely impractical. Where we can provide information access and correction, and when

required by law, we will do so for free.

We also make every effort to ensure the accuracy of the information in our reports, displays,

articles and support queries. However, you must verify all information created from your use of

the Naborino App and Website. We recommend that you consult a professional before

completing any government or regulatory filing or otherwise relying upon the information, as the

use of this information is at your own risk. You are responsible for ensuring that the information

you have entered into our system is accurate, reliable and complete.

10. MERCHANT’S ACCESS FOR YOUR EMPLOYEES OR CONTRACTORS

If you are a Merchant, in order for you to use certain features of the Naborino App and Website,

you may be required to provide Personal Information relating to your employees, agents,

contractors and representatives (“Company Representatives”) from time to time. You

acknowledge, and represent to us that you will not share your subscriber identification, and rather

that your Company Representatives shall register for their own subscriber accounts on the

Naborino App and Website. You agree to indemnify and hold us harmless for any loss, cost,

complaint, damage, claim or liability whatsoever arising from your disclosure to us of Personal

Information relating to your Company Representatives to enable us to set up a user id for such

Company Representatives.

11. THIRD PARTY SERVICE PROVIDERS

We may share your Personal Information with service providers who help us to run our

operations or to otherwise fulfill your request or as required by law. Our service providers are

restricted from using your Personal Information in any way other than for the service they are

providing. We ensure that such third parties maintain reasonable and appropriate safeguards.

You own your data in accordance with the rules for subscriber generated content set out in the

Terms of Use www.naborino.com/legal/naborino-terms and can download your own data via the

Naborino App and Website at any time.

12. BUSINESS TRANSFERS

We may share information from or about you with subsidiaries, joint ventures, or other

companies under common control, in which case we will require them to honour this Privacy

Policy.

13. LINKS TO OTHER WEBSITES

Links to sites controlled or operated outside of our domain (each individually a “Third-party Site”

and collectively the “Third Party Sites”) are provided as a convenience to you only and do not

imply an endorsement by us of a Third Party Site or the company it purports to represent. We do

not assume any responsibility for information and materials found on, or the privacy practices of,

a Third Party Site. This Privacy Policy does not apply to a Third Party Site.

14. SECURITY MEASURES

We take your privacy very seriously. To keep your Personal Information secure, you are required

to safeguard your subscriber name and password information in accordance with the Terms of

Use.

In addition, we restrict unauthorized access through protective policies, procedures, and

technical measures, including:

Please note that no data transmission over the internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect your Personal Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

If you have a security related concern, please contact us at the contact details provided above.

We will work closely with you to ensure a quick and personal response to your concerns.

15. DISCLAIMER

IF YOU CHOOSE TO ACCESS THE Naborino App and Website, YOU DO SO AT YOUR OWN RISK,

AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS.

WE MAY LIMIT THE AVAILABILITY OF THE Naborino App and Website, IN WHOLE OR IN PART,

TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND

IN OUR SOLE DISCRETION. OUR PRIVACY POLICY DOES NOT COVER THE INFORMATION

PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE OUR SERVICES,

AND WHO MAY USE COOKIES, PIXEL TAGS, AND OTHER TECHNOLOGIES TO SERVE AND OFFER

RELEVANT ADVERTISEMENTS.

16. NOTIFICATIONS

We will never send email messages to customers requesting confidential information such as

passwords, credit card numbers, or social security or social insurance numbers. Please do not

act on any such emails as you may compromise your Personal Information by replying or by

following links to a fraudulent website.

17. MISCELLANEOUS

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or

court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void

or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or

unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for

convenient reference only and are not to affect the interpretation of this Privacy Policy.