Privacy Policy

INTRODUCTION

1.1 GCA and our affiliates and subsidiaries ("Company" or "We" or “Us” or “Our”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

1.1.1 How we collect, use, disclose, and protect the personal information of our Customers and website users ("You", “Your”, “Yours”). 1.1.2 Describes the types of information we may collect from you or that you may provide when you visit the website https://www.gcafopfo.simprime-ca.com (our "Website"). 1.1.3 Our practices for collecting, using, maintaining, protecting, and disclosing that information. 1.2 We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes. 1.3 Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information. 1.4 This policy applies to information we collect, use, or disclose about you: 1.4.1 On this Website. 1.4.2 In email, text, and other electronic messages between you and this Website. 1.4.3 Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website. 1.4.4 When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy. 1.4.5 When you interact with us and our staff directly, for example by contacting customer service or customer care, as the terms are used interchangeably. 1.5 The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit. 1.6 This policy DOES NOT apply to information that: 1.6.1 We collect offline or through any other means, including on any other Company or third-party website, including those of our affiliates and subsidiaries. 1.6.2 You provide to or is collected by any third party including our affiliates and subsidiaries, through any application or content (including advertising) that may link to or be accessible from or on that other company or third-party Website. 1.6.3 You create in your offline activities and communications. 1.7 Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. We will notify you and other users of our website of all changes, and we will also notify you and other users of our website in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information. Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU

2.1 When you interact with the Application or Service through any or all of FopFo™, Familigi™, BoxAlong™, Currencida™, and SEBAA™, we collect and use several types of information from and about you, including: 2.1.1 Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, login location and device or platform used, and any other identifier we may use to contact you ("personal information"). 2.2 We provide an opportunity for any user to unsubscribe from our products and services or information collection, or updates and announcements related to our products and services, or to opt-out of contact for marketing purposes on an ongoing basis by accessing our Website and using the unsubscribe tool, by using the unsubscribe mechanism on our Newsletter page or at the bottom of our newsletter e-mails, or by sending an e-mail to gcasupport@simprime-ca.com

Employment-related information voluntarily provided, namely information that related to your work duties, including:

(a) title;

(b) city and nation of primary work;

(c) work email address, and an alternate email; and

(d) work telephone number, and an alternate telephone number.

2.2.2 Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature. 2.2.3 Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, any email address used to access our website, and usage details. 2.2.4 Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as visit date and time and duration, scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number. 2.2.5 Public Commentary and website postings, including assessments and reviews of our products and services.

HOW WE COLLECT INFORMATION ABOUT YOU

3.1 We use different methods to collect your information, including through: 3.1.1 Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 3.1.2 User contributions. You may also contribute or provide information such as reviews and testimonials and commentary and the like (“User Submissions”) for us to publish or display on public Website areas or transmit to other Website users or third parties. None of the User Submissions you submit to the Website will be subject to any confidentiality by the Company. By providing any User Submission to the Website, You grant Us and Our affiliates and service providers, and each of their and Our respective licensees, successors, and assigns the right to a world-wide, royalty free, perpetual, irrevocable, non-exclusive licence to use, reproduce, modify, perform, display, distribute, and otherwise disclose to third parties any such material for any purpose and according to Your account settings and/or incorporate such material into any form, medium or technology throughout the world without compensation to you. You further waive any moral rights or other rights of authorship as a condition of submitting any User Submission. 3.1.3 By providing the User Submissions and making them available, You declare and warrant that You own or have the necessary rights to submit the User Submissions and have the right to grant the licence hereof to Us and Our affiliates and service providers, and each of their and Our respective licensees, successors, and assigns to the User Submissions. You represent and warrant that all User Submissions comply with applicable laws and regulations and all applicable Terms and Conditions. 3.1.4 Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, as further explained in our Cookies Policy, which is included and contained and incorporated herein by reference and available at https://www.gcafopfo.simprime-ca.com/cookies 3.1.5 Third parties or publicly available sources, for example, our business partners and affiliates may also collect your information, including your payment information through Stripe, and you are encouraged to review their Privacy Policy.

