Effective Date: September 24, 2021

PopReach Corporation, and its subsidiaries or affiliates (collectively, “PopReach”,“we”, “us” and “our”), takes your privacy seriously. This privacy policy (“Privacy Policy”) explains how we collect, use and share Personal Information (as defined below). This Privacy Policy applies to information you provide or we otherwise collect when you use our services, mobile game or other application (an “App”) or visit our websites (the “Sites”) (collectively, the “Services”). For the avoidance of doubt, this Privacy Policy does not apply to websites, applications or services owned by PopReach that display or link to different privacy statements.

By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not use the Services.

Some of our Services may target an audience including children under the age of 13. We do not knowingly collect personal information from children under the age of 13. For more information on how we treat children’s privacy, see section 7 below.

Table of Contents

1. Collection and use of Personal Information
   
2. Use of Personal information
   
3. Cookies and Web Beacons
   
4. How we disclose or share Personal Information with others
   
5. Managing your data
   
6. How we protect your Personal Information
   
7. Children’s privacy
   
8. International transfer
   
9. Changes to this Privacy Policy
   
10. Contact us
    
11. COLLECTION AND USE OF PERSONAL INFORMATION
    We collect information that alone or in combination with other information in our possession could be used to identify, locate and/or contact you (“Personal Information”). We collect most Personal Information directly from you through your use of our Services, or through email, chat, verbal, or other forms of written, oral, or electronic communication and correspondence with us.

    When you sign up for or use our Services, we may request information, including Personal Information, to create your PopReach account, including your first and last name, address, phone number, e-mail address, and password. We use such Personal Information to manage your account and to provide you with access to our Services. We may also use the information to notify you of updates to our Services and provide you with access to special promotions.
    PopReach collects information about how you use our Apps using data sent from the Apps to our servers. The types of data collected by PopReach may include: platform, SDK version, timestamp, API key (identifier for application), application version, device identifier, iOS Identifier for Advertising, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), model, manufacture and OS version of device, session start and stop time, locale (specific location where a given language is spoken), time zone, network status (WiFi, etc.), latitude and longitude (obfuscated to state/city), gender, age, events, errors, page views, IP address, device type, locale, and timezone of the user.

    PopReach may also collect information from you as part of research that can improve our Services. This can include data you submit when completing a survey or play test. We may also use your data in an aggregated and anonymized format for analysis used to improve our Services. Aggregated data in this format will not be used to identify you personally.

12. USE OF PERSONAL INFORMATION
    PopReach may use data or Personal Information collected from you for the following l purposes: (1) to fulfill your requests for the Services; (2) to improve the Services and related products or services; (3) to contact you to resolve problems and provide support; (4) to send you information about Services including confirmations, technical notices, updates, security alerts, and support and administrative messages; (5) to communicate with you about products and services offered by PopReach and our selected partners; (6) to conduct research (as described above); and (7) to make our Apps easier to use by reducing the need for you to enter information.
    
13. COOKIES AND WEB BEACONS
    In order to provide you with a personalized experience, PopReach may use “cookies” to keep and occasionally track information about your visits to our Site and use of the Services. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes.
    We use both session ID cookies and persistent cookies on the Sites. We use session cookies to make it easier for you to navigate our Sites. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Most web browsers are set to accept cookies by default. You can typically remove or reject cookies by following directions provided in your Internet browser’s help file. If you view Sites without changing your cookie settings, you are indicating your consent to receive all cookies from our Sites. If you do not allow cookies, some features and functionality of our Site or Services may not operate as expected.

    We may collect information using Web Beacons. Web Beacons, or “gifs”, are electronic images that may be used on our website, in our e-mails (“Web Beacons”), or in our Apps. We use Web Beacons to deliver cookies, count visits, and to tell if an email has been opened and acted upon. We may use Web Beacons that allow our third party ad network partners to serve targeted ads within our Apps, which may be based on your activities across the Internet and targeted to you for products and services in which we believe you might be interested. Most advertising networks offer you a way to opt out of targeted advertising. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.

14. HOW WE DISCLOSE OR SHARE PERSONAL INFORMATION WITH OTHERS
    Except as described in this Privacy Policy, unless required by law, PopReach does not rent, sell, or share Personal Information collected by us with other people or nonaffiliated companies unless we have your consent or under the following circumstances:
    a) Vendors, Business Partners and Service Providers. To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with third party vendors, consultants and other service providers who work for us and need access to your information to do that work. These parties will access, process or store Personal Information in the course of performing their duties to us in accordance with contractual obligations that are consistent with this Privacy Policy and applicable laws.
    b) Legal Requirements. If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, laws or to respond to lawful requests and legal process; (ii) to protect the rights and property of PopReach, our agents, customers, users, and others including to enforce our agreements, policies and terms of use; (iii) in an emergency, to protect the personal safety of PopReach, its customers, or any person; and (iv) prevent fraud and protect against legal liability.

