Privacy & Policy

Introduction

This Privacy Policy explains how Clappe Inc and its affiliated companies (collectively, "Clappe", "us", "we" or "our") collect, use, disclose, transfer, protect, store and otherwise process your personal information. It also explains your rights and options around our use of your information and how you can exercise these choices. From time to time, we will need to update this Privacy Policy and we encourage you to check it regularly so that you stay informed. If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact us using the information provided below.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us via the method on last page.

What Personal Data Do We Receive?

In registering for or using our Services, you provide us with certain information which we store securely. To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person ("Personal Information"). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

We collect certain information when you register for our Services, including:

• Contact information, such as name, email address, mailing address, phone number and country.
• Profile information, such as a username, profile photo, and job role.
• Preferences information, such as notification, account plan information, billing information and marketing preferences.

Information we collect when you use the Service

We also store information that you choose to upload to or send to us through our Services, that may include:

• Information about products and services the Subscriber sells (including inventory, pricing, sale, transaction, tax, and other data)
• Information about the Subscriber or the Subscriber's business (employee, customer, and contact data)

Information we collect from other sources

We also may collect certain information from you when you submit web forms on our websites or when you participate in any interactive features of our Services (such as a promotion, activity, survey, competition, or event), request customer support, apply for a job, download content, communicate with us via third party social media sites, or other form of communication with us.

Chidren's Privacy & Information for Parents/Guardians

We do not knowingly solicit, collect, maintain, or disclose any Personal Information from children under the age of 16. If you are under the age of 16, please do not:

• Create or attempt to create an account on the website.
• Sign up for any subscription service via the website.
• Buy anything through the website; or
• Otherwise interact with the website.

Occasionally, we may collect Personal Information from minors who are under 16 in person at tradeshows or for product testing with proper consent from a parent or legal guardian. We may collect name, online identifiers, and email address. We may use this information to provide with communications, conduct contests and promotional events, and participate in product testing.

As a parent or legal guardian, you may request that we delete Personal Information collected from your child in person at any time by contacting us at the email address or telephone number provided below. We will delete such information from our database within a reasonable time.

To request that we delete your child's Personal Information, or if you have questions regarding our practices as to Personal Information about children, please contact us at: privacy@clappe.com

If we learn that we have collected Personal Data of a child under 16, we will take steps to delete such information from our files as soon as practicable.

How we Use the Information that we Collect

We collect your Personal information for the following purposes:

• To provide and operate the Services.
• To provide our Users with ongoing customer assistance and technical support.
• To process payments to us for the Services.
• To get a better understanding of how you browse our Websites so that we can optimize your experience.
• To research and analyze your use of or interest in our Services and those products and services offered by others.
• To improve the functionality of our Websites and Services.
• To help you find the most relevant information by customizing our Services to optimize your experience.
• To perform any additional purposes explicitly described to you at the time of collection and for which we receive your consent.
• To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants' eligibility, monitor performance, contact winners, and grant prizes and benefits.
• To comply with any applicable laws and regulations.

Lawful grounds for processing (for individuals located in the EEA or the UK)

If you are an individual residing in the European Economic Area ("EEA") or the United Kingdom ("UK"). we can only process your Personal Data if we have a lawful ground to do so. Depending on the processing activity, we can process your Personal Data on the following grounds:

• To comply with our obligations under an agreement we concluded with you, such as to provide our Services.
• Where you have freely given your explicit consent and this consent has not been revoked.
• Where we are pursuing a legitimate interest, which is not outweighed by your fundamental rights or freedoms; or
• Pursuant to a legal obligation under EU law or the law of a member state of the EU; or
• In very exceptional cases to protect your vital interests.

How Do We Share Personal Information?

