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Updated: October 2023

Loopio Inc., together with its subsidiaries, affiliates, and related entities
(collectively “Loopio”, “we”, “us”, or “our”, as applicable) respects your
privacy and is committed to protecting the privacy and security of the Personal
Data (as defined below), that is entrusted with us.

Loopio provides a software as a service (SaaS) platform that assists companies
in curating, reviewing, maintaining and accessing a library of content for
responding to requests for proposals (RFPs), request for information (RFIs), due
diligence questionnaires (DDQs), and security questionnaires (SQs), collectively
the (“Services”). Loopio’s Services provide technology that empowers its Users
to deliver their own services, which requires at times processing confidential
information, including Personal Data.

SCOPE

This Privacy Policy (this “Policy“) is intended to describe how we collect, use,
store, and share Personal Data from prospects, customers, suppliers, business
partners, website visitors, candidates and other individuals (collectively
“User”, “you”, or “your”) to manage our relationship with you and fulfill our
obligations to you through the use of the Services (as defined below) and/or
your interactions with Loopio. This Policy also describes your rights regarding
the Personal Data that you provide us and how you can withdraw consent, and
access, correct, and request erasure of your Personal Data.

For purposes of this Policy, “Personal Data” is defined as any information
relating to an identified or identifiable natural person, as may be defined, or
limited under applicable privacy legislation.

Our use of your Personal Data is treated in accordance and in compliance with
applicable privacy laws, including the General Data Protection Regulation (EU)
2016/679, the UK Data Protection Act, the Information Technology Act, 2000 (read
with Information (Reasonable Security Practices and Procedures and Sensitive
Personal Data or Information) Rules, 2011), and the California Consumer Privacy
Act of 2018 (“CCPA”).

By using or accessing our Services, our websites (including downloading
content), registering for an event we are hosting, applying for a job with us or
otherwise generally interacting/communicating with us, you acknowledge that we
will collect, use and share your Personal Data as described in this Policy. If
you do not agree to any of the provisions set out in this Policy, then you
should not provide your Personal Data to us.

WHAT WE COLLECT

In order to provide you with the Services and to carry out our other contractual
obligations to you, we may be required to collect, store, transfer and use the
following categories of Personal Data:

* General Contact Information: First name, last name, username (or similar
identifier), business billing addresses, business telephone number, business
title and business email addresses.
* Technical Information: Including cookies, full/partial Internet protocol (IP)
address used to connect your computer to the Internet, your login
information, browser type and version, time zone setting, browser plug-in
types and versions, or operating system and platform.
* Non-Personal Usage Information: Information related to your website
interactions, including the full URL, clickstream information to, through,
and from our website (including date and time), products 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), or
methods used to browse away from the page.
* Recruitment Information: Information contained in your resume/CV, cover
letter, or similar employment-related materials, including employment
history, work experience and education background and any social media
handles or information available about you on social media if you connect
with us through any professional platforms.
* Financial Information: Bank account or credit card or debit card or other
payment instrument details provided to use for payment in respect of our
Services.
* Other Information: Passwords created for using our Services, and other
information related to password recovery

OUR ROLE

In Loopio’s provision of the Services to you, you are the “Data Controller” (who
controls the Personal Data when using the Services) and Loopio is the “Data
Processor” (who processes Personal Data (either on your behalf or someone
else’s) on your behalf to provide you with the Services). To the extent that you
upload Personal Data you are responsible for ensuring that your use of the
Services and provision of such Personal Data is in compliance with all
applicable privacy laws and that you have provided all necessary notice,
obtained all necessary consents, and otherwise have all authority to provide
such Personal Data to Loopio for provision of our Services to you. You agree to
not provide us with any sensitive Personal Data (as defined by applicable
privacy laws).

To the extent the CCPA applies to you, you shall be deemed the “business” and
Loopio will be deemed the “service provider”.

If you are applying for a job or otherwise interacting with Loopio beyond the
use of the Services (i.e., accessing our website), you will be deemed the “Data
Controller” and Loopio will be deemed the “Data Processor”.

HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect your Personal Data, such as directly from
you when you access our website, subscribe to our Services, apply for a job with
us or otherwise interact with us.

We may also collect Personal Data from you indirectly when you interact with our
website by using cookies, server logs and other similar technologies. This may
include Technical Information about your equipment, browsing actions and
patterns from (i) third-party analytics providers (such as Google based outside
the EU) and (ii) search information providers (such as Google based outside the
EU). We may also collect Contact Information from publicly available sources.

HOW WE USE PERSONAL DATA

We use your Personal Data to provide you with our Services, communicate with
you, deliver advertising and marketing, consider you for employment with us, or
to conduct other business operations, such as using data to improve and
personalize your experiences.

Examples of how we may use the Personal Data we collect include:

* Present our website and provide you with the information, products, services,
and support that you request from us.
* Meet our obligations and enforce our rights arising from any contracts with
you, including for billing or collections, or comply with legal requirements.
* Fulfill the purposes for which you provided the data or that were described
when it was collected.
* Notify you about changes to our website or services.
* Ensure that we present our website content in the most effective manner to
you and to your computer.
* Administer our website and conduct internal operations, including for
troubleshooting, data analysis, testing, research, statistical, and survey
purposes.
* Improve our website, products or services, marketing, or customer
relationships and experiences.
* Enable your participation in our website’s interactive, social media, or
other similar features.
* Measure or understand the effectiveness of the advertising we serve to you
and others, and to deliver relevant advertising to you.
* Make suggestions and recommendations to you and other users of our website
about goods or services that may interest you or them.
* For job candidates, consider and respond to your application and assess your
suitability for current and future career opportunities.
* For legal, safety, and security purposes. We may also use personal
information to comply with law or for safety and security reasons, as
follows:
* We may use and share personal information as we believe necessary or
appropriate to comply with laws that apply to Loopio and to support our
bank partners’ compliance with applicable law, including anti-money
laundering (AML) and sanctions screening rules.
* We may use and share personal information to respond to lawful requests and
legal process, such as to respond to subpoenas or requests from government
authorities.
* We may use personal information and disclose it to law enforcement,
government authorities, and private parties as we believe necessary or
appropriate to: (i) protect our or others’ rights, privacy, safety or
property (including by making and defending legal claims); (ii) audit our
internal processes for compliance with legal and contractual requirements;
(iii) enforce the terms and conditions that govern the Services; and (iv)
prevent, identify, investigate and deter fraudulent, harmful, unauthorized,
unethical or illegal activity, including cyberattacks and identity theft.

* For other disclosed purposes and with consent. We may also use personal
information for other purposes that are disclosed at the time you provide
personal information, or purposes where we obtain your consent.

SHARING OF PERSONAL DATA

We will only share your Personal Data with third parties where required by law
or to our employees, contractors, designated agents, or third-party service
providers who require it to assist us with administering our relationship with
you, including providing services to us or on our behalf. Third-party service
providers include, but are not limited to, those who may host our website, store
data, provide back-up services, provide customer support, process customer
payments, provide data analytic services, conduct surveys or obtain your
feedback. We will not publish any Personal Data without specific consent and any
third party to whom the Personal Data is shared, should not be permitted to
disclose it further without our consent.

We require all of our third-party service providers, by written contract, to
implement appropriate security measures to protect your Personal Data consistent
with our policies and any data security obligations applicable to us as your
service provider. We do not permit our third-party service providers to use your
Personal Data for their own purposes; we only permit them to use your Personal
Data for specified purposes in accordance with our explicit instructions.
Details about our trusted third-party service providers is available upon
written request.

We may also disclose your Personal Data to third parties for the following
purposes:

* To other members of the Loopio group of companies for: (a) the purposes set
out in this Policy, (b) as necessary to perform our rights or obligations
with this Policy and (c) as part of our regular reporting activities to other
members of the Loopio group of companies.
* To comply with legal obligations or valid legal processes such as search
warrants, subpoenas, or court orders. When we disclose your Personal Data to
comply with a legal obligation or legal process, we will take reasonable
steps to ensure that we only disclose the minimum Personal Data necessary for
the specific purpose and circumstances.
* During emergency situations or where necessary to protect the safety of
persons.
* Where the Personal Data is publicly available.
* If a business transfer or change in ownership occurs, and
* For additional purposes with your consent where such consent is required by
law.

