Privacy Policy — Protect

At Reklaim Ltd. ("we," "our," "us," or "Reklaim"), your privacy is of the utmost importance. Thank you for taking the time to read our privacy policy (the "Privacy Policy"). This Privacy Policy sets out how we collect, use, process, store, and disclose your personal information on https://www.reklaimyours.com (the "Website") and our mobile and web applications (the "Platform").

Reklaim Protect provides identity and data protection services, including monitoring, alerts, and removal assistance, by acting on your behalf to mitigate the misuse or exposure of your personal information. The Services provided through the Platform in accordance with our Terms and Conditions. This Privacy Policy sets out how we collect, use, process, store, and disclose your personal information in providing our Services.

By joining and using our Services, you freely and expressly consent to the collection, use, processing, storage, and disclosure of your personal information as set out in this Privacy Policy.

Separate from our Services, we provide our business customers ("Customers") with 'Data Broker' activities, which consist of selling, sharing, or licensing personal information that Reklaim receives from third parties to our Customers for their own independent marketing, communications, or other business purposes. For example, Reklaim may use the insights provided by our Services to produce an audience of prospective customers for advertisers to target with advertisements (that excludes any of our mobile app users' personal information). If you are interested in exercising your privacy rights related to our Data Broker activities or would like to learn more about our Data Broker activities, please visit our Data Broker Privacy Notice.

1. When We Collect Information

We may collect personal information that you provide when you:

• Register or otherwise sign up for our Services;
• Use our Services;
• Visit our Website or Platform;
• Contact us;
• Otherwise, provide us with your consent.

2. Types of Personal Information We Collect

Information you provide:

• You provide information to create an account, such as your name, email address, and phone number.
• Information you may choose to provide to Third Parties through the Platform, including contact details such as your name, email address, postal address, and phone number.

Please note that any information you voluntarily provide through the Platform are deemed to be affirmative written consent for Reklaim to 'share' the specific nature of these responses in conjunction with your personal information, unless otherwise restricted by you through use of the Platform.

• Information from your inquiries into our Services, or how you otherwise indicate you may be interested in our Services, may include providing us with your name, email, phone number, and any corresponding message to us.
• Information when you use our interactive chatbot may include providing your contact information.

Information we automatically collect:

• Records of your consent (e.g., the date and time) for Reklaim to disclose your information to Purchasers.
• Metadata and analytics with your use of our Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, and what you do on those pages.
• Use cookies, pixel tags, application programming interfaces (API), software development kits (SDK), and similar tracking technologies to collect additional information automatically as you interact with the Services and personalize your experience with our Services.

Information from third parties:

• When you elect Reklaim to search for your data online by pressing 'scan for data,' Reklaim may gather your personal information from third parties such as data brokers. This information may be disclosed to Purchasers unless you restrict its use through the Platform.
• When you elect to have Reklaim search for your information associated with public data security breaches, Reklaim does not obtain any additional data from these data breaches beyond confirmation if an email address or phone number is included in a publicly available data security breach. We make no claims regarding the accuracy of the information associated with a specific data security breach and disclaim all liability for information that Reklaim may enable you to view.
• When you interact with our accounts on our community forums or through our brand or community forums on a social media platform, we may collect certain information that you or the platform make available to us, such as Website metadata analytics, your social media account ID, your social media 'likes,' click-throughs to our Website, or custom interactions.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To operate our Services, namely to facilitate the sale of your information to Purchasers with your consent.
• To search the Internet on your behalf to determine if your information may have been associated with a publicly available data security breach.
• To improve our Services.
• To process payments securely.
• For customer support.
• To communicate with you.
• For marketing and advertising with the exception of any phone numbers provided to Reklaim.
• For other business and legal purposes, such as detecting and preventing fraud, collecting amounts owing to us, and maintaining business records.
• Otherwise, with your consent.

4. How We Disclose Your Personal Information

We may disclose your information with our corporate affiliates, as well as vendors or service providers who:

• Help us communicate with you through our email updates.
• Manage and optimize our Services. As part of our Services, we may utilize third-party data brokers to provide information about you. These third parties are restricted from using the information shared for any purpose other than to give Reklaim information or related services, and you will only receive more marketing offers as a result of these disclosures if you provide us with specific consent for such use.
• Help us provide our chatbot. This may include disclosing communications with our service provider, Intercom.
• Provide marketing and advertising services.

In addition:

• We may share your personal information to protect the legal rights of our company, employees, agents, and affiliates.
• To protect the safety and security of our customers.
• To detect and protect against fraud.
• To comply with the law or legal process.

