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Privacy Policy

This Privacy Policy is effective as of March 1st, 2022.The purpose of this Privacy Policy is to inform you on howSOULBERcollects and processes your personal data to provide you with our Services.It also contains information on some privacy rights that you can exercise.

The terms “we”, “us”, and “our” used in the Privacy Policy refer to the SOULBER app, owned and operated by Pini Holdings Inc.

SOULBER has developedan app you can download which guides you in your addiction recovery and provides you with a support community. Theplatformallows you and your family-members to take charge ofyour sobriety in order tobe your best self and reintegrate society. Our appalso aims to prepare you for post-treatment.

SOULBER does not knowingly collect any personal data from minors under the age of 16. If you think that yourchild has provided us with their personal data, we strongly encourage you to contact us immediately and we will do our best to promptly remove such information from our records.

1. WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies strictly to thisapp.

Our Services have optional features which, if used by you, require us to collect additional information to provide these features. We will inform you of these additional featuresas you navigate our app. If you choose not to use a certain feature, you will not need to provide the information needed to use the feature. For example, we need to collect the location data from your device to enable you to share your location with your contacts.

If you have any questions or concerns regarding how we collect and process your personal data or regarding your privacy, please do not hesitate to contact us:
[email protected]
1-833-768-5237
1083 Main Street
Champlain, New York
12919

2. WHEN DOES THIS PRIVACY POLICY NOT APPLY?

If you click a link that leads you from ourapptoathird-party website, application or service, this Privacy Policy does not extend to the collection and processing of personal data by these external services. For example, if you chose to use our Housing Services, you will be directed to a third party website and will no longer be within the SOULBER platform.

We encourage you to review third partyPrivacy Policies before using these external services.

3.WHAT IS“PERSONALDATA”?

“Personal Data”means any information that relates to an identified or identifiable natural person.Personal data can include online identifiers, such as your name, telephone number, address,e-mail and purchase information, including your credit card number and the history of your purchases.

Different jurisdictions may have different legal definition(s) of what constitutes personal data. We use a large definition for this Privacy Policy so that we can provide you with as much information as possible, but it is possible that the personal data covered in this Privacy Policy is not protected by your local laws.

4.WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND FOR WHAT PURPOSES?

We require certain information to provide our Services to you. For example, you must create an account in order to access our Services. If you choose to create an account on our app to access our Services, you must firstidentify yourself as a “Dependent”, meaning a recovering addict, or a “Guardian”, meaning a person supporting a recovering addict. When you choose to share the information below with us, we collect and use it to operate our Services. We have developed our app with a privacy-by-default approach, meaning that you, as a member, have choices about the personal data you choose to keep private.

Our Services include optional features that you can use. These features will collect and process additional information about you if you chose to use them. We notify you of such collection, as appropriate. If you choose not to provide the information needed to use a feature, you might be unable to use the feature. For example, you cannot share your location with your contacts if you do not permit us to collect your location data from your device.

Please note that you are responsible for the personal data and information you choose to share on our platform.

• Account Registration Data

Examples: Name, Email Address, Username, Password,Telephone Number, Membership Status (Dependent or Guardian), Gender, Picture, Bio, Emergency Contact Information

When you choose to create your account, we will collect the information that you share with us, such as your name, email, telephone number, address, username, password, membership statusand emergency contact. You might want to add other information to your account, such as a profile picture,bio, genderand the date you became sober, which you may choose to keep private.We collect and process this personal data to create and administer your account and todeliver our Services to you.

You can delete your account at anytime by contacting us as [email protected] may ask you about your reasons for wanting to delete your account,in order to improve our Services, which you may refuse to share with us. We will delete your account within ten (10) business days from receiving your request. Once the account is deleted, SOULBER will anonymize your personal data to use itfor statistical and research purposes. Please note that your participation in public activities such as forums and chats, and the information, comments, pictures, links and actions you have shared with the public community, will not be deleted once your account is deleted, we will anonymize the personal data before using it for secondary purposes.

• Purchase Data

Examples: purchased items, credit card information, address, transaction history, telephone number

Our Services are free for “Dependent” members. “Guardian” members are required to purchase aSOULBER membership to access our Services. We collect “Purchase Data” about you when you pay your membership fees or make an onlinepurchase through ourapp.SOULBERwill collect and process your credit card information directly from you to process your membership fees.

You can also make your payment by using one of our paymentservice providers, such as PayPal,Google Pay, Amazon Pay, etc.In doing so, SOULBER does not collect nor do we process your credit card information.Your personal data is shared directly with the payment service provider you have chosen. Our payment service providers are PCI DSS compliant, meaning that they have implemented standards to ensure secure payment solutions.

