Privacy Policy Last modified: 20 June 2017 Effective date: 5 June 2015

This privacy policy as well as our Terms of Use found here: www.clausehound.com/terms-use/ (“Terms of Use”) govern your access of the Clausehound Software Product, whether: (a) accessed on a computer connected to the internet at www.clausehound.com (the “Site”); (b) on the Clausehound social media properties; or (c) by mobile phone (individually and collectively, (a), (b) and (c) are the “Clausehound Software Product”), as owned and operated by Clausehound Inc. (“Clausehound”), a federal corporation having its registered address at 21 Anglesey Blvd, Toronto ON, M9A 3B4, Canada (referred to in these Terms as “we”, “us” or the “Company”). Terms capitalized but not defined in this Privacy Policy have the meanings set out in the Terms of Use.

Clausehound is committed to maintaining the confidentiality, integrity and security of any Personal Information (as defined below) about our subscribers of the Site. The Company strives to support individuals and business owners with the Clausehound Software Product, while respecting your privacy expectations and protecting your Personal Information. To demonstrate our commitment to protecting your privacy, we have developed this privacy policy (“Privacy Policy”), which describes how we will collect, use, disclose and protect your Personal Information through the Site.

By accessing and/or using the Clausehound Software Product, you agree to all the terms and conditions of this Privacy Policy and the Terms of Use (as defined above) which are incorporated here by reference. If you do not agree to all the terms and conditions of this Privacy Policy and the Terms of Use, please do not use the Clausehound Software Product.

The Company may amend or change this Privacy Policy at its sole discretion at any time, and in accordance with the amendment provisions set out in the Terms of Use. The use of the information we collect at any given point is subject to the Privacy Policy in effect at the time of collection. If we make any material changes we will notify you by email or by means of notice on the Clausehound Software Product prior to the change becoming effective. We will post the most current Privacy Policy on the Clausehound Software Product, and your use of the Clausehound Software Product is subject to the most current Privacy Policy as posted on the Clausehound Software Product at any time. We encourage you to periodically check our Privacy Policy for the latest information on our current policy.

If you have questions or concerns regarding our policy or practices, please contact our privacy officer by email at [email protected] or at the following address:

341 King Street East Suite 615 Toronto, Ontario M5A 1A1 Canada

If you do not receive acknowledgment of your inquiry or your inquiry has not been satisfactorily addressed, you can contact the Privacy Commissioner of Canada at:

112 Kent Street, Ottawa Ontario, K1A 1H3 1.800.282.1376 http://www.priv.gc.ca/

We may provide areas on our websites where you can post information about yourself and others and communicate with others or upload content. Such postings are governed by the Company’s Terms of Use or Contributor terms which can be accessed here: https://clausehound.com/terms-use or https://clausehound.com/contributor-terms-of-use, respectively. In addition, such postings may appear on other Clausehound Software Products or when searches are executed on the subject of your posting. We cannot control who reads your posting or what other users may do with the information you voluntarily post. Therefore, we encourage you to exercise discretion and caution with respect to your personal information.

Collection of information at registration

Registration may be required to use certain features of the Clausehound Software Product. You may register at www.clausehound.com/signup. As part of this registration, we will require that you submit certain information that is relevant to the purposes of the Clausehound Software Product. We collect the following information (“Personal Information”) from our subscriber’s registration information: first and last name, email address, and password.

Collection of information when you use the Clausehound Software Product

When you use the Clausehound Software Product, we may automatically collect and store certain information about your computer or device and your activities including but not limited to:

the IP address of your computer; the unique mobile device identifier; technical information about your computer or mobile device such as the type of device, mobile device identification number, web browser, other browser information (e.g., size, connection speed and connection type), and operating system or platform; your preferences and settings (time zone, language, etc.); and your internet provider or mobile carrier name. Collection through interaction with the Clausehound Software Product We may collect your Personal Information when you communicate it to us by using one of our web forms or other interactions with the Clausehound Software Product, by email, or by any other means of communication.

The Clausehound Software Product offers publicly-accessible blogs and may allow you to create expert pages and content which can be seen by others (collectively, “Public Content”). This Public Content and any of the information you post to the Site, such as reviews, are intended for public consumption. You should be aware that any information you provide in this area may be read, collected, and used by others who access them. We take no responsibility for any information which you or your employees, agents, contractors and representatives post or publish on the Clausehound Software Product and you agree to indemnify and hold us harmless for any loss, cost, complaint, damage, claim or liability whatsoever arising from any such post or publication. We may post your testimonials along with your name on the Clausehound Software Product from time to time if such information is provided to us.

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches and cookies.

“Traffic Data” is collected by the Clausehound Software Product and our third-party traffic analysis provider through the use of software that is included on the Clausehound Software Product as well as cookies that are stored temporarily on your computer. Together, these technologies help us manage our content by identifying which content is effective.

