MAPGEARS PLATFORM PRIVACY POLICY

Mapgears Inc. wishes to offer to users of its platform a secure environment that is respectful of their private life and information.

Mapgears Inc, its subsidiaries, affiliates, partners and suppliers (collectively "Mapgears") provide a set of mobile applications, web applications and online services (the “Platform”). As the owner and operator of the Platform, Mapgears commits to the respect and protection of the Platform users’ confidentiality with a strict application of this Privacy Policy (the “Policy”). This Policy explains how Mapgears processes personal information gathered during your usage of the Platform. This Policy also explains how you may ask questions and make suggestions on our privacy protection practices, and request access to, and correction of, your personal information.

Mapgears advises you to read carefully and review this Policy periodically for any changes.

By using the Platform or the services offered on the Platform (the “Services”), you accept, with neither reserve nor restriction, the terms and conditions of this Policy as well as every other rule, modality, condition and policy shown on the Platform, particularly the Terms and Conditions of Use. If you do not accept these terms and conditions, please stop using the Platform and Services immediately.

We will not use or share your information with anyone except as described in this Policy.

Personal Information Collection

When operating the Platform, Mapgears gathers two types of information: non-personal information and personal information.

When using the Platform, you agree to provide Mapgears with anonymous information, such as your computer’s Internet Protocol (“IP”) address, the domain you used to access the Platform, your browser’s or operating system’s type and version as well as the website that you have just visited and that you will be visiting right after ours (collectively, “Non-Personal Information”). When operating the Platform, Mapgears could also collect general and global information, such as Platform users’ demographic statistics (i.e., average age or users’ geographic distribution), the number of visitors and average time spent on the Platform. Such information is also considered as Non-Personal Information.

In addition, Mapgears may use third party services that collect, monitor and analyze your Non-Personal Information in order to increase the Platform’s functionality. These third party service providers have their own privacy policies addressing how they use such information.

By using the Platform, you also agree to provide Mapgears with information that allows it to identify you, such as your name, your mailing address, your phone number or your email address when appropriate (collectively, “Personal Information”).

Mapgears may also use and store information about your location. You can enable or disable location services when you use the Platform at any time through your mobile device settings.

Collecting Personal Information is necessary to ensure the effective operation of the Services offered on the Platform. As you are using the Platform, collecting your Personal Information allows Mapgears to help with your browsing by showing you the most relevant information to you. Collecting your Personal Information also allows Mapgears to improve the Platform and to communicate with you if necessary.

More specifically, Mapgears only collects Personal Information that is necessary to fulfill the following purposes:

• To verify identity;

• To identify your preferences;

• To open and manage an account;

• To ensure that you receive a high standard of service;

• To analyse the use of the Platform and its users’ habits in order to communicate them to third parties;

• To meet regulatory requirements;

• Other legal reasons as applied to the goods and services requested.

Use of Personal Information

Mapgears will keep your Personal Information for the time required to fulfill the identified purpose or for a legal or business purpose after which Mapgears agrees to destroy or have the Personal Information linked to your account destroyed by all commercially reasonable means. Mapgears will use appropriate security measures when destroying your Personal Information such as shredding documents or deleting electronically stored information, at its discretion.

Mapgears will make reasonable efforts to ensure that your Personal Information is accurate and complete. You may request modifications to your Personal Information to ensure its accuracy and completeness. A request must be written and must provide enough details to identify your Personal Information and the modifications sought.

Mapgears is committed to the security of your Personal Information and may use passwords, encryption, firewalls, restricted employee access or other methods, at its discretion, to ensure its security.

You hereby specifically agree to allow Mapgears to use the information gathered on the Platform, whether Personal or Non-Personal Information, for commercial or non-commercial purposes, including in particular but not limited to the analysis for statistics or targeted publicity for the clientele, as well as selling or renting this information to third parties, or also to provide its clients with detailed and anonymous reports.

Personal Information Disclosure

Mapgears will not sell your Personal Information to other parties unless consent has been hereby explicitly provided or implied.