Clappe provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

• Resellers: If an account owner licensed Clappe from a third-party reseller of Clappe Products and services ("Services"), the reseller may be able to access personal data and content for users
• Service providers: Clappe works with third-party service providers to provide, support, and improve Clappe Product and services ("Services") and technical infrastructure. Clappe may also work with third-party service providers to provide advertisements and business analytics regarding Clappe Products. These providers can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Clappe or as required by law.
• For Legal Reasons: Clappe may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; 4) meet our corporate and social responsibility commitments; (5) protect our and our customers' rights and property; and (6) resolve disputes and enforce agreements.
• Marketing and Analytics Partners: Clappe uses third-party marketing and advertising providers to provide statistics and analysis about how people are using our website and to provide advertising and marketing, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on Clappe website through third-party cookies placed on Clappe website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool. Where required by law, Clappe will first obtain your consent before engaging in the activities described here.
• Corporate Affiliates: We may share your Personal Information internally within our family of companies, for the purposes described in this Privacy Policy. For example, we may share your Personal Information with "clappe store", in the course of facilitating and providing you (and your Users-of-Users) with our Services. Sharing Personal Information by Clappe subsidiaries and affiliated companies in the European Union, the United Kingdom and Switzerland with Clappe subsidiaries located outside these regions will only take place under an approved transfer mechanism, such as the relevant Standard Contractual Clauses.
• Integration partners: Subscribers may choose to connect the Services to the services of one of o many integration partners for added functionality. By setting up these connections, you allow Clappe to share certain information with these integration partners.
• Social Network Sharing: Our Services may include social media features, such as the Facebook "Like" button and widgets, and the "Share" button or interactive mini programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.
• User-Generated Content (UGC): Some parts of our Websites and Services may allow Visitors, End-Users, and Subscribers to submit and view UGC. UGC includes such things as posting a question, an answer, or a blog post. When you post UGC, other Visitors or Subscribers will be able to see certain information about you, such as your username or handle. You should be aware that any Personal Data you submit in UGC can be read, collected, distributed, or used by other Visitors or Subscribers and could be used by third parties to send you unsolicited messages. We are not responsible for the Personal Data you choose to include in the UGC you provide through the Websites or Services.
• Links to third party sites: Our Services may contain links to other sites. We have no control over, and take no responsibility for, the privacy practices or content on other sites. You are responsible for checking the privacy policy of any such sites so that you can be informed of how they handle personal information.
• In connection with a change in corporate control: In addition, should Clappe or any of its affiliates undergo any change in control, including by means of merger, acquisition, or purchase of substantially all its assets, your Personal Information may be shared with the parties involved in such event

How do we Protect your Personal Data?

We treat your Personal Data as private, confidential information and we strive to ensure that Personal Data under our control, regardless of format, is always protected and kept secure. Please be aware, however, that no method of transmitting information over the Internet or of storing information is completely secure. Accordingly, we cannot absolutely guarantee the protection of any information shared with us. In the event of an unauthorized loss or disclosure of Personal Data, Visitors, Subscribers and End-Users may be subject to a risk of harm resulting from such loss or disclosure. Depending on various factors, such as the type and amount of Personal Data disclosed, consequences for individuals could include changes to their credit bureau rating or financial situation or identity theft. Clappe will always comply with applicable laws concerning data breach notification requirements and will endeavor to mitigate any risks of residual harm to the affected individuals.

Location of Personal Data

Your Personal Data may be stored on servers located in a country other than where you reside or do business. Please refer to this website for our list of service providers (sub-processors) and their established location. Personal Data may be subject to the local laws of the jurisdictions within which it is collected, used, disclosed and/or stored, and may be accessed by governmental authorities and law enforcement agencies in those jurisdictions. When the data concerns Personal Data of data subjects from the EEA or the UK, we will provide for an adequate level of protection of this data. Currently, Data are stored in Canada server.

Retention of Personal Data

Clappe retains your Personal Data for as long as it is reasonably needed to deliver the Services. The retention terms can be longer if we are required to keep Personal Data longer on the basis of applicable law or to administer our business. Where you have the right to request deletion, we will delete your Personal Data in accordance with and upon receipt of written instructions from you to this effect, unless we are legally required to keep it. You may choose to do this in the event you terminate your agreement for the Services. If deletion is not possible, we will de-identify it in a way that cannot be reversed. If de-identification is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

International Data Transfers

We may transfer to, and store the data we collect about you in, countries other than the country in which the data was originally collected, including Canada, France, Italy, Germany, Singapore, or other destinations outside the European Economic Area ("EEA") or the United Kingdom ("UK"). Those countries may not have the same data protection laws as the country in which you provided the data. However, when we transfer your data to other countries; we will protect the data as described in this Privacy Policy and comply with applicable legal requirements for the transfer of data to third countries outside the EEA or the UK. If you are located in the EEA or the UK, we will only transfer your personal data if the country to which the personal data will be transferred has been granted a European Commission adequacy decision, or if we have put in place an appropriate transfer mechanism and appropriate safeguards with any recipient or sub-processor, such as Standard Contractual Clauses as adopted by the European Commission or Data Processing Agreements ensuring an adequate level of data protection.

