Privacy Policy

Last update: 2024-09-20

At Haply Robotics Inc., we are committed to protecting and respecting your privacy.

This policy applies to the Haply Robotics websites, and related services (the “Platform”). It explains our practices concerning the personal data we collect from you, or that you provide to us, in connection with the Platform. It does not apply to other products or services that display or reference a different privacy policy. If you do not agree with this policy, you should not use the Platform.

The Platform is provided and controlled by Haply Robotics, with its registered address at 400-4316 St Laurent Blvd Montreal Quebec H2W 1Z3 Canada (“we”or “us”). If you have any questions about how we use your personal data, please contact info@haply.co.

1. The types of personal data we use

The information we collect depends on how you use the Platform and the choices you make. We collect information about you from different sources and in various ways when you use our products, including information you provide directly, third-party data sources, information collected automatically, and data we infer or generate from other data. More information about the categories and sources of information is provided below.

Information you choose to provide

For certain activities, such as when you register, upload content to the Platform,or contact us directly, you may provide some or all of the following information:

• Inquiry details

• Name

• Phone number

• Email

• Country and city

• Registration information, such as age, username and password, language, and email or phone number

• Profile information, such as name, social media account information, and profile image

• User-generated content, such as photos and videos, documents, phone books or contacts lists, calendars, or messages you create or share with the Platform

• Payment information, such as PayPal or other third-party payment information (where required for the purpose of payment)

• Information to verify an account, such as email account

• Information in correspondence you send to us

Information from Third Parties.

You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data. We have set out further detail on the information we receive from third parties below:

• Social Networks. If you connect a social network account to the Platform, we will collect information from the social network that it makes available, which may depend on your use and settings on the social network.

• Business Partners. If you choose to register to use the Platform using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

• Advertisers and Advertising Networks. We use the information collected from you, and your interaction with the Platform and other third party sites, to infer your likely interests to provide you with more relevant advertising.

• Data Brokers. We occasionally acquire information from data brokers or aggregators to supplement the information we collect.

• Publicly available sources. We may gather additional information from other public sources of information, including open government databases.

Information we collect automatically

We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes:

• Identifiers and device information. We automatically log your IP address, mobile carrier, time zone settings,device identifiers including mobile advertising IDs, and the version of the app you are using. We will also collect information regarding the device you are using to access the Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system.

• Usage data. We automatically log your activity on the Platform,including the content you view on the Platform, how long you spent viewing such content, access times, the URL of the website from which you came to our site, and other details about your use of and actions on the Platform.

• Geolocation data. Depending on your device and app settings, we collect geolocation data when you use the Platform.

• Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Information we create or generate.

We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). We infer your general geographic location (such as city, state, and country) based on your IP address.

2. Cookies, Mobile IDs,and Similar Technologies

We use cookies, mobile IDs, and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to operate the Platform, enable us to provide certain features and functionality, and enhance your experience using the Platform.

Cookies are small text files placed on your device to store information that can be recalled by the web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies..

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our Platform contains software that enables our third-party analytics and advertising partners to access the mobile IDs.

We, and our analytics and advertising partners, use Cookies for the following purposes:

• Strictly necessary Cookies. These are Cookies that are required for the operation of the Platform.They include, for example, Cookies that enable you to log into secure areas of the Platform.

• Analytical/performance Cookies.They allow us to recognize and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform works, for example, by ensuring that users are finding what they are looking for easily. Note that we use third-party analytics tools, including Google Analytics, to perform these functions. For further information on how Google Analytics collects and processes information about you, please click here and information on how to opt out of Google Analytics is available here.

• Functionality Cookies. These are used to recognize you when you return to the Platform. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting Cookies. These Cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also make this information available to third party advertising partners, which may combine this information with information about your online activities over time and across different websites or online services for this purpose. These partners may participate in organizations that provide simple ways to opt out of analytics and ad targeting, which you can access at:

￮ United States: NAI(http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/)

￮ Canada: Digital Advertising Alliance of Canada(https://youradchoices.ca/)

￮ Europe:European Digital Advertising Alliance (http://www.youronlinechoices.com/)

Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website.If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.

Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Email web beacons. Most email clients have settings which allow you to prevent the automatic downloading of images, which will disable web beacons in the email messages you read.

Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our websites do not currently respond to browser DNT signals.Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.

3. How we use your information

We use your information to provide the Platform to you and to improve and administer it.

We generally use each of the categories of information we collect for the following purposes:

• We collect your information to contact you in a timely manner and communicate with you about products or services.

• In order to provide better services, when you communicate with us by phone or customer service tools, we will record your contact information and related communication.

• If you intend to inquire, modify, delete or withdraw the personal information you are authorized to submit, or have any questions or complaints about the protection of personal information, you can contact us, and we will cooperate as soon as possible.

We will strictly protect the security of your personal information. We will adopt appropriate systems, organizations and security technologies to protect your personal information from unauthorized access, use or leakage.

4. How we share your information

We may share each of the categories of personal data with selected third parties in or outside your country, including:

We may share your personal data with selected third parties in or outside your country, including:

• our business partners so that we can make you special offers via the Platform;

• service providers or agents that provide services to us for any of the purposes described in this policy, such as cloud storage providers to store the information we collect and for disaster recovery services, as well as for the performance of any contract we entered into with you;

• analytics and advertising providers to help us in the optimisation and improvement of the Platform and to help us serve targeted adverts, as further described in the Cookies section of this policy.

We may also share your information with any members, subsidiaries, or affiliates of our corporate group, to provide the Platform, including improving and optimising the Platform, preventing illegal use and supporting users.

We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• comply with a legal obligation, process or request (including tax and related reporting requirements);

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues; or

• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or

• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

Finally, we may share de-identified information in accordance with applicable law.

Please note that the Platform may include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy policies.

We may share your personal data with selected third parties in or outside your country, including:

• our business partners so that we can make you special offers via the Platform;

We may also share your information with any members, subsidiaries, or affiliates of our corporate group, to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.

• comply with a legal obligation, process or request (including tax and related reporting requirements);

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues; or

We will also disclose your information to third parties:

Finally, we may share de-identified information in accordance with applicable law.

5. Where we store your personal data

The information that we collect from you may be transferred to, and stored at, a destination outside of your country. It may also be processed by staff operating outside your country who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy and applicable law.

Location of Processing European Personal Data. We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protections,please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en

6. Your choices and rights

You can access and edit most of your profile information by signing into your account. We also provide a number of tools in Settings that allow you to control your information. Should you choose to do so, you may delete your entire account in Settings.

See the Cookies section of this policy for choices about cookies and other analytics and advertising controls.

If you have any questions on how to use those tools,or want to know about any rights you may have in the country where you live,please contact us at the email address provided at the bottom of this policy.

EUROPEAN DATA PROTECTION RIGHTS

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

• You can request access to, and rectification or erasure of, personal data;

• If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

• If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing;

• You can to object to, or obtain a restriction of, the processing of personal data under certain circumstances;and

• For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, contact us at the email address provided at the bottom of this policy. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.

You have a right to request that we disclose to you the personal information we have collected about you and to receive additional information about our collection, use,disclosure, or sale of such personal information. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make such requests, please contact us at the email address provided at the bottom of this policy.

Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. If you have an account, we will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

Right to Opt-Out. You have a right to opt-out from future“sales” of personal information.

Note that we do not “sell”personal information as defined by the CCPA and have not done so in the past 12 months.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.

7. The security of your personal data

We take reasonable and appropriate technical and organizational measures to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk.To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

8. How long we keep your personal data

We retain your information for as long as it is necessary to provide you with the service or fulfill the transactions you have requested or authorized. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data, including to comply with our legal obligations, enforce our agreements, resolve disputes, and as necessary for the establishment, exercise or defence of legal claims.

After you have deleted your account, we may retain certain information in an aggregated and anonymised format.

9. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at info@haply.co and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

10. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.

11. Contact

Questions, comments and requests regarding this policy should be addressed to info@haply.co.