PRIVACY POLICY
V.26.02

INTRODUCTION

Ethos Multiverse Inc. and our affiliates and subsidiaries (“Ethos”, the “Company”, “we” or “us”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

•  How we collect, use, disclose, and protect the information, including personal information, of users of our Platform (“you").
• The types of information we may collect from you or that you may provide when you visit or use the functionality of website www.heyethos.com, all related websites, subdomains, related tools, mobile applications, web applications, decentralized applications, technologies, databases, software, systems, APIs and all other technologies, platforms or sites owned or operated by Ethos including social media platforms (collectively, the “Platform”).
• Our practices for collecting, using, maintaining, protecting and disclosing that information.

We take steps to ensure that the personal information that we collect about you is adequate, relevant and used for limited purposes.

This policy applies to information we collect, use, or disclose about you:

• On the Platform.
• In email, text, and any other electronic messages between you and Ethos.
• Through any mobile and desktop applications or files you may have downloaded from the Platform, which provide dedicated non-browser-based interaction between you and the Platform.
• When you interact with any connections, applications or services on or through third-party websites and services if third parties include links to this policy.

The Platform may include links or functional connections to third-party websites, plug-ins, services, social networks or applications. Clicking on such links or using or enabling such connections may allow the third party to collect or share information or data about you. If you follow a link to a third-party website or engage in the use of a third-party plugin, application or service, please note that these third parties may have their own privacy policies, and we do not accept any responsibility or liability for such policies. We do not control the actions of any third parties, and we encourage you to read the privacy policy of every website, service and application that you may visit, access or use.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with this policy and the practices outlined herein, you may choose to not use the Platform. By accessing or using the Platform in any manner or capacity, you indicate your understanding and acceptance of this policy in its entirety.

We collect, use, and disclose your personal information with your consent and as permitted by applicable privacy laws. Consent is not the only basis on which we may process your personal information. Where the law of your jurisdiction permits or requires it, we may also process your personal information on other legal bases, such as the performance of a contract with you, compliance with our legal obligations, or our legitimate interests. If you are located in the European Economic Area or the United Kingdom, the specific legal bases we rely on are described in the “Additional Information for Users in the European Economic Area” section below. The Platform is not intended for children under the age of 13 (or equivalent minimum age in relevant jurisdiction), and we do not knowingly collect personal information from such children. Depending on the information we collect and the purposes for which the personal information will be used, your consent may be express or implied. When you access or use the Platform in any capacity or voluntarily provide any information, including any personal information, to us, you acknowledge and consent to all provisions of this policy. If you wish to withdraw your consent to our collection, use, or disclosure of your personal information, please refer to the “Withdrawing Your Consent” section below.

This policy may change from time to time. Your continued use of the Platform after we make changes indicates that you accept and consent to those changes, so please regularly check the Platform for the most recent version of this policy and review it for any relevant changes.

INFORMATION WE COLLECT ABOUT YOU

We may collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, including your contact information (which may include your name, mailing address, email address, telephone number or other information), your account information (such as your username, password or other information), your payment information (such as your credit card information or other information) and any other information or identifiers.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as, demographic information, or statistical or aggregated information. Statistical or aggregated information does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Platform feature.
• Technical information, including your login information, browser type and version, time zone setting, browser types and versions, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use and usage details.
• Non-personal details about your Platform interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Platform (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),methods used to browse away from a webpage, or any phone number used to contact us.
• Other information, and any other personal information that you or other parties give to us or submit to us on a voluntary basis.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

•  Direct interactions with you when you provide it to us, for example, by filling in forms, entering information on the Platform or corresponding with us by phone, email or otherwise.
• User generated content. We may collect content or other information, including personal information (such as testimonials, blog posts, messages and any associated pictures photos or videos or other forms of media, data or content)that you may provide, enter, create or upload when you interact with the Platform.
• Automated technologies or interactions, through your use of the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• Third parties or publicly available sources, including from payment processing providers, risk assessment providers and other service providers, technology providers and business partners.

