Privacy Policy

Updated 7th Feb. 2022
Introduction
This Privacy Policy (the “Policy”) represents the policy of Redbiller Technologies Inc., an Ontario corporation (together with all subsidiaries thereof, the “Company”) regarding the collection, use, and management of personal data belonging to:
• All visitors (“Site Visitors”) to the Company’s website located at https://www.waverlite.com/ (the “Website”) • Anyone who registers or uses (“Platform Users”) the Company’s service Platform(s) (the “Platform”) • Anyone who enrolls for the Services of the Company (“Clients”).
Site Visitors, Platform Users, and Clients are referred to collectively as “Users”.
The Website and the Platform together with the Services (as defined below) and all content contained therein are referred to collectively as the “Resources” as further described in the

User Agreement.
In order to ensure the free, informed, and unambiguous consent of our Users to the collection and use of personal data, the Company requires all Users to read this Policy and accept the terms and conditions contained herein, together with consent to release personal data subject to such terms and conditions.

OVERVIEW
This Policy addresses the following topics:
• What data do we collect?
• How do we collect your data?
• How will we use your data?
• How do we store your data?
• Data retention and deletion
• Data usage and processing
• Data sharing and disclosure
• Marketing
• What are your data protection rights?
• What are cookies?
• How do we use cookies?
• What types of cookies do we use?
• How to manage your cookies
• Privacy policies of other websites
• Changes to our privacy policy
• How to contact us

WHAT DATA DO WE COLLECT?
The Company collects the following data on all Users:
• Personal identification information, such as name, email, address, and phone number
• Information on your browser, IP address, location, and device
• Information on your behavior on our website, including pages viewed, links clicked,
• Demographic information
• Transaction information, including information related to the use of the Services, types of Services requested, dates and times of such requests, payment methods, and other similar information
• Communications data, including messages, comments, or file transmissions
• About your internet connection, the equipment you use to access our Resources, and usage details

Children Under the Age of 13
Our Resources are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Resources. We do not knowingly collect personal informa- tion from children under 13.
If you are under 13, do not use or provide any information on this Resources or through any of its features, register on the Resources, make any purchases through the Resources, use any of the interactive or public comment features of this Resources, or pro- vide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.
If you believe we might have any information from or about a child under 13, please contact us at at the information provided below.
California residents under 13 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights (below) for more information.

HOW DO WE COLLECT YOUR DATA?
Users directly provide data to the Company. The Company collects data and processes data when Users:
• Register online or place an order for any of our products or Services
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email
• Use or view the Site via your browser’s cookies
• Download or use the Platform
• Submit content to the Site, like reviews, messages, or comments
• Enable access to their device’s location-tracking functionality, whether the Site or Platform is running in the foreground (Platform or Site open and on-screen) or background (Platform or Site open but not on-screen). Certain functionality may be affected while location data is turned off.
Clients expressly and directly provide personal data, including payment information, to the Company via the Site when enrolling for the Services.

HOW WILL WE USE YOUR DATA
The Company collects data from Users in order to:
• To provide the Services and the other Resources
• To enhance the safety and security of our Users and Services
• For customer support
• For research and development
• To enable communications between users
• To send marketing and non-marketing communications to users
• In connection with legal proceedings and compliance with regulators

The Company does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
The Company provides software Services as defined in the User Agreement. The Company may collect data from its Clients in order to perform such services (the “Services”). You acknowledge, accept, and agree that without the data collected as set forth above, the Company will not be able to provide the Services and most functionality of the Platform.
Clients consent to the release of this information and data to the Company for the purpose of the performance of the Company’s Services for the Client’s benefit. This release of information and the relationship between the Company and its Clients is subject to the User Agreement.

HOW DO WE STORE YOUR DATA?
The Company securely stores Client data on servers leased from a reputable third party hosting/cloud service located in the United States. Data is retained in accordance with the Company’s User Agreement.

DATA RETENTION AND DELETION
The Company retains user profile, transaction, and other information for as long as a user maintains their account.
Users may request deletion of their account at any time. Following such requests, the Company deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, regulatory or other legal requirements. For example, the Company retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development.
In certain circumstances, the Company may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, the Company will delete the account as described above.
The Company may also retain certain information if necessary, for purposes of safety, security, and fraud prevention. For example, if the Company deactivates a user’s account because of unsafe behavior or security incidents, the Company may retain certain information about that account to prevent that user from opening a new account in the future.

