Project Canary Privacy Policy

Effective Date/Last Updated: April 19th, 2021

This Privacy Policy applies to information Project Canary, PBC and all of their subsidiaries and affiliated companies ("Project Canary", "we," "us," "our") collect from or about you, including when you use our website at https://www.projectcanary.com/ and related web pages where this Privacy Policy appears (collectively, "Site"), our mobile applications (collectively, the "App"), services, offerings, or when you otherwise invest with us, contact us, engage with us on social media, or interact or communicate with us (collectively, "Services").

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Site homepage or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Contents

• Collection of Information
• Use of Information
• Sharing of Information
• International Transfer of Information
• Your Choices
• Additional Disclosures for Individuals in the Europe
• Contact Us

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, you may share information directly with us when you subscribe to an investment product, email us, fill out a web form, communicate with us via third-party platforms, create an account on the Services, or otherwise interact with us. The types of personal information we collect may include your name, email address, postal address, phone number, and any other information you choose to provide.

Information Collected Automatically

When you access or use our Site or Services, we may automatically collect information about your activities. For example, we and our service providers may use tracking technologies, such as cookies and web beacons, to collect information about your use of our Site and Services, including your browser type, operating system, IP address, access times, pages viewed, and links clicked. We and our service providers may also collect information about your use of the App, such as IP address, device name, operating system version, the configuration of the App when utilizing our Services, the time and date of your use of the Services, and other statistics.

We use cookies and similar technologies to facilitate some of this automatic data collection. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. Web beacons (also known as "pixel tags" or "clear GIFs") are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand and analyze usage. In addition, our App may use software development kits, or SDKs. SDKs are third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our App or to add features or functionality to our App. SDKs may enable third parties to collect information directly via our App.

For more information about cookies and how to disable them, see Your Choices section below.

Information We Collect from Other Sources

We may also obtain information about you from other sources. For example, we may collect information about you from data analytics providers, marketing automation platforms, email providers, and other third-party sources.

Information We Derive

We may derive information or draw inferences about you based on the information that we or our service providers collect. For example, we may make inferences about your country of residence based on your IP address or infer that you may be interested in certain Services based on your browsing behavior.

Use of Information

We use the information we collect to communicate with you, fulfill regulatory requirements, enter into agreements, and understand the interest for our core services. We also use the information we collect to:

• Provide, maintain, and improve our products and services;
• Send you support and administrative messages, respond to your comments, questions, and provide you client service;
• Communicate with you about products, services, and events offered by Project Canary and others, and provide news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
• Monitor, analyze, and track data, usage, and activities in connection with use of our Site;
• Tailor your experience on or with respect to our Services;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Project Canary and others;
• Debug to identify and repair errors in our Services;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We share personal information as follows or as otherwise described in this policy:

• With service providers, vendors, and consultants that perform services for us, such as companies that assist us with web hosting and security, shipping and delivery, general administration, customer relationship management, email delivery, App delivery, customer service, and marketing;
• Publicly on our Site or Services if you submit comments or post content in another public area of our Site or Services;
• If we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Project Canary, our users, the public, or others;
• With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Project Canary and our current or future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

International Transfer of Information

Project Canary is headquartered in the United States and have operations and service providers in other countries, including Canada. We and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your jurisdiction of residence. By providing us with your data, you consent to its transfer to and processing within the United States, Canada, and in any other country where we or our service providers may process your information.

You Choices

Account Information

If you wish to change or update your contact information or other investor information we have about you, please email us at info@projectcanary.com. But note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of some of our Services.

Promotional Communications

You may opt out of receiving promotional emails from Project Canary by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Do Not Track Signals

Project Canary does not respond to "Do Not Track" signals.

Additional Disclosures for Individuals in the Europe

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on one or more of the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., email correspondence).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
• When we find such processing is necessary to comply with a legal obligation to which we are subject (e.g., to track those who have opted-out of marketing communications).
• When we have your consent to do so (e.g., when you agree to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data for as long as is necessary for the purpose(s) for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Data Subject Requests

You have the right to request access to the personal data we hold about you and to ask that your personal data be corrected, erased, or transferred in a portable format. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at info@projectcanary.com.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. Contact details of your Data Protection Authority can be found using the links below:
For individuals in the EEA: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@projectcanary.com.