INFORMATION YOU PROVIDE TO US

4.1 The information we collect directly from you on or through our Website may include: 4.1.1 Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website. 4.1.2 Records and copies of your correspondence including email addresses, if you contact us. 4.1.3 Your responses to surveys that we might ask you to complete for research purposes. 4.1.4 Details of transactions you carry out through our Website and of the fulfillment of your orders. We use a third-party service provider (Stripe) to process our payments. You will be required to provide financial information before placing an order through our Website. Your submission of that financial information shall be subject to the Stripe privacy policy and other applicable Stripe policies as available on or through their website: https://www.stripe.com 4.1.5 Your search queries on the Website.

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

5.1 As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: 5.1.1 Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. 5.1.2 Information about your computer and internet connection, including your IP address, operating system, and browser type. 5.2 For a fuller explanation of how we use Cookies, please see our Cookies Policy available at https://www.gcafopfo.simprime-ca.com/cookies which is included and contained and incorporated here by reference. 5.3 The information we collect automatically is statistical data that includes personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: 5.3.1 Estimate our audience size and usage patterns. 5.3.2 Store information about your preferences, allowing us to customize our Website according to your individual interests. 5.3.3 Speed up your searches. 5.3.4 Recognize you when you return to our Website.

HOW WE USE YOUR INFORMATION

6.1 We use information that we collect about you or that you provide to us, including any personal information: 6.1.1 To present our Website and its contents to you. 6.1.2 To provide you with information, products, or services that you request from us. 6.1.3 To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it. 6.1.4 To provide you with notices about your account or subscription, including the communication of expiration and renewal notices. 6.1.5 To communicate information back and forth in attempted dispute resolution, including providing notices under the SaaS Agreement which is separately transmitted to all registered users and includes, contains, and incorporates all of our policies. 6.1.6 To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements. 6.1.7 To notify you about changes to our Website or any products or services we offer or provide though it. 6.1.8 To improve our Website, products or services, marketing, or customer relationships and experiences. 6.1.9 To allow you to participate in interactive features, social media, or similar features on our Website. 6.1.10 In any other way we may describe when you provide the information. 6.1.11 For any other purpose with your consent. 6.2 We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please opt out of receiving advertising and promotional content on your dashboard when you next log-in.

DISCLOSURE OF YOUR INFORMATION

7.1 We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 7.2 We may disclose personal information that we collect or you provide as described in this privacy policy: 7.2.1 To our subsidiaries and affiliates. 7.2.2 In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of GCA's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by GCA about our customers and users is among the assets transferred. 7.2.3 To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. 7.2.4 To fulfill the purpose for which you provide it. 7.2.5 For any other purpose disclosed by us when you provide the information. 7.2.6 With your consent. 7.3 We may also disclose your personal information: 7.3.1 To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law. 7.3.2 To enforce or apply our general terms of use https://www.gcafopfo.simprime-ca.com/terms/, or terms of the Software As A Service (SaaS) Agreement entered into by Customers, and other agreements, including for billing and collection purposes. 7.3.3 If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of GCA, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

8.1 We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy. 8.2 We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation. 8.3 You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada by using the contact form on our website, and selecting “PRIVACY QUERY” as your Subject. You may also send a free-form email with the subject “Privacy Query”, to gcasupport@simrime-ca.com 8.4 By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

9.1 We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 9.1.1 Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website: Flash Cookies (https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html) If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. 9.1.2 Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into the Website and opting-out in your account profile dashboard by checking or unchecking the relevant boxes or by sending us an email stating your request to gcasupport@simprime-ca.com 9.1.3 Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your [email /phone /contact information] used by the Company to promote our own or third parties' products or services, you can opt-out by logging into the Website and opting-out in your account profile dashboard by checking or unchecking the relevant boxes or by sending us an email stating your request to gcasupport@simprime-ca.com If we have sent you a promotional email or our Newsletter, you may unsubscribe by clicking the unsubscribe link we have included in the email or our Newsletter. 9.1.4 Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by logging into the Website and opting-out in your account profile dashboard by checking or unchecking the relevant boxes or by sending us an email stating your request to gcasupport@simprime-ca.com 9.2 We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance (https://youradchoices.ca/en/tools) or Network Advertising Initiative (https://thenai.org/how-to-opt-out/) . You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