Information You Provide to Us

The information we collect directly from you on or through the Platform may include:

• Information that you provide by filling in forms on the Platform or otherwise entering, uploading or providing information on the Platform. This includes information provided at the time of creating an account on the Platform, enrolling in a membership, posting material or content anywhere on the Platform, and requesting or utilizing other services. We may also ask you for information when you contact us through any means.
• Records and copies of your correspondence (including emails), if you contact us.
• Details of activities or transactions you may carry out through the Platform, including for example you may be required to provide payment information (such as your credit card information) before enrolling in a membership where such membership requires the payment of a membership fee.

You may voluntarily provide information to be published or displayed (“Posted”) on public areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). You accept that any User Contributions are provided by you at your own risk and that User Contributions may be Posted on public areas of the Platform or transmitted to other users of the Platform or third parties and that you may not be able to control, edit or delete such User Contributions once Posted. You may be able to set certain privacy settings by logging into your account or by contacting us. Please be aware that no security or privacy measures are perfect. Additionally, we cannot control the actions of other users of the Platform or any other third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions or use your User Contributions in some unauthorized or inappropriate capacity and accordingly we are not responsible for the use by any other third party of any of the User Contributions that you disclose, transmit, display or enter in the Platform.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies  

As you access, use and interact with the Platform, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking).

Information we collect automatically is statistical information in nature which may include personal information as we may associate it with personal information we collect in other ways or receive from third parties. Such information helps us to operate and improve the Platform and to deliver a better and more personalized service to you, including by enabling us to:

•  Estimate our site traffic volume, audience size and usage patterns.
•  Store information about your preferences which allow us to customize the Platform according to your specific interests.
• Recognize you when you return to the Platform.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you refuse to accept browser cookies you may be unable to access or use certain parts of the Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access or use the Platform.
•  Flash Cookies. Certain features of the Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies.
• Web Beacons. Certain components of the Platform including our emails or other electronic communications may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that may provide the Company with certain website or Platform statistics. For example, counting the number of users who have visited certain webpages, accessed certain components of the Platform or opened certain emails.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information, for the following purposes:

• To operate and make available the Platform, its functionality and contents to you.
• To contact and correspond with you directly for purposes including to manage our relationship.
• To facilitate and manage your account and to process any activities or transactions on the Platform.
• To provide you with information or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you may have provided it to us.
• To provide you with notices including about your account, activities, transactions or memberships.
• To carry out our obligations and enforce our rights relating to any agreements with you, including for billing and collection or manage risk and to comply with legal requirements.
• To notify you about changes to the Platform or any services we offer or provide though it.
• To improve the Platform or services, marketing or customer relationships and experiences.
• To allow you to participate in all relevant features, social media, or similar features or functions on the Platform.
•  To measure or understand the effectiveness of the information we provide to you and others, and to deliver relevant information to you.
• To send you commercial electronic messages, which could include messages about your activities or transactions on the Platform, upcoming events or offers available from Ethos, news or upgrades to the Platform or other information that may be relevant or of interest to you.
• To detect and prevent fraud and protect the security of the Platform.
•  To meet our legal obligations and for regulatory purposes.

We may also use your personal information to provide you with information or services you request or for other purposes that we may identify.

If you do not want us to use your information in this way, please contact us at privacy@heyethos.com. For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION

Except as described in this policy or in other situations where we have provided you with notice, have obtained your consent, or are obligated or permitted by law, we will not share your personal information with third parties.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide, as described in this privacy policy:

• To our subsidiaries and affiliates to operate the Platform and to continue operation of the Platform in the event of any potential future reorganization of the business.
• To successor entities or acquiring entities in the event of a potential sale or transfer of any part or all of the business as we may decide to sell or transfer all or part of our business to a related company or to a third party company, to merge with another entity, or to engage in another form of corporate or financing transaction (including transfers made as part of insolvency or bankruptcy proceedings or as part of a corporate reorganization).We may share your personal information in connection with the evaluation of and/or entry into such transactions.
• To contractors, subcontractors, service providers and other third parties we use to operate the Platform and to support our business such as cloud service providers, analytics providers and artificial intelligence models and to our brands who use such information to operate and improve their customer loyalty programs. Where applicable and appropriate, information may be anonymized or de-identified before being used by third-party artificial intelligence tools or machine learning models. Such service providers assist us with the analysis required to improve the Platform and overall service optimization. We take reasonable steps to help ensure that such parties only use personal information for authorized purposes and that such parties implement reasonable privacy and security safeguards appropriate to the personal information they handle. Where you provide information directly to third party providers who operate on our behalf, you may be subject to the collection practices, terms of use and privacy policies of those third parties. You are responsible for reviewing and agreeing to those privacy policies and terms and conditions. In certain circumstances your information may be tokenized or otherwise encrypted or anonymized so that certain parties, including at times Ethos, do not have direct access to such information even if such information is initially entered into online properties, applications or technologies operated by such parties.
• To fulfill the purpose for which you provide it. For example, if you give us an email address with the instructions to "email a friend", we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us, including as set out in any agreement between you and us.

If you are a user who has enrolled in a membership your information, including your personal information, will be shared with our brands to allow the operation of their loyalty programs and to facilitate any relevant brand benefits associated with their loyalty programs. All of our brands are contractually obligated to treat such information in accordance with their own privacy terms and conditions. We take reasonable steps to ensure that our brands are only using personal information for authorized purposes and that they implement reasonable privacy and security safeguards.

We may also disclose your personal information:

• Where authorized or required by law. For example, we may disclose your personal information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms and agreements with you, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property or safety of Ethos, our brands, our users or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

ADDITIONAL INFORMATION FOR USERS IN THE EUROPEAN ECONOMIC AREA

You are able to contact our Privacy Officer at: privacy@heyethos.com. The data controller is Ethos Multiverse Inc., 1600 – 925 West Georgia Street, Vancouver, BC V6C 3L2, Canada. The data that we collect from you, including your personal data and information, may be transferred, stored and accessed in countries outside the European Economic Area.

Legal Bases for Processing

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), our collection and use of your personal information is governed by the EU General Data Protection Regulation (GDPR) and, where applicable, the UK GDPR. We only process your personal information where we have a valid legal basis to do so under Article 6(1) of the GDPR. We rely on the following legal bases:

• Performance of a contract (Article 6(1)(b)). Creating and administering your account; enrolling you in and operating a membership; processing your activities, transactions and payments; providing the Platform, its functionality and the services, information or content you request; and providing related notices and customer support.

• Consent (Article 6(1)(a)). Sending you commercial electronic messages and other marketing communications; using cookies and similar technologies that are not strictly necessary; and behavioural tracking and online advertising. You may withdraw your consent at any time (see below).

• Legitimate interests (Article 6(1)(f)). Operating, securing, improving and developing the Platform and our services; understanding how the Platform is used and measuring the effectiveness of our communications; managing our relationship with you; detecting, preventing and investigating fraud, misuse and security incidents; and establishing, exercising or defending legal claims — where these are not overridden by your interests, rights and freedoms.

• Legal obligation (Article 6(1)(c)). Complying with our legal, regulatory, accounting and reporting obligations; responding to lawful requests from courts, regulators and law enforcement; and retaining information where required by law.

Consent. Where we rely on your consent, you may withdraw it at any time by contacting us at privacy@heyethos.com or, for marketing emails, by using the unsubscribe link. Withdrawing your consent does not affect the lawfulness of any processing we carried out before you withdrew it, and does not affect processing we carry out on another legal basis.

Legitimate interests. Where we rely on legitimate interests, we have assessed whether those interests are overridden by your interests, rights and freedoms. You have the right to object to this processing; if you do, we will stop unless we have compelling legitimate grounds to continue or we need the information to establish, exercise or defend legal claims. You may contact us for more information about this assessment.

Special categories of data. We do not seek to collect special categories of personal data (such as data revealing health, ethnic origin, religious beliefs or biometric data). If we ever need to process such data, we will do so only where an additional condition under Article 9 of the GDPR applies, such as your explicit consent.