We will also collectthehistoryof your transactions for record-keeping purposes. Transaction historywill be processed to obtain statistical data about your participation as a member of SOULBER as well as to help us identify when your subscription is set to expire and/or auto-renew.

• DependentData

Examples: connections, who you follow and your followers, forum participation (comments, pictures, quotes, thoughts, ideas, statements), therapist consultations, AA/NA meeting participation, date you became sober, rewards, panic button use, emergency contact information, links and interactions with your Guardian.

When you become a “Dependent” member of SOULBER, you will have access to an online support community for recovering addicts. As a “Dependent” member,we will collect and process the personal data you share with usin order to provide you with a multitude of Services to support your recovery. You can choose to navigate the platform under a username, which offers you anonymity; or you can choose to identify yourself by revealing your real name. In fact, many of our features protect your confidentiality if you so wish.

Our Services provide you with a Dashboard that allows you to:

• Create connections with other SOULBERDependent members;

• Check the latest updates from your connections;

• Participate in chat forums and post stories;

• Search for housing;

• Find labs and therapists and book appointmentsdirectly through the platform;

• Find AA/NA meetings and book appointments directly through the platform;

• Chat with your connections

• Receive Rewardsfrom SOULBERand/or your “Guardian”for reaching set goals;

• Access a Panic buttonthat allows you to reach out for help when you feel you are going to relapse or when you feel the need to talk with someone. You will get a phone call from a trained volunteer through the platform itself – we use a spoof phone number so that you can maintain your anonymity. A HIPAA certified “dialer provider” is used to hide your caller ID (your name, your phone number and any personal data).

You can consent to sharing your personal data withyour “Guardian”, who can oversee your progress towards recovery and monitor your activities on the platform, such as your meetings with therapists, your participation in AA/NA meetings, the rewards you receive from SOULBER and/or your Guardian and your use of our Panic button. It is not required for “Dependent” members to be accompanied by a “Guardian” member, although it is recommended.

• Guardian Data

Examples: Name, name of Dependent and your interactions, allocated rewards, connections, who you follow and your followers, forum participation (comments, pictures, quotes, thoughts, ideas, statements)

As a “Guardian” member, you can find support from the Guardian community as well as monitor your Dependent’s activitiesand their progress towards recovery by:

• Checking the latest updates on your Dependent;

• Creating connections with other SOULBERGuardians;

• Participating in forums for Guardian members;

• Monitoring your Dependent’s participation in therapy sessions and AA/NA meetings;

• Checking your Dependent’s sober test results;

• Being informed of your Dependent’s Rewards and PanicHistory;

• Offering your Dependent Rewards when goals are achieved.

• Public Forums and Discussions Data

As a Dependent and/or as a Guardian member of SOULBER, forums and discussions you create can be viewed by other SOULBER members along with the date and time you created them. Your participation in public forums and discussions, including viewing, listening, commenting, speaking, reacting to, or otherwise participating in them can be viewed by other SOULBER members. On our platform, we also register the date and time of your participation, as well as the hearts and comments you post, the number of hearts you receive, the accounts you are a Superfan of, the broadcasts you watched live or on replay. Any engagement you have with another account’s broadcast will remain part of that broadcast for as long as it remains on our Services.

When you share pictures or visualcontent on our app, we may analyze that data to operate our Services.

Information posted about you by other people who use our Services may be viewed by other SOULBER members. For example, with your consent, other members may tag you or mention you in a message.

You can choose to participate in SOULBER forums and discussions under a pseudonym (username) to safeguard your anonymity or by using your real name.

• Usage and Technical Log Data

Examples: IP address, browser type, Internet Service Provider, date and time of visit, referring/exit pages and number of clicks

When you visit our platform, we monitor usage and technical log data such asyour internet protocol (IP) address, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable to you. We monitor log files to analyze trends, administer our platform, fix bugs,prevent suspicious activity, track members' movements and gather demographic information.

• Communication Data

Examples: name, email address, message content, supporting documentation and attachments, zip/postal code, location and other pertinent information

If you inquire about our Services by email, through social media or otherwise, if you interact with us through any media or if you request support from us, we will process the personal data required to respond to your inquiries, including any attachments and content you include. We process such personal data based onyourimpliedconsent. We use a service provider to help SOULBER manage its support requests.

If you interact with us on social media, we will collect the personal data which you make available to us based on your implied consent. On social media, we will have access to your publicly available information when you interact with us. We process such personal data as well. Furthermore, when you interact with our social media accounts, data about you may be shared with the social media partners.

