PLEASE CAREFULLY READ THIS PRIVACY POLICY BEFORE USING THIS WEBSITE

Last Updated: July 27, 2021

NowVertical Group Inc. and our subsidiary entity, NowVertical Group, Inc., (collectively, “NowVertical”, “we”, “us” and “our”) are committed to protecting your Personal Information (as defined below). This Privacy Policy (the “Policy”) governs the collection, use and disclosure of your Personal Information in any communication or interaction you may have with us, whether it be in-person, over the telephone, in writing or electronic.

NowVertical complies with the requirements of Canada’s privacy legislation, the Personal Information Protection and Electronic Documents Act and substantially similar provincial legislation, as applicable.

By submitting your Personal Information, and using NowVertical’s services or website (the “Site”), you accept this Policy and consent to its terms and conditions and any other terms and conditions described to you at the time of collection of your Personal Information. If you do not agree to such terms and conditions, please do not use the Site.

YOU ACKNOWLEDGE THAT YOU HAVE READ THIS POLICY, UNDERSTAND IT AND AGREE TO ALL OF ITS TERMS AND CONDITIONS. BY CONTINUING TO USE THIS SITE, YOU WILL BE LEGALLY GRANTING YOUR CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. IF YOU DO NOT CONSENT, PLEASE DO NOT USE THIS SITE OR OTHERWISE PROVIDE YOUR PERSONAL INFORMATION TO US.

POLICY AMENDMENTS

This Policy may be revised or updated at our discretion at any time. We may provide notice to you of such updates by posting them on the Site and the date of last modification will appear at the top of the Policy. Please check back from time to time for such amendments. By continuing to access and use the Site, you agree to the terms of the then-current Policy.

WHAT IS PERSONAL INFORMATION?

“Personal Information” is information about an identifiable individual, including but not limited to, your name, residential address and e-mail address, and your views and personal opinions. Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not typically considered Personal Information.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We only collect Personal Information from you that is necessary to establish, manage and maintain our relationship with you, including your name, email address, phone number(s), company, title, business and/or residential address and your comments and questions.

NowVertical collects Personal Information that you voluntarily provide to us, such as when you subscribe for investor alerts, request event reminders, or contact us with questions or comments. We may also receive Personal Information from our business partners and other third parties, if such parties confirm to us that they have obtained your consent or we have obtained your consent in this regard.

WHAT OTHER INFORMATION WILL WE COLLECT?

We collect certain technical information that is recorded by the standard operation of our Site on an anonymous basis. This includes your IP address, the operating system and type of browser you are using, the sections of the Site you visit, any content you download from the Site, the URL that directed you to the Site, and the date and time of your visit (collectively, “Technical Information”). This Technical Information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes; (ii) to improve the Site; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.

Cookies: When you view the Site, we generally collect and store some information on your computer. This information will be stored in a “Cookie,” which is a file created on your computer’s hard drive, and will help us in many ways. For example, Cookies allow us to tailor the Site to match your interests and preferences. With most Internet browsers, you can erase Cookies from your computer hard drive, block the creation of Cookies, or receive a warning before a Cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.

Other Technologies: Our Site may use Web beacons, gifs, Google Analytics or other technologies. When you access certain parts of our web pages, a non-identifiable notice of that visit is generated which may be processed by us. These technologies usually work in conjunction with cookies. If you do not want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacon technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.

HOW WILL WE USE THE INFORMATION WE COLLECT?

NowVertical collects and uses your Personal Information for the following purposes:

• to respond to your communications and requests
• to meet legal, regulatory, audit, security and financial requirements under federal and provincial regulations
• to maintain business records for reasonable periods of time
• to conduct market research and gather demographic and statistical information about our users in order to manage and improve our business
• to provide you with our press releases, alerts and updates, in accordance with applicable law. You can unsubscribe from such communications at any time by clicking on the unsubscribe link included in each communication.

Your Personal Information will not be used for any other purpose without your consent, unless required or permitted by applicable law.

HOW WILL WE SHARE OR DISCLOSE THE INFORMATION WE COLLECT?

NowVertical does not sell or otherwise share or disclose Personal Information about you that we collect or receive, except as described below or permitted by law.

Authorized third party service providers may be required to process your Personal Information in order for us to provide you with the Site and our services. Personal information will only be processed by service providers who have entered into a contract with us that restricts their use of such information and requires them to implement and maintain appropriate security safeguards, in order to protect such information from unauthorized or unlawful access, use or disclosure.

Your Personal Information may be disclosed in accordance with applicable law if we are involved in a prospective or completed business transaction, such as the sale or transfer of some or all of our business or assets.

We may disclose Personal Information as required by law to respond to a court order or subpoena, to comply with applicable laws and regulations as we determine in our discretion, or to enforce our rights and protect our property and interests or those of others.

PROCESSING AND STORAGE OF PERSONAL INFORMATION

Your Personal Information may be processed and stored outside of the province/territory in which you reside and/or outside of Canada. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction. If you have any questions about our use of non-Canadian service providers, please contact us as set out under the “Contact Us” heading below.

SECURITY AND RETENTION OF PERSONAL INFORMATION

We utilize physical, technical, contractual and administrative safeguards to protect your Personal Information against loss or theft and unauthorized or unlawful access, disclosure, copying, use or modification. However, no Internet-based system is impenetrable and emails sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind whenever disclosing any Personal Information to us via the Internet.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information.

LINKS TO THE OTHER SITES

The Site may contain links to third party platforms to which the Policy does not apply. Should you select such a link, you will leave the NowVertical Site. Please note that we do not monitor or control the content that appears on these third-party sites and such content may be constantly changing. If you view these third-party sites, the sites may assign a cookie. NowVertical does not control these cookies, nor is it responsible for any marketing or other use of your information by these third parties. All Personal Information you provide via those third-party sites will be governed by the privacy policies applicable to those sites and not this Policy. We encourage you to review all such privacy policies before you provide any Personal Information to third-party sites.

YOUR RIGHTS AND PREFERENCES

By providing us with your Personal Information, you consent to our collection, use and disclosure of your Personal Information for the purposes described in this Policy. Other than as required by law, your Personal Information will not be collected, used or disclosed for any other purpose without your consent. You can withdraw your consent to some or all of these purposes by contacting us as set out under the “Contact Us” heading below.

NowVertical wants to ensure that your Personal Information is accurate, complete and current. Please inform us of any changes to your Personal Information. In addition, you have the right to access and correct your Personal Information, subject to certain legal restrictions, including if the information contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege. If there are errors in the Personal Information we have on record, you may request that it be changed. If we have disclosed inaccurate Personal Information about you to a third party, we will be pleased to contact the third party in order to advise them of the error. In order to access this information, you must submit a written request using the contact information set out below.

CONTACT US

If you have any questions, concerns or would like more information about the collection, use or disclosure of your Personal Information by NowVertical, you may contact us as follows: EVP, Corporate Development & Legal Affairs, privacy@nowvertical.com.