CHILDREN’S PERSONAL DATA

Loopio’s Services, including our website, and web and mobile apps, are not
directed to children. We do not knowingly collect personal information through
the Services from children younger than the legally qualifiable age under
applicable data privacy laws in different jurisdictions. If a parent or guardian
becomes aware that his or her child younger than such indicated age prevalent in
the appropriate jurisdiction has provided us with personally identifiable
information without his or her consent, he or she should contact us at
privacy@loopio.com. If we become aware that we have unknowingly collected
personally identifiable information from a child younger than indicated age
prevalent in the appropriate jurisdiction, we will make reasonable efforts to
delete such information from our records.

MARKETING PREFERENCES

Where the processing of your Personal Data by us is based on consent, you have
the right to withdraw that consent without detriment at any time by contacting
us. You can also change your marketing preferences at any time by emailing us at
privacy@loopio.com.

* Visiting our Website: We collect the IP (Internet protocol) addresses of all
visitors to our website and other related information such as page requests,
browser type, operating system and average time spent on our website. We use
this information to help us understand our website activity, and to monitor
and improve our website.
* Cookies: Our website uses technology called “cookies” (and/or other similar
technologies such as device-IDs, in-App codes, pixel tags and web beacons). A
cookie is a tiny element of data that our Website sends to a user’s browser,
which may then be stored on the user’s hard drive so that we can recognize
the user’s computer or device when they return. Cookies may provide us and
our service providers with information that we will use to personalize our
website in accordance with a user’s preferences. You may set your browser to
notify you when you receive a cookie or to not accept certain cookies.
However, if you decide not to accept cookies from our website, you may not be
able to take advantage of all of the website features. We may also use a
third party to help us gather and analyze information about the areas that
users visit on the website to evaluate and improve the customer experience
and the convenience of the website.
* Analytics: We may use a third party such as Google Analytics to help us
gather and analyze information about the areas visited on the website (such
as the pages most read, time spent, search terms and other engagement data)
in order to evaluate and improve the user experience and the website. These
third parties may use cookies and other tracking technologies. For more
information about Google Analytics or to prevent the storage and processing
of this data (including your IP address) by Google, you can download and
install the browser plug-in available at the following link:
https://tools.google.com/dlpage/gaoptout?hl=en

You can also obtain additional information on Google Analytics’ data privacy and
security at the following links:

* https://policies.google.com/technologies/partner-sites
* https://support.google.com/analytics/topic/2919631

INTEREST-BASED ADVERTISING

We may use third parties such as ad networks and other advertising companies to
serve advertisements on other websites (including social media sites). These
companies may use cookies, tracer tags or web beacons to report certain
information about your activity on our website and other websites and apps (such
as web pages you visit and your interaction with our ads and other
communications) in order to make predictions about your preferences and deliver
ads that are more relevant to you, both on and off our website (including on
social media sites). This information may also be used to evaluate the
effectiveness of our online advertising campaigns or to tailor marketing
messages to you.

Please note that if you opt-out, you may still receive online advertising from
us, but it will not be tailored to your interests based on online behavioural
information about you. To successfully opt-out, you must have cookies enabled in
your web browser (see your browser’s instructions for information on cookies and
how to enable them). Your opt-out only applies to the web browser you use so you
must opt-out of each web browser on each device you use. Once you opt-out, if
you delete your browser’s saved cookies, you will need to opt-out again.

Our website may contain links to other websites that Loopio does not own or
operate. We provide links to third party websites as a convenience to the User.
These links are not intended as an endorsement of or referral to the linked
websites. The linked websites have separate and independent privacy policies,
notices and terms of use. We do not have any control over such websites, and
therefore we have no responsibility or liability for the manner in which the
organizations that operate such linked websites may collect, use or disclose,
secure and otherwise treat personal information. We encourage you to read the
privacy policy of every website you visit.