We may share de-identified, aggregate, or anonymous information for any purpose. This means the information we share does not identify specific individuals or is combined with other data to protect your privacy.

5. Your Privacy Choices

You have the right to exercise the following choices with our use of your personal information:

• Access the personal information we maintain about you.
• Delete the personal information we maintain about you.
• Correct inaccurate personal information we maintain about you.
• Opt out of specific uses of your personal information, notably:
• Email marketing. Follow the 'Unsubscribe' link in the footer of any commercial email message. Please note that we may continue communicating with you about Service-specific messages following an unsubscribe request. To cease all communications, your account must be terminated.
• SMS (text messages). Reply to any SMS with the keyword 'Stop.'
• Push notifications. Adjust the settings in your mobile operating system.
• Tailored advertising using third-party cookies. Please refer to the 'Use of Cookies and Tracking Technologies' section below to learn how to opt out of tailored ads.

You can exercise these rights by contacting us at privacy@reklaimyours.com or via the Platform.

6. Use of Cookies and Tracking Technologies

Like many companies, we use cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect information about your browsing activities, your interactions with websites and our Services, and to serve tailored ads and for the purposes described in this Privacy Policy. There are several ways to opt out of having your online activity and device data collected through these services, which we summarize below:

• You can opt out of cookie use in our Cookie Preferences. You can opt out of third-party advertising cookies via our cookie preferences center or by clicking the 'Do Not Sell or Share My Personal Information' link on our website footer.
• Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit the use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info.

Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you must opt out on every browser and device you use.

7. Security

We protect information we collect about you by maintaining physical, electronic, and procedural safeguards designed to prevent unauthorized access to user data retained in our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We take reasonable precautions to protect your information both online and offline. The servers on which we store data are kept in a secure environment.

8. Retention

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the website or any requested services and for a reasonable time after that in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Any account that has yet to be logged into and for which no payment for services has been provided for 90 days or more may be deemed inactive. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

9. U.S. State-Specific Disclosure

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or "CPRA" (collectively, the "CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), Utah Consumer Privacy Act ("UCPA"), Oregon Consumer Privacy Act ("OCPA"), Texas Data Privacy and Security Act ("TXDPSA"), and the Montana Consumer Data Privacy Act ("MTCDPA") create additional privacy obligations for businesses and provide their residents with additional privacy rights.

Additional Privacy Rights:

In addition to the rights granted in 'Your Privacy Choices' above, if you are a resident of the above states, you have the right to:

• Opt out of the "sale" or "share" of your personal information for targeted advertising. Some third-party cookies placed on our website or mobile advertising identifiers collected through our application may be considered a 'sale' or 'share' for targeted advertising. You may opt out of such cookies as detailed in the 'Use Of Cookies And Tracking Technologies' section above. Additionally, with your consent, we 'sell'/'share' the information you provide us to Purchasers. You can update your consent in the Platform at any time.
• Sensitive personal information. Certain U.S. states have the right to limit the use of their sensitive personal information, including information provided through our Platform, such as ethnicity or health-related information. Residents of Virginia, Colorado, Connecticut, Oregon, Texas, and Montana have the right to opt into the use of their sensitive personal information. We only collect sensitive personal information you choose to provide, which is deemed affirmative consent for the 'sale' of such information. You can update your consent to collect, process, and disclose your sensitive personal information on the Platform anytime.

You can exercise these rights by contacting us at privacy@reklaimyours.com or via the Platform.

Appeal:

If we deny your privacy request, you may appeal that decision by emailing us at privacy@reklaimyours.com. If you are still unsatisfied with our response, you have the right to file a complaint with your state attorney general.

Service Provider/Processor Designation:

We operate as a Controller (and a Business under CCPA).

10. Children's Privacy

We qualify all of our Services as exclusively available for visitors at least 18 years of age. If you believe we have obtained personal information associated with children under 18, please contact us at privacy@reklaimyours.com, and we will delete it.

11. Third-Party Links on Our Website

Our Services may contain links to other websites or services. We do not exercise control over the information you provide, or that is collected by these third-party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy on this page with a "Last Updated" effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

13. Contact Us

If you have any questions about our privacy or security practices, or if you would like to request access to or correction of your personal information, you can contact us by email at privacy@reklaimyours.com or at:

Attn: Privacy Officer
Reklaim Ltd.
PO Box 60029 Etobicoke RPO
Thorncrest, ON
M9A 5G2

Residents of Canada may also reach out to our Privacy Officer:

Neil Sweeney
CEO
privacy@reklaimyours.com