    c) Business Transfers: In connection with or during negotiation of any merger, acquisition, sale of all or a portion of our assets, reorganization, bankruptcy, receivership, financing, or transition of service to another provider, your Personal Information and other information may be shared in the diligence process with counterparties and other assisting with the transaction along with other assets in accordance with applicable laws.

    d) Aggregated Information. We may also share aggregated or anonymized information in a form that does not directly identify you with any third parties to improve our Services and for other similar purposes. In addition, from time to time, we may analyze the general behaviour and characteristics of users of our Services and share aggregated information such as general user statistics with prospective business partners.We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. Aggregated information will not be used alone or in combination with other information to, directly or indirectly, identify any individuals.

    e) Affiliates: We may share Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with PopReach, in order to provide our Services. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

15. MANAGING YOUR DATA
    UPDATING YOUR INFORMATION AND CONTACT PREFERENCES
    You may update your information either directly through our Apps, if applicable, or by sending an e-mail to [email protected].

    DELETING YOUR DATA
    You can request for your data to be deleted either directly through our Apps, if applicable, or by sending an e-mail to [email protected].

    YOUR CHOICES
    In certain circumstances, providing Personal Information is optional or you may have opt-out choices as described in this Privacy Policy. However, if you choose not to provide Personal Information that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Information or to withdraw your consent for our future collection, use or disclosure of your Personal Information in accordance with applicable laws.

16. HOW WE PROTECT YOUR PERSONAL INFORMATION
    PopReach uses reasonable technical, physical, administrative and organizational measures to help protect your Personal Information against unauthorized access, use, misuse, loss and unauthorized alteration, disclosure, or destruction. However, we cannot guarantee that your Personal Information will be absolutely protected and no Internet or e-mail transmission is ever fully secure or error free. Your Personal Information may be affected by actions outside of our control and you should take special care in deciding what information you send to us via the Services or email. You acknowledge that you provide your Personal Information at your own risk.
    
17. CHILDREN’S PRIVACY
    We recognize the need to provide further privacy protections with respect to Personal Information that we may collect from children who may use our Services. Some of the features on our Sites and Apps are age-gated so that they are not available for use by children, and we do not knowingly collect Personal Information from children in connection with those features.
    If you are under the age of 13, you may only use the Services and provide Personal Information if you have the consent of, and are supervised by, a parent or guardian.
    If we believe a child using the Services is under 13 we will not process any Personal Information of that child without the consent of the parent or guardian. If the user is 13 or over we will only collect and process Personal Information taking into account the level of maturity of youth of different ages.

    We comply with the Children’s Privacy Protection Act of 1998 (“COPPA”), a United States federal law. We do not knowingly collect personal information from children under the age of 13.

    We do not publish apps or own services that target children as their primary audience. Some of our apps or services may be considered mixed audience services under COPPA, meaning that they may be directed at children under the age of 13, but children are not the primary audience. For these apps and services, we employ methods to ensure that we do not collect any personal information from users under the age of 13.

    If you believe that we have collected personal information from your child, please contact us at: [email protected]. Such personal information will be promptly deleted.

    Although we do not collect personal information from children under 13, parents and guardians may contact us to request to review, modify, delete, or stop further collection of their child’s personal information. This can be done by emailing us at: [email protected] or using other contact information provided in the Contact Us section of this Privacy Policy.

18. INTERNATIONAL TRANSFER AND RETENTION
    We may, in the process of providing Services to you, transfer information that we collect about you, including Personal Information, to affiliates and subsidiaries, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Canadian or U.S law, please note that you are transferring information and permitting the transfer of information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and/or Canada and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy. If you are using the Services from outside the United States, please be aware that your Personal Data may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. As a result, your Personal Data may be subject to the laws of the United States and may be accessible without notice to you by the courts, law enforcement and national security authorities of the United States.

    We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

19. LINKS TO OTHER WEBSITES
    The Services may contain links to other websites not operated or controlled by PopReach (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
    
20. CHANGES TO THIS PRIVACY POLICY
    We may change this Privacy Policy at any time. We will post all changes to this Privacy Policy on our website and will indicate at the top of the page the modified policy’s effective date. Please check back from time to time for such changes. By continuing to access and use the Services, you agree to the terms of the then-current Privacy Policy.

    If we change our privacy practices in a way that requires us to obtain verifiable parental consent under COPPA, we will solicit and obtain such consent.

21. CONTACT US
    If you have any questions about our Privacy Policy or any privacy-related concerns, please do not hesitate to contact our Privacy Officer at [email protected] or by writing to:
    Attention: Privacy Officer
    PopReach Corporation
    1 University Ave., Floor 3, Toronto, Ontario, Canada, M5J 2P1
    Phone number: +1-416-583-5918

     Subsidiaries and Affiliates
    The following are subsidiaries and/or affiliates of PopReach Corporation:
    ·      PopReach Incorporated
    ·      PopReach UK Ltd.
    ·      PopReach Technologies Private Limited