Cookies are small data files that are stored on a subscriber’s computer for record-keeping purposes. Cookies track where you travel on the Clausehound Software Product and what you look at. A session ID cookie expires when you close your browser. When you log into the Clausehound Software Product, your browser may ask if you want it to remember you as a registered subscriber of the Clausehound Software Product. If you accept, the session ID becomes a persistent cookie, which remains on your hard drive for an extended period of time. Although cookies are used by most major websites and are accepted by default by most web browsers, it may be possible to disable cookies via your browser settings.

We use session cookies and usage data to make it possible to navigate the secure environment inside the Clausehound Software Product and to keep, and periodically track, information about you for the purpose of creating a personalized web experience and improving the Clausehound Software Product or measuring and conveying to others the performance levels of the Clausehound Software Product. We may link the information we store in cookies to any personally identifiable information you submit while on the Clausehound Software Product. This is for the purpose of creating a personalized experience within the Clausehound Software Product, to assist Clausehound in understanding its users and subscribers, to design improvements to the Clausehound Software Product, and for the purpose of collecting usage and performance metrics.

We may allow third parties to use Cookies on the Clausehound Software Product to collect the same type of information for the same purposes as we do. Advertisers and advertising networks place advertisements on our websites and mobile applications. These companies as well as data analytics companies who service them may collect information, such as your computer’s IP address, browser information, mobile device ID, and search queries as you use the Clausehound Software Product. These companies also may use cookies and other technologies to collect data about you when you visit our Site. Cookies from advertising companies enable them to track your activity across various websites where they display advertisements and record and associate your activities, so they can show advertisements that they consider relevant to you. We do not have access to or control over the Cookies that these third-parties use.

Use of analytics tools

The Clausehound Software Product may from time to time implement other third-party analytics services that also use cookies. We will ensure that no personally identifiable information is included in those cookies. If the use of cookies by any service provider differs materially from the practices already listed, we will revise this document accordingly and notify existing customers of the change(s). Other cookies created by the Clausehound Software Product are used to secure your login session and to help ensure the security of your account. Such cookies are unrelated to the aforementioned traffic analysis and are never shared with third parties.

Location Data

When you access the Clausehound Software Product using a web browser or other application, we may gather and store certain types of information including: traffic data from your browser, your IP address, location, GPS signals sent by a mobile device, cookie information, and the pages you visit on the Clausehound Software Product. Traffic data is helpful in identifying and fixing problems with the Clausehound Software Product.

USE AND DISCLOSURE OF PERSONAL INFORMATION

The Company will not use or disclose Personal Information for purposes other than the identified purposes of the Clausehound Software Product. We may use your Personal Information (defined above) to:

enforce our Terms of Use; provide customer service and support, administrative messages, resolve disputes, and troubleshoot problems including helping third-party service providers fulfil their functions; fulfill your requests for certain features of the Clausehound Software Product or referrals to third-party service providers; customize, measure, and improve the Clausehound Software Product, including without limitation, learning about user preferences and clause preferences; offer or provide you with products and services including providing you information relating to receipts, technical notices, updates, and security alerts; inform you of targeted marketing, service updates, and promotional offers unless you opt out; assist us to measure our performance and to share performance information with others; to use and disclose such data to our community, with other data on the Clausehound platform, in an anonymous form in connection with research and development, the creation of Clausehound proprietary data, and analytical tools; comply with legal or regulatory requirements (as described below); and fulfill other purposes, subject to your explicit consent.

We may share personal information or feedback with affiliates, third-party vendors, consultants and other service providers who work for us. We may share your first name and comments or feedback with third-parties. We will not tie any other information, other than your first name, that can identify you to your comments or feedback. However, third-parties may be able to tell who you are from your comments, particularly if you provide your full name or your contact information in the comments. We may also disclose your information in an anonymous form to third-parties for the purpose of research and development, building our own proprietary data, and building further analytical tools.

Provided you have consented to us doing so, we may share personal information with our affiliate legal service providers.

In the event that the Company, or all or a portion of our business, or one or more of its divisions, is acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, liquidation or another similar transaction, your Personal Information shall be one of the transferred assets.

We may retain your Personal Information while you have an account with us and thereafter for as long as we need it for purposes not prohibited by applicable laws and subject to the provisions in our Terms. This data may be retained for approximately two (2) years after your relationship with us has been terminated. Clausehound reserves the right to retain any anonymized personal information for as long as such data is needed and not prohibited by applicable laws for the purpose of research and development and for building and refining Clausehound proprietary data and analytical tools.

Notwithstanding the foregoing, the Company reserves the right (and you authorize the Company) to share or disclose your Personal Information when the Company determines, at its sole discretion, that the disclosure of such information is necessary or appropriate:

to enforce our rights against you or in connection with a breach by you of this Privacy Policy or the Terms of Use; to investigate or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others; to prevent prohibited or illegal activities; or when required by any applicable law, rule, regulation, subpoena, or other legal process.

