TECHNOBRIGHT INC

Last Updated: [16-Sep-2023]

This Privacy Policy describes the privacy practices of TechnoBright Inc. (“us”, “we”, “our”, etc.) with regards to users (“you”, “your”, etc.) of the GyftEasy platform which includes our mobile app and our website at [www.gyfteasy.com] (the “Platform”). We take the privacy of our users very seriously and are committed to keeping the trust that our users place in us when they utilize our Platform. This Privacy Policy (the “Policy”) describes how we collect, use, and disclose your data in connection with your use of our Platform. This Privacy Policy does not apply with respect to third-party platforms and links that are made available and accessed by you in your use of the Platform, including the platforms of merchants whose gift cards you redeem through the Platform. It is your responsibility to consult with the specific privacy policies of all third-party services, links, websites, and platforms that you access through the Platform.

This Policy is incorporated by reference into our Terms of Service and forms part of it. The Policy, along with our Terms of Service are subject to change without advance notice, and you are responsible for periodically checking the Policy and our Terms of Service periodically. Your continued use of the Platform evidences your continued consent to the terms herein.

Where used in this agreement, “data” means any information that relates to an identified or identifiable individual (“Personal Information”), or data collected automatically, in connection with your use of the Platform for its intended purposes.

By using our Platform, you consent to the use of your data, including Personal Information, as described herein. Except as set forth in this Policy, your data will not be used for any other purpose without your consent. 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 to not use our services.

We do not knowingly collect information from anyone under the age of thirteen (13) years old and our services must not be used by anyone under thirteen years old and nobody under thirteen years old may provide any information to our Platform. Furthermore, users in between the ages of thirteen to eighteen (18) years old must only access and utilize our Platform under the guardian and supervision of an parent/ adult guardian, and by accessing or using this Platform, all users are evidencing that they are either eighteen years old or older or are at least thirteen years old and have the consent of their parent/ adult guardians to access and use the Platform.

If you believe we might have unknowingly collected information from or about a child under 13, please send us an email at [admin@gyfteasy.com] so we may rectify the situation.

Data That We Collect From You

When you use our services, we collect different types of data about you, including Personal Information.

Identifiers (“Personal Information”): Information that identifies you directly such as your name, billing and/or mailing address, birth date, gender, telephone number, credit card information, other billing information, country and location of residence, internet protocol (IP) address used to connect your device to the internet to access the Platform, user preferences, username or similar identifier, your account information, and any other identifier we may use to contact you or build a user profile for you to be able to use the Platform.

Commercial Information Information about your purchases through our Platform or your use of our services which includes but is not limited to your purchase order history, your user habits and preferences, your customer profile, and information related to your commercial transactions on our platform.

Technical Information This includes your account login information, browser type and version, time-zone setting, browser plug-ins, operating system and platform, or information about your internet connection, the equipment you use to access our Platform, and your usage details.

Profile Information Thi includes your username, age, e-mail address and/or telephone number, information you disclose in your user profile, your contact list (as exists in the Platform), and your profile information.

Non-personal Demographic Information This information does not directly or indirectly reveal your identity or directly relate to you as a specific identifiable individual and includes demographic information, geographical information and location, or statistical or aggregated information. Statistical or aggregated data does not directly identify a particular person, but we may derive non-personal statistical or aggregated data from personal information.

User Generated Content: This includes any information you share with us (including in correspondence with us via e-mail or other means) or upload to the platform including messages to other users.

Marketing Information This includes information on your preferences for receiving information about offers, promotions, and other marketing materials from us.

Other Information: We may collect other information that constitutes Personal Information or “data” as used in this Policy, which is not specifically described herein, but we will treat such other information in accordance with this Policy nonetheless.

How We Collect Information

Information you give us: When you do such things such as sign up for an account, or input user data, or communicate with us, you voluntarily submit this data to us.

Information Automatically Collected: We use technologies such as cookies, web beacons, or similar tracking technologies, and other technologies such as Google Analytics, to collect certain information automatically or passively about visitors to our Platform and those interacting with our e-mails or online advertisements. You may have options to change your browser settings to choose how we can collect some of this information.