Accountability for Third Parties

We may transfer Personal Data to third parties for processing on our behalf. We will ensure that such data may only be processed for limited and specified purposes consistent with the purposes for which such Personal Data was collected, or the consent provided by you. In addition, any such third-party processor will process the data with the same level of protection as the protection provided by us including adherence to the data processing agreement executed with us to the extent it relates to Personal Data that is transferred from the EEA, the UK or Switzerland.

Your Rights in Relation to your Personal Data

What are my Rights?

Right to Know about the Collection, Disclosure and Sale of Personal Data. You may ask us about what Personal Data we have collected about you and whether or not we have disclosed or sold such Personal Data to third parties.

Right to Access, Rectify, or Transfer your Personal Data

You have the right to access your Personal Data at any time and to receive a copy of the Personal Data undergoing processing. You can require us to correct or complete your Personal Data if it is not correct or complete. You can also ask us to provide your data in a commonly used electronic form.

Right to Object to Further Processing of your Personal Data

If we are processing your Personal Data based on a legitimate interest, you may object to the processing activity. Upon receipt of an objection, we will cease the processing activity for the future unless we can demonstrate a legitimate ground which overrides your interests, or that the processing is necessary for the establishment, exercise, or defense of legal claims. Please note that your exercise of this right may result in Clappe being unable to continue providing all or part of the Services to you.

Right to Deletion and to Restrict Processing of your Personal Data

If there is no longer a reason for us to process your Personal Data or if we don't have a legal ground for the processing, you can require us to delete your Personal Data. We will take steps to delete your information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law. In addition, we may choose to de-identify your Personal Data instead of deleting it, provided we have a legitimate business reason for doing so. You can also require us to restrict the processing of your data if such processing is unlawful or if there is a dispute about the accuracy of the data.

Right to Non-Discrimination for Exercising your Rights

In the event you exercise one of the rights outlined in this section, Clappe will not discriminate against you for having done so. In particular, we will not deny you any goods or services, charge you different prices for goods or services, or provide you with different quality levels of goods or services.

Right to Opt-Out of the Sale of your Personal Data (For individuals located in California only)

Clappe does not sell Personal Data within the meaning of applicable privacy laws. Should Clappe consider selling Personal Data, we will only do so with your consent, and you will have the right to opt-out from the sale of your Personal Data at anytime.

Right to lodge a complaint with a supervisory authority (For individuals located in the EEA & UK only)

You have the right to lodge a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that Clappe processing of your personal data infringes the GDPR. Please visit the website of the relevant supervisory authority for more information on how to submit such a complaint.

How can I Invoke my Rights?

If you wish to invoke any of your rights in relation to your Personal Data, you may do so using one of the following methods. Online Privacy Request. You may submit a request to exercise any of your data rights (a "Privacy Request") by emailing us at privacy@clappe.com. Or mail us

Privacy Officer
Clappe Inc.
Suite C, 16644- 71st
Edmonton. AB. T5Z0N5.
Canada.

Canada's Anti-Spam Law (CASL)

For Canadian Visitors and Subscribers: When you voluntarily and expressly provide Personal Data, an existing business relationship is created under Canada's Anti-Spam Law (CASL). We may use your Personal Data to provide you with information that is relevant to you or your business, such as newsletters, event invitations, or updates about Services. In some cases, we may collect, use or disclose Personal Data without your consent or knowledge (e.g., we may use your Personal Data where it's been conspicuously published on a website or directory). While we offer you some control over marketing communications, certain transactional, relationship and legally required communications will not be affected by the choices you have made about marketing communications. You have the right to revoke your consent to the collection, use and disclosure of your Personal Data and to unsubscribe to electronic communications at any time.

Electronic Messages to Canadians. Our Services allow Subscribers to collect and use the Personal Data of End-Users, through communications or transactions facilitated by Clappe. You may not use the Services to send your Canadian-based End-Users commercial electronic messages without first obtaining their express consent or otherwise complying with other legal requirements.

Security

We have adopted technical, administrative, and physical procedures to collect, manage, maintain, and store information in a manner designed to help protect your information from loss, misuse, unauthorised access, and alteration. Unfortunately, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. Where data is transferred over the Internet as part of the Services, the data is encrypted using industry standard TLS (HTTPS).