To use certain services on the Clausehound Software Product, we may require your credit card account information. By submitting your credit card account information through the Clausehound Software Product, you expressly consent to sharing of your information with third-party payment processors, other third-party service providers, and applicable businesses.

By using the Clausehound Software Product, you consent to the collection, use and disclosure of your Personal Information by us in the manner described in this Privacy Policy. You may always opt not to disclose certain Personal Information, but which may restrict your access to certain features of the Clausehound Software Product. For example, your name and email address are necessary to complete the registration process. At any time after registration, you may opt out of most email communication from us by clicking on the opt-out link at the bottom of our emails, or by contacting us at the contact details listed above. However, we may still contact you for administrative purposes. Withdrawing consent will not apply to actions the Company has already taken based on your prior consent.

By providing us your email address, you expressly consent and agree to receive emails and notifications from Clausehound (and other Clausehound users such as lawyers or experts that have contributed to Clausehound), for the purposes of, including without limitation: service updates, surveys, newsletters, promotional offers, and marketing to the email address provided by you.

The Company relies on you to ensure that the Personal Information you enter into our system is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. You may make changes or corrections to your Personal Information at any time.

When updating your personal information, we may ask you to verify your identity before we can act on your request. Unless required by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical. Where we can provide information access and correction, and when required by law, we will do so for free.

We also make every effort to ensure the accuracy of the information in our reports, displays, articles and support queries. However, you must verify all information created from your use of the Clausehound Software Product. We recommend that you consult a professional before completing any government or regulatory filing or otherwise relying upon the information, as the use of this information is at your own risk. You are responsible for ensuring that the information you have entered into our system is accurate, reliable and complete.

We may share your Personal Information with service providers who help us to run our operations or to otherwise fulfill your request or as required by law. Our service providers are restricted from using your Personal Information in any way other than for the service they are providing. We ensure that such third parties maintain reasonable and appropriate safeguards.

We may share information from or about you with subsidiaries, joint ventures, affiliates, or other companies under common control, in which case we will require them to honour this Privacy Policy.

Links to sites controlled or operated outside of our domain (each individually a “Third-party Site” and collectively the “Third Party Sites”) are provided as a convenience to you only and do not imply an endorsement by us of a Third Party Site or the company it purports to represent. We do not assume any responsibility for information and materials found on, or the privacy practices of, a Third Party Site. This Privacy Policy does not apply to a Third Party Site.

We take your privacy very seriously. To keep your Personal Information secure, you are required to safeguard your subscriber name and password information in accordance with the Terms of Use.

In addition, we restrict unauthorized access through protective policies, procedures, and technical measures, including:

providing reasonable physical and electronic safeguards with regard to the storage of Personal Information; limiting access to your Personal Information to those employees or contractors who we reasonably believe need to come into contact with that information to provide products or services to you or in order to do their jobs; and governing employees and other contractors by strict standards and policies to ensure that Personal Information is secure and treated with the utmost care and respect. Please note that no data transmission over the internet or otherwise can be guaranteed to be completely secure. As a result, while we strive to protect your Personal Information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk.

If you have a security related concern, please contact us at the contact details provided above. We will work closely with you to ensure a quick and personal response to your concerns.

IF YOU CHOOSE TO ACCESS THE CLAUSEHOUND SOFTWARE PRODUCT, YOU DO SO AT YOUR OWN RISK, AND ARE RESPONSIBLE FOR COMPLYING WITH ALL LOCAL LAWS, RULES AND REGULATIONS. WE MAY LIMIT THE AVAILABILITY OF THE CLAUSEHOUND SOFTWARE PRODUCT, IN WHOLE OR IN PART, TO ANY PERSON, GEOGRAPHIC AREA AND/OR JURISDICTION WE CHOOSE, AT ANY TIME AND IN OUR SOLE DISCRETION. OUR PRIVACY POLICY DOES NOT COVER THE INFORMATION PRACTICES OF OTHER COMPANIES AND ORGANIZATIONS WHO ADVERTISE OUR SERVICES, AND WHO MAY USE COOKIES, PIXEL TAGS, AND OTHER TECHNOLOGIES TO SERVE AND OFFER RELEVANT ADVERTISEMENTS.

In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we may notify you by the email address registered to your account.

We will never send email messages to customers requesting confidential information such as passwords, credit card numbers, or social security or social insurance numbers. Please do not act on any such emails as you may compromise your Personal Information by replying or by following links to a fraudulent website and in the case that you do act on such emails, we shall not be liable for any damages or costs you have incurred for such acts.

If any portion of this Privacy Policy is deemed unlawful, void or unenforceable by any arbitrator or court of competent jurisdiction, this Privacy Policy as a whole shall not be deemed unlawful, void or unenforceable, but only that portion of this Privacy Policy that is unlawful, void or unenforceable shall be stricken from this Privacy Policy. The insertions of headings are for convenient reference only and are not to affect the interpretation of this Privacy Policy.