International transfers. Where we transfer your personal information outside the EEA or the UK, we take steps to ensure it receives an adequate level of protection, including by transferring it to a country recognized as providing adequate protection or by putting in place appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum, where applicable). You may contact us to obtain a copy of these safeguards.

Your rights. Subject to applicable law, you have the right to access, correct, update or request erasure of your personal information; to restrict or object to certain processing; to request portability of your personal information; and to withdraw consent. To exercise these rights, contact our Privacy Officer at privacy@heyethos.com.

ADDITIONAL INFORMATION FOR USERS IN CALIFORNIA

We do not sell unaggregated personal information to third parties for their marketing purposes. In accordance with applicable California privacy laws, including the California Consumer Privacy Act, as ammended by the California Privacy Rights Act, under certain circumstances California users have the right to request Ethos to disclose or to delete specific components of personal information that Ethos may have collected. If you are a California user, you may submit a request by email for this information or for deletion of this information by contacting: privacy@heyethos.com. If required to do so, we will respond to your request in the manner and time provided for in accordance with the California Consumer Privacy Act, as amended.

 INTERNATIONAL DATA TRANSFERS

We may process and store personal information in jurisdictions outside of the country in which it was collected, including jurisdictions that may have different data protection laws. We take reasonable technical and organizational measures to protect personal information in accordance with this Privacy Policy. In certain circumstances, personal information may be accessible to governments, courts, law enforcement or regulatory agencies in accordance with applicable law.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the information, including personal information, you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Platform may not be accessible or may not function properly.
•  We do not control actions or activities conducted by third parties including those relating to the collection or use of your information. However, third parties may provide you with ways to choose not to have your information collected or used in certain ways. Withdrawing your consent from a third party may not mean you will no longer receive any online advertisements. It may mean that the third party from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
•  Promotional Offers from the Company. When you access or use the Platform in any capacity or voluntarily provide any information, including any personal information, to us, you may receive commercial electronic messages from us. If you no longer wish to receive these types of communications from us, you can opt-out by sending us an email stating your request to privacy@heyethos.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we may have included in the email or by contacting us. If you opt-out of promotional emails, we may still use your e-mail address to communicate with you regarding important matters in accordance with relevant privacy laws.

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DATA SECURITY

• Data Security. The security of your personal information is very important to us. We use physical, electronic and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
• The safety and security of your information also depends on you. You are responsible for choosing a strong and unique password for all relevant accounts and for keeping your password confidential. We ask you not to share or disclose any of your passwords with anyone.
• Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained within the Platform.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. Please contact our privacy officer in writing at the contact information noted below, with sufficient detail to enable us to identify the personal information being sought or corrected.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions may include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process, if applicable.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

You may request a copy of your personal information in a structured, commonly used and machine-readable format.

We may charge a reasonable fee according to the cost required to retrieve and provide access to the requested information. We may provide an estimate of the fee in advance and in some cases, will require a deposit for all or part of the fee.

If you are concerned about our response or would like to correct the information provided, you may contact us at privacy@heyethos.com.

WITHDRAWING YOUR CONSENT

You have the right to withdraw your consent to the collection, use, and transfer or disclosure of your personal information. In some cases, withdrawal of your consent may not be possible due to legal obligations or requirements. To withdraw your consent, contact us at privacy@heyethos.com. Please note that if you withdraw your consent, you may not be able to use certain functions within the Platform or you may not be able to access or use the Platform in its entirety.

CHANGES TO THE PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we may notify you through a notice on the Platform or through other means.

We include the date the privacy policy was last revised 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 the Platform and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this policy and our privacy practices. Please contact us at:

Privacy Officer
privacy@heyethos.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.

If you have concerns of our handling of personal information, please contact us using the information above. Depending on your jurisdiction, you may also have the right to lodge a complaint with a relevant data protection or privacy authority.

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LANGUAGE DISCREPANCY

In the event of any discrepancy or inconsistency between this policy and any translated version or versions of this policy, the policy in the English version shall prevail, govern and control.

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