DATA USAGE AND PROCESSING
We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our Users are located, but generally include processing personal data:
1. To provide requested Services and features
In order to provide our Services, we must collect and use certain personal data. This includes:
• User profile data, which we use to establish and maintain User accounts; verify User identity; communicate with Users about their orders and accounts; and enable Users to make or receive payments (as and if applicable)
• Usage data, which is necessary to maintain, optimize, and enhance the Company’s Services
• Transaction information
• Information relating to customer support
2. For purposes of the legitimate interests of the Company or other parties
This includes using personal data to maintain and enhance our Users’ safety and security. For example, we use personal data to prevent use of our Services by Users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned Users to prevent their use of the Platform.
This also includes purposes such as combating fraud; improving our Services, direct marketing, research, and development; and enforcing the Company’s User Agreement.
In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.
3. To fulfill the Company’s legal obligations
We collect and use personal data to comply with applicable laws. The Company may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. 4. With consent
The Company may collect and use personal data based on the User’s consent. For example, we may collect personal data through voluntary surveys.
Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
A User who has provided consent to a collection or use of their personal data can revoke it at any time. However, the User will not be able to use any Service or feature that requires collection or use of that personal data.

DATA SHARING AND DISCLOSURE
Some of the Company’s products, Services, and features require that we share data with other Users or at a User’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. The Company may share the data we collect:
1. With Other Users This includes sharing User’s personally identifying information shared on the Platform, including to such User’s Profile on the Platform 2. At the User’s request
This includes sharing data with:
• Other people at the User’s request.
• Company business partners. For example, if a User requests a service through a partnership or promotional offering made by a third party, the Company may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs.
3. With the general public
Questions or comments from Users submitted through public forums such as the Company blogs and the Company social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a User.

4. With the User account owner
If an account is operated by a User other than the registered User account owner, we will share information with the registered User account owner.

5. With the Company subsidiaries and affiliates
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, the Company processes and stores data in the United States on behalf of its international subsidiaries and affiliates.

6. With the Company service providers and business partners
The Company provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:
• Payment processors and facilitators
• Background check and identity verification providers (as applicable)
• Cloud storage providers
• Marketing partners and marketing platform providers, including social media advertising services • Data analytics providers
• Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf • Vendors that assist the Company to enhance the safety and security of its platforms
• Consultants, lawyers, accountants, and other professional service providers
• Insurance and financing partners
• Vehicle solution vendors or third-party vehicle suppliers

7. For legal reasons or in the event of a dispute
The Company may share Users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our User Agreement or other policies; to protect the Company’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.
This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent
The Company may share a User’s personal data other than as described in this notice if we notify the User and they consent to the sharing.

MARKETING
The Company may send its Users information about products and services of the Company, always with the consent of the User. Clients consent to marketing and promotional communication when they enroll for the Services pursuant to the User Agreement.
If you have agreed to receive such marketing materials, you may always opt out at a later date. You have the right at any time to stop the Company from contacting you for marketing purposes.

WHAT ARE YOUR DATA PROTECTION RIGHTS?
The Company is committed to making you fully aware of all of your data protection rights. Every User is entitled to the following: The right to access - You have the right to request from the Company copies of your personal data. We may charge you a small fee for this service.
The right to rectification - You have the right to request that the Company correct any information you believe is inaccurate.
You also have the right to request the Company to complete information you believe is incomplete.
The right to erasure - You have the right to request that the Company erase your personal data, under certain conditions.
The right to restrict processing - You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
The right to object to processing - You have the right to object to the Company’s processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that the Company transfer the data collected to another organization, or directly to you, under certain conditions.
Clients who voluntarily provide their personal data in order for the Company to provide Services do so pursuant to the Company’s User Agreement.
The retention, return, transfer, and destruction of personal data provided for such purposes is subject to the terms of such User Agreement.
If you make a request, the Company has one month to respond to you. If you would like to exercise any of these rights, please contact us at the information provided below.

Your California Privacy Rights
California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are required to respond to a customer request only once during any calendar year. To make such a request you should contact the Company at the information provided below.
In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information sharing that is covered will be included in our response.

WHAT ARE COOKIES?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Site, we may collect information from you automatically through cookies or similar technology.

HOW DO WE USE COOKIES?
The Company uses cookies and similar technologies for purposes such as:
• Authenticating Users
• Remembering User preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those.

HOW TO MANAGE YOUR COOKIES
You can set your browser not to accept cookies, and you can remove cookies from your browser. However, in a few cases, some of the Site features may not function as a result.

PRIVACY POLICIES OF OTHER WEBSITES
The Site contains links to other websites. This Policy applies only to the Site. If you navigate to any other website from a link on the Site, you should review the privacy policy of such website.

CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users' personal information, through a notice on the Website home page or in the Platform. The date the Policy was last revised is identified 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 our Resources and this Policy to check for any changes.

HOW TO CONTACT US
If you have any questions about this Policy, the data we hold from you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us: Email: [email protected]