Our global operations (including transfers of data from your home country to another)

We operate globally and therefore, in order to provide you with our Services, your personal information may be transferred to, and processed in countries other than the country in which you live in, including to Canada, Australia, New Zealand, Germany, France, Italy and United Kingdom. These countries may have laws different to what you're used to and, in some cases, less protective. Rest assured, wherever we transfer and process your information we put safeguards in place to ensure that your information remains protected. Specifically, Clappe hosts data with Digital Ocean In Canada. If you are a non-Canada resident, this means that your personal information will be transferred to Canada. The servers on which personal information is stored are kept in a controlled environment.

For Subscribers who reside in the European Economic Area (EEA), Switzerland and the United Kingdom, when your personal information is transferred outside of your home country it will only be transferred to countries that have been deemed to provide an adequate level of protection for personal information (like Canada), or to a third party where we have approved transfer mechanisms in place to protect your personal information – i.e., by entering into the European Commission's Standard Contractual Clauses.

For Australian Subscribers, the third parties we share your information with do not control and are not permitted to access or use your personal information, except for the limited purpose it was provided. This means that, for the purposes of Australian privacy legislation and Australian Subscribers, Clappe does not disclose personal information to third parties located overseas.

Where We Store your Personal Information

Clappe is a global organization with its headquarters in Canada. As such, your information, including your Personal Information, may be transferred to, stored in, entities affiliated with us and other third parties located in countries which do not have the same level of data protection laws as those in the country where you are located.

Links to Other Sites

Our site may contain links to the websites of third parties. If you choose to follow a link to any of these websites, please note that these websites have their own privacy policies and that Clappe does not accept any responsibility or liability for these policies. Please check these policies before you provide any Personal Information to these websites.

Information retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (in connection with the purposes described in this Privacy Policy). For information about how long any of our Subscribers retain your personal information, please contact that Subscriber.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

General Matters

Updates to our privacy policy

We may update this Privacy Policy from time to time to reflect changes to our information practices. Any changes we make will become effective when we post a modified version of the Policy on this webpage. The "Effective Date" at the top of the Policy indicates when it was last updated. If we make material changes to the Policy, we will post a notice on our websites or in our Services. Your continued use of our websites or Services after the modified version of the policy is posted constitutes your acceptance of those changes to the policy, as well as any additional applicable requirements. If you do not agree to the changes to our policy, it is your sole responsibility to stop using our websites or Services. You are required to ensure that you read, understand, and agree to the latest version of the Policy.

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or "port" that data to another provider.
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications.
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data.
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data, we hold about you is not accurate or lawfully held).

In order to exercise any of your rights as to personal data controlled by Clappe, or if you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Clappe processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Clappe services to account owners, their users, and those they invite to manage their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all Products, features, and services.
• Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool.
• As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity ("fraud and abuse detection") and compliance with privacy laws.
• To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
• As necessary for our (or others') legitimate interests: Unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

International Data Transfers

Clappe operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Clappe or its service providers have customers or facilities.

Therefore, by using Clappe services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in Canada where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission's standard contractual clauses. Please contact us if you would like further information in that respect.

California Privacy Rights

California Consumer Privacy Act

Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:

• Access the categories and specific pieces of personal data Clappe has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Clappe has shared personal data.
• Delete personal data under certain circumstances; and Opt out of the "sale" of personal data. We do not sell your personal data in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. The CCPA's statutory definition of the term "sale" is broad and may include interest-based advertising. You can get more information and opt out of the use of cookies on our sites for interest-based advertising purposes by clicking the Do Not Sell My Personal Information link, in the webpage footer, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to reset your settings.

Clappe will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.

To exercise your rights, contact us by emailing privacy@Clappe.com. To opt out of the use of cookies on our sites for interest-based advertising purposes, follow the instructions on cookies policy.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 44 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.

Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Clappe account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

California's Shine the Light Law

California Civil Code Section 1798.83, also known as "Shine the Light" law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties' direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties' direct marketing purposes.

Do You Have Questions?

Thanks for reading! If you have any questions about this Privacy Policy or Clappe's privacy practices, or would like to request a printable version of the Privacy Policy, please contact us at privacy@Clappe.com or at our mailing address below:

Privacy Officer
Clappe Inc.
Suite C, 16644- 71st
Edmonton. AB. T5Z0N5.
Canada.