Mapgears will disclose your Personal Information if required to do so by law or by a court order made by a court or an authority with jurisdiction to compel the production of your Personal Information, to protect or defend a legal interest or to protect the security or integrity of our Platform.

If Mapgears is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. In such a case, Mapgears will make reasonable efforts to provide notice before your Personal Information is transferred and becomes subject to a different privacy policy.

Consent

You provide implied consent where our purpose for collecting, using or disclosing your Personal Information would be considered obvious or reasonable in the circumstances. Consent may also be implied where you have notice or a reasonable opportunity to opt-out of having your Personal Information used for mail-outs, marketing or fundraising and you do not opt-out.

At all times and subject to Mapgears’ obligations, you may rectify or withdraw your consent for your Personal Information use and disclosure by communicating with Mapgears. You acknowledge, however, that your access to the Platform and to the Services may then be refused, at Mapgears’ sole discretion.

Cookies

The Platform uses cookies (“Cookies”). Cookies are small files stored on your computer’s hard drive by Mapgears to collect Non-Personal Information enhancing the Platform’s efficiency.

When connecting to the Platform, Mapgears’ servers install some Cookies on your computer allowing the Platform to recognize your browser, your password, your geolocation data and your preference amongst others. Cookies allow Mapgears to improve the Platform’s performance as well as your usage.

Most browsers automatically accept Cookies, but you can refuse them or turn them off via your browser’s settings. However, if you do not accept or turn off Cookies, some of the Platform’s features might not be available anymore. It is also possible to delete Cookies after using the Platform.

Please note that Cookies do not collect or keep Personal Information for Mapgears.

Service Providers

Mapgears may employ third party companies and individuals to help provide the Platform, to provide the Platform on its behalf, to perform Platform-related services or to assist it in analyzing how the Platform is used.

These third parties will have access to your Personal Information only to perform these tasks on our behalf. Furthermore, they will first have to agree to respect strict contractual conditions that will force them (i) to maintain confidentiality; (ii) to keep and use this Personal Information only for purposes intended by the Platform and Services; and (iii) to destroy this Personal Information once it has been used for purposes intended by the Platform.

Personal Information Security

Mapgears takes every necessary and commercially reasonable technical, contractual and administrative measure to ensure the security of your Personal Information.

Your Personal Information is securely stored on servers associated with the Platform. If your Personal Information was stored with third parties, please note that the latter will have to respect strict contractual conditions forcing them to maintain Personal Information confidentiality and to use it only to perform their services.

To ensure a higher security level of your Personal Information, Mapgears advises you to never disclose your username and your password, since they provide access to your account and your Personal Information. Mapgears also recommends that you carefully sign out of your session after accessing your account and that you close your browser window after using the Platform.

International Transfer

Your Personal and Non-Personal Information may be transferred to and maintained on computers located outside of your province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Canada and choose to provide Personal and Non-Personal Information to us, please note that Mapgears transfers the information to Canada and processes it there.

Your consent to this Policy followed by your submission of your Personal and Non-Personal Information represents your agreement to that transfer.

Links To Other Sites

The Platform contains links to external websites (“External Sites”) that will make you exit the Platform. Mapgears provides you with these links for your convenience. Since External Sites are not operated by Mapgears, we strongly advise you to review the Privacy Policy of every site you visit.

Mapgears has no control over, and assumes no responsibility for the content, privacy policies or practices of any third party sites or services.

Modifications

Changes to this Policy are effective when they are posted on this page. If we make important changes to this Policy, we will notify you either through the email address you have provided, or by placing a prominent notice on our website.

Access to Personal Information

Mapgears agrees to take any reasonable commercial means to allow you, at all times, to request access to your account and your Personal Information in order for you to modify or delete them yourself.

To ensure effective services, it is essential for you to check that your Personal Information is accurate and complete at all times.

Upon your request, Mapgears agrees to make reasonable commercial efforts to confirm with you whether it holds your Personal Information or not, and to forward it to you when appropriate.

Contacting Us

For any questions, comments or suggestions on this Policy or on Mapgears’ privacy protection practices, please contact us by email at privacy@mapgears.com.

MAPGEARS PRIVACY POLICY v1.0 – Last Revision: 2018-12-10