When you share our content through the social mediaon our websites, they may use your personal data for other purposes, please consult their privacy policies below:

• Housing Data

We do not collect or process your personal data if you choose to use our Housing Services. We have partnered with third party, Taste Recovery, which offerssoberliving homesto recovering addicts.When navigating our Housing Services, you are in fact navigating the Taste Recovery website.We therefor encourage you to read Taste Recovery’s Privacy Policy, as we are not liable for their Privacy practices.

• Marketing Data

Examples: Name, email, marketing and product preferences, transaction history, cookies, browsing habits.

With your consent, we will use your email address to provide you with commercial electronic messages (CEMs), promotional content andour newsletters.We send these commercial electronic messages in accordance with the Canadian Anti-Spam Law (CASL).

You can unsubscribe to our promotional content by clicking the “unsubscribe” link in our emails or by contacting usat [email protected]

5. WHAT TYPES OF “COOKIES” DO WE USE AND HOW?

Cookies are data files installed on your device (a computer tablet or mobile for instance) to fulfil several purposes. In this Privacy Policy, when we use the term “cookies”, we also mean similar tracking technologies such as tracking pixels (or pixels tags), web beacons and browser fingerprinting.

Cookies can be installed by us, in which case, they are called “first party cookies”. They can also be installed by third parties, such as Google Analytics and Amazon Advertising, referred to as “third party cookies” and result in the sharing of your personal data, such as your IP address, with these third parties.

We use essential, preference andanalyticalcookies to better understand how you interact with our application, to improve and personalize your experience, to provide SOULBER with some aggregated statistical data about how you use and browse our application and to allow third parties to generate aggregated statistics on our users. More specifically:

Essential cookies

We use “essential” cookies to ensure the functionality of our websites, namely by enabling basic activities like navigating our online pages and accessing the secure areas of our websites.

Preference cookies

We use “preference” cookies to recognize you each time you return to our websites, remember your preferences and your consents. For example, we create a persistent cookie that includes some basic information about you, like your most recent searches or your language preferences.

Analytical Cookies

Analytical cookies are used to generate aggregated statistical data about traffic and visitor behaviour on our websites. SOULBER uses Google Analytics to view key metrics such as how many visitors view the website, peak hours of traffic, duration and frequency of visits, pages visited, and key words searches. Google Analytics is Google’s analytical tool that helps us to understand how Visitors engage with our websites.Data collectedalso includes your IP address, geographic location, browser information, device identifiers, what websites you visited before and after your visit.

6. WHAT IS INTEREST-BASED ADVERTISING AND DO WE CONDUCT ANY?

SOULBER does not participate in or conduct interest-based advertising. Interest-based advertising (also known as targeted or behavioral advertising) means that your preferences and

interests are collected through cookies or otherwise and then used to serve you advertising and marketing materials that are relevant to you (based on those preferences and interests).

Without interest-based advertisingyou would still be getting ads when browsing the Internet. However, these ads would not be personalized based on your preferences and interests; they would be less relevant to you and less effective for us.

For more information on interest-based advertising, please visit the Digital Advertising Alliance (“DAA”)and the Digital Advertising Alliance of Canada’s (“DAAC”) at https://youradchoices.com & https://youradchoices.ca.

7. HOW DO I MANAGE MY COOKIE PREFERENCES?

You can manage your cookie preferences through your browser using the instructions provided below by clicking on the browser that you are using. However, by blocking some cookies that enable the functions of the Services, parts of the Services may not be available.

You can also install the Google Analytics opt-out browser add-on, which prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

8. DO WE SHAREPERSONAL DATA WITH THIRD PARTIES?

We will not disclose, trade, rent, sell or otherwise transfer your personal data without yourconsent, except as set out in this Privacy Policy.

We do sell anonymized data to health related companies to support research in addictions treatment and recovery processes. Anonymization is a technique used to remove all personal identifiers from a record so that the individual can no longer be known or identified.

We may transfer your personal data to service providers that are assisting us in our operations and to conduct our marketing activities.

We may share your personal data with thirdparties in some circumstances, includingto administer, provide, secure and improve ourproducts and services,to host our Cloud servicesor if required by law pursuant to a subpoena or other legal process.

Here are the various types of service providers with whom we share your personal data:

o Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services and provide useful reporting features to brand partners and their users (Google Analytics);

o Third party advertising partners, ad servers and ad networks (such as Google Ads andDoubleClick);

o Providers of IT services and online cloud storage services (such as Google Cloud );

o Housing Services (Taste Recovery);

o Payment Service Providers (PayPal, Google Pay, Apple Pay, Amazon Pay).