Information from third-party platforms: We may choose to maintain pages for our services on third-party platforms including popular social media platforms such as Facebook or Instagram, among others. When you interact with our Platform through such a platform, the specific platform’s privacy policy and terms and conditions will apply. If you submit information to us through your use of said third-party platforms, then we will treat your data in accordance with this Policy.

If you utilize our Platform or services through a third-party platform’s functionality, such as by connecting your GyftEasy account to a social media platform, we may collect additional information from you related to the platform you access GyftEasy from. Such information may include your social media platform profile picture, name, and other information which said third-party platform may make available to us. All such information collected by us shall be treated by us in accordance with this Policy.

How we use the information

We use identifiers, commercial information, online activity, geolocation information, user-generated content, and financial content we collect for different business purposes, including those listed below. We are committed to protecting and maintaining your privacy with regards to such information, and will only process and store your data in a lawful manner under applicable data protection laws, such as if:

• We need to process your information to provide you with the services you request from us;
• We need to share such information with third-party service providers that we engage or hire to perform business or commercial services for us (such as to develop or maintain our Platform and systems, and to process your payments);
• To share such information with merchants from who you are redeeming gift cards from;
• You have consented to such processing;
• We have a legitimate interest for processing your data – such as in the case of fraud prevention, network and information systems security, data analytics, enhancing, modifying, or improving our services, identifying user trends and behaviours, determining the effectiveness of promotional campaigns, and personalization of the service using data to make it easier for you to use our services, and or,
• We are required to do so to comply with an applicable legal process such as a criminal or civil court proceeding.

We may use your information for a variety of commercial purposes, including but not limited to:

• Reaching out to you with offers or promotions;
• Marketing and advertising;
• Sharing your information with third-party advertisers;
• For analytical and demographic purposes;
• As otherwise described in this Policy or in the Terms of Service which incorporates this Policy by reference.

Data Security and Retention

The security and safety of your data is very important to us. Although we do our best to protect your data, we cannot guarantee the security of your data (which includes Personal Information) that you transmit through us through our Platform. Any transmission of data is done at your own risk. We are further not responsible for any circumvention of privacy setting that may be contained in our Platform.

Except as otherwise permitted or required by applicable law or regulation, we will only retain your data for as long as is necessary to carry out the purposes that we have collected it for in connection with our Platform, including but not limited to satisfying any legal, accounting, or data retention requirements imposed by law. Under some circumstances, we may also anonymize your 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 without your consent.

Accessing and Correcting Your Data

It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes. By law, you have the right to request access to and to correct Personal Information we hold about you.

If you would like to review, verify, correct, or withdraw your consent to the use of your Personal Information or data by us, you can send us an e-mail at [admin@gyfteasy.com] and we will make the required changes.

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 to make your requested changes as discussed above. If we cannot provide you with access to your Personal Information, we will inform you of the reason for why such is the case, subject however to any legal or regulatory restrictions on our ability to do so.

How We Secure your Data

We are committed to handling your Personal Information and other data with high standards of data security. We maintain physical, electronic, and procedural safeguards and protocols to protect your data both during its transmissions and after we receive it. When you enter sensitive information (such as credit card information) into our Platform, we encrypt the transmission of said information using secure socket layer encryption (SSL). While this is the case, no method of transmission over the internet can ever be 100% secure. Therefore, we cannot guarantee the absolute security of your information in all situations.

Third Party Content, Links, Plug-ins, Licensed Software

Our Platform may contain links to other platforms, websites, applications, or online services. Accessing such third parties may allow said third parties to collect or share data about you. Such links are not an endorsement or promotion of said third parties by us, and we accept no responsibility for what may befall you if you choose to access those third-party platforms, websites, or online services. It is your responsibility to appraise yourself of the platforms’ specific privacy policy and terms and conditions.

Data Transfers

Though we are located in Canada, we may at times transfer your data to parties located in other countries to assist us with our business and the functioning of our Platform. By using our Platform, you are consenting to such data transfers.

Withdrawing your Consent

You may at anytime withdraw your consent to this Privacy Policy, which forms part of our Terms of Service. Should you do this, you will have to immediately cease using the Platform.

Changes

This Privacy Policy, like our Terms of Service are subject to change at any time and, subject to legal requirements, without any advance notice. It is your responsibility to periodically check this Policy to keep yourself updated as to any changes.

Last Updated: [16-Sep-2023]