When you engage with Loopio’s content on or through third-party social
networking websites, plug-ins and applications, we may have access to certain
information associated with your social media account (e.g., name, username,
email address, profile picture, gender). We may use this information to
personalize your experience on the website and on the third-party social
networking websites, plug-ins and applications, and to provide you with other
information you may request.

DATA SECURITY

We have implemented appropriate and reasonable physical, technical, and
organization security measures designed to secure your Personal Data against
accidental loss and unauthorized access, use, alteration, or disclosure. In
addition, we limit Personal Data access to only those employees, agents,
contractors, and other third parties that have a legitimate business need for
such access.

CROSS-BORDER DATA TRANSFERS

Where applicable law permits, we may be required to transfer your Personal Data
to the United States and other jurisdictions, as necessary to perform the
Services and for the purposes set out in this Policy. We shall make reasonable
efforts to ensure that the same level of data protection as provided by us, is
adhered to by the organization to whom such Personal Data is transferred.
However, the measures that we use to protect Personal Data are subject to the
legal requirements of the jurisdictions to which we transfer Personal Data,
including lawful requirements to disclose information to law enforcement and
government agencies in those countries. We will take all steps reasonably
necessary to ensure that your data is subject to appropriate safeguards, such as
relying on a recognized legal adequacy mechanism, and that it is treated
securely and in accordance with this Policy and applicable law.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we
will only retain your Personal Data 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 Data (“Anonymized Data”)
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. This Anonymized Data does not
directly identify and could not reasonably be used to identify any specific
individual and we use this Anonymized Data to understand, develop, improve, and
market our Services, and it may be used or shared with third parties for any
lawful purpose.

RIGHT OF ACCESS, CORRECTION, ERASURE, AND OBJECTION

It is important that the Personal Data we hold about you is accurate, current,
and complete. Please keep us informed of any changes to your Personal Data. By
law you have the right to request access to and request us to correct the
Personal Data that we hold about you or withdraw your consent to the use of your
Personal Data under certain circumstances. If you are no longer an active
customer or are no longer interacting with Loopio, we may need to request
specific information from you to help us respond to your request.

Applicable law may allow or require us to refuse to provide you with access to
some or all of the Personal Data that we hold about you, or we may have
destroyed, erased, or made your Personal Data anonymous in accordance with our
record retention obligations and practices. If we cannot provide you with access
to your Personal Data, we will inform you of the reasons why, subject to any
legal or regulatory restrictions.

If you would like to exercise any of these rights, please contact us at
privacy@loopio.com.

RIGHT TO WITHDRAW CONSENT

Where you have provided your consent to the collection, use, and transfer of
your Personal Data, you may have the legal right to withdraw your consent. To
withdraw your consent, if applicable, please contact us at privacy@loopio.com.

DATA PRIVACY OFFICER

We have appointed Neetu Toor, Loopio’s General Counsel as our Data Privacy
Officer (“DPO”) to oversee compliance with this Policy and to address any
questions you may have. If you have any questions about this Policy or how we
handle your Personal Data or would like to request access to your Personal Data
please contact us at privacy@loopio.com.

If your request or concern is not satisfactorily resolved by us, you may
approach your local data protection authority, (for example, see
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html),
who can provide further information about your rights and our obligations in
relation to your Personal Data, as well as deal with any complaints that you
have about our processing of your Personal Data.

CHANGES TO THIS POLICY

We reserve the right to update this Policy at any time to reflect changes to our
personal information practices. If we make material changes to the Policy, we
will provide notification by updating the “Last Updated” date at the top of the
Policy and posting the new Policy to our website or other Services. We may also
notify you about updates through email (sent to the email address specified in
your account) or use other reasonable means to alert you to changes. We strongly
encourage you to refer to this Policy often for the latest information about our
privacy practices.

If you have any questions or comments about this Policy or the way in which we
handle your Personal Data, please contact us at:

Loopio Inc.

310 Spadina Ave. Suite 600

Toronto, Ontario M5T 2E8 Canada

Attention: Legal Department

Telephone: 1-844-456-6746

Email: privacy@loopio.com

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