We may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce or apply our policies and agreements; (e) to protect our rights, operations or property; (f) to collect amounts owed to us; (g) to allow us to pursue available remedies or limit the damages that we may sustain; (h) to protect the safety of our stakeholders; (i) to address, prevent or stop fraud or other activity that we consider to be illegal or unethical; or (j) to address an emergency involving danger of death or serious harm.

9. HOW DO WE PROTECT YOUR PERSONAL DATA?

SOULBERhas established reasonable physical, organizational and technological security measures in an effort to protect your personal data from loss or theft, unauthorized access, use, or disclosure. For example, your personal data can only be accessed on a need-to-know basis for specific purposesand is stored behind password-protected systems with encrypted connections when necessary. We also use contractual agreements and confidentiality agreements with our service providers.

Keep in mind the Internet is not entirely safe. No method of transmitting information over the Internet or of storing information is completely secure. It’s your responsibility to keep your credentials secure and ensure that you are connected on safe network connections.

10. WHERE DO WE STORE YOUR PERSONAL DATA?

Unless prohibited by law or contracts with our stakeholders, we may rely on service providers who are in the United States who assist us with the Services, in which case your personal data may be stored in or accessed from the United States. In that case, your personal data will be subject to United States laws and may be subject to disclosure to United States governments, courts or law enforcement or regulatory agencies, pursuant to those laws.

11. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

The personaldata that we process for an identified purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We store your personal data for as long as necessary to provide you with the services or as required by law, whichever is longer.

You can delete your account at any time by contacting us as [email protected] may ask you about your reasons for wanting to delete your account,in order to improve our Services, which you may refuse to share with us. We will delete your account within ten (10) business days from receiving your request. Once the account is deleted, SOULBER will anonymize your personal data to use itfor statistical and research purposes. Anonymization is a technique used to remove all personal identifiers from a record so that the individual can no longer be known or identified.

Please note that your participation in public activities such as forums and chats and the information, comments, pictures, links and actions you have shared with the public community, will not be deleted once your account is deleted, we anonymize your personal data so that it can be used to support research of the addiction and recovery process.

12. WHAT ARE YOUR PERSONAL DATA RIGHTS?

You have rights when it comes to your personal data! However, these rights may change depending on where you are located in the world. These rights generally include the right to access and correct your personal data, as well as the right to withdraw your consent. Some jurisdictions offer additional rights, such as the right to object to the processing of your personal data, the right to data portability and the right to restrict the processing of your personal data.

If you have questions regarding how SOULBERprocesses your personal data or you are looking to exercise your personal data rights, please reach out to us:
[email protected]
1-833-768-5237
1083 Main Street Champlain, New York 12919

Once we receive your request, we will get back to you within 30 days. It’s possible that we cannot comply with your request, for instance, if it’s not applicable under the law. If we can’t process your request, we will provide you with explanations.

We will try to help you with your request free of charge. However, we may request that you pay a reasonable fee if you request a transcript, a reproduction or for us to send a copy of your personal data, if the law allows us to do so. If we need to charge a fee to process your application, we will contact you before addressing your request.

For security reasons and to avoid any fraudulent requests, we may be required to ask that you provide a proof of identity with your request. We will not use such personal data for any other purposes.

The Office of the Privacy Commissioner of Canada (OPC) has published advice to help you access your personal data, as well as exercise your rights when it is held by a business. For more information, you can contact the OPC at:

Office of the Privacy Commissioner
30 Victoria Street
Gatineau, QuébecK1A 1H3
Toll-free: 1-800-282-1376

If you are not satisfied with how we process your request, you can communicate with the OPC and lodge a complaint by filling out this form.

If you are a resident of California, please know that we do not disclose your personal data to third parties for direct marketing purposes.For more information regarding how to exercise your privacy rights as a consumer under the California Consumer Privacy Act (“CCPA”),please follow this link.

If you are a citizen of the United States, please visit the Federal Trade Commission website more information on Consumer Privacy.

14. MAY I WITHDRAW MY CONSENT?

Yes, whenever we process your personal data based on your consent, you can withdraw that consent at any time by contacting us or by using the functionalities that we make available to you within your online account to adjust your profile and preferences and delete your account.

15. CAN YOU CHANGE THIS PRIVACY POLICY?

Yes, we may need to modify this Privacy Policy to reflect new processing activities, adapt to new laws and regulations or reflect technological changes or corporate changes, such as a result of a merger and acquisition.

In case of material changes, we will send you a notification within the app. You can view the date of the latest update at the top of this page and you can always reach out to us should you have any questions!

16. USER Content Responsibility

Any content i.e text, photos or videos uploaded by any user to the app from their account is solely their responsibility and Soulber will not be held responsible for anything.