10.1 The security of your personal information is very important to us. We use combinations of physical, electronic, and administrative measures including but not limited to hashing and encryption, password protection, role-base access, and other assorted technical and physical tools to protect your data in storage, in use, in transmission, and at rest. Individually and together, all of these measures are designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on secure servers. Any payment transactions and related information will be collected and processed by our third-party payments processing service provider (Stripe), it will be encrypted, and it will use SSL technology. 10.2 The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in real and virtual public areas. 10.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RESIDENCE

11.1 Where your data is held depends on the platform, and our goal is to hold as little of your content as possible. 11.1.1 In the current web (browser) edition, a browser cannot securely store a full working dataset on your machine, so the data you enter is kept on a secure synchronisation server linked to your activation code — this is what lets the applications function, keeps your desktop devices in conformance, and protects you against a cleared browser. 11.1.2 In the forthcoming native desktop and mobile editions, your data moves to full on-device residency: it stays on your own devices and synchronises directly between them (over your local network or Bluetooth), so nothing you enter needs to leave your machines. In the native desktop and mobile editions, the Provider's servers retain only your licence entitlement (which applications are unlocked, tied to your email, mobile and activation code), and periodic compliance heartbeats.

DATA RETENTION

11.2 Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information 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 information 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.

CHILDREN UNDER THE AGE OF 13

12.1 Our Website is not intended for children under 13 years of age. No one under age 13 may submit any information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us through the contact form on our website https://www.gcafopfo.simprime-ca.com , and select as your subject “Children Under 13”. You may also call us Toll Free at Customer Service/Customer Care: 1 (428) 4 FOPFO 4 (1-428-436-7364).

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

13.1 It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. 13.2 You can review and change your personal information by logging into the Website and visiting your account profile page, or you may also call us Toll Free at Customer Service/Customer Care: 1 (428) 4 FOPFO 4 (1-428-436-7364). 13.3 If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at gcasupport@simprime-ca.com to request access to, correct, or delete any personal information that you have provided to us. PLEASE NOTE, We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance. 13.4 We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include: 13.4.1 Information protected by solicitor-client privilege. 13.4.2 Information that is part of a formal dispute resolution process. 13.4.3 Information that is about another individual that would reveal their personal information or confidential commercial information. 13.4.4 Information that we have destroyed, erased, or if we have made your personal information anonymous in accordance with our record retention obligations and practices 13.4.5 Information that is prohibitively expensive to provide. 13.5 If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions 13.6 If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer by using the Contact Form on our website, selecting “Privacy Query” as the subject. You may also send a free-form email with the same subject line to gcasupport@simprime-ca.com

WITHDRAWING YOUR CONSENT

14.1 Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us through the contact form at https://www.gcafopfo.simprime-ca.com, choosing “Privacy Query” as your subject. You may also send us a free-form email with the same subject line, to gcasupport@simprime-ca.com 14.2 PLEASE NOTE, that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. 14.3 PLEASE NOTE, that if you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have already been copied or stored by other Website users.

CHANGES TO OUR PRIVACY POLICY

15.1 It is our policy to post any changes we make to our privacy policy on this page along with a notice that the privacy policy has been updated on the Website home page, and a mention in the next edition of our Newsletter. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary or the secondary email address specified in your account, through a notice on the Website home page, and with a mention in the next edition of our Newsletter. You will also see a prompt when you next log-in after a material policy change or changes, asking you to review and accept the change or changes. If you disagree with the change or changes and do not accept it or them, you should immediately stop using the website and the Services. 15.2 We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email addresses for you, and for periodically visiting our Website and this privacy policy to check for any changes.