Last modified: April 10, 2023

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Introduction

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GhostRetail Inc. (“GhostRetail”, "Company" or "we" or its derivations (e.g. “our”)) respects your privacy and is committed to protecting it by complying with this policy.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website, and users ("you").
• The types of information we may collect from you or that you may provide when you visit the website located at https://www.ghostretail.com, which include any content, functionality, products and services, including our live video shopping platform (the “Platform”), as offered on or through the website (collectively, "Website").  
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

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.

By using (the word “use” in this Privacy Policy will mean “access or use”) the Website, you expressly consent to Our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This policy may change from time to time in accordance with the terms of this Privacy Policy (below). 

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Information We Collect About You

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We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, phone number, billing and account information,, IP address, and any other identifier we may use to contact you or that you provide when you use the Website or provide when you contact us. 

We provide an opportunity for any user to or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to privacy@ghostretail.com.

• Non-personal information (“NPI”), that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as statistical or aggregated information. NPI, including statistical or aggregated data does not directly identify a specific person. 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 portion of the Website feature. 
• Technical information, including your 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, and usage details.

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/services you viewed or searched for, page response times, , length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

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How We Collect Information About You

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Methods of Collection

We collect your information your information through various methods:

• When you are a user and you are viewing, accessing, interacting or otherwise using the content on or via the Website, including the Platform.
• When you are a customer that has purchased a subscription to our services or Platform.
• When you provide information or content for us to publish or display on the public or paid portions of the Website, or to transmit to other Website users, customers or third parties.
• 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 (e.g. for support or marketing requests). 
• When you interact with us on our social media profiles.
• When you attend a marketing event, provide us with your business cards and/or provide us with your personal data for marketing purposes.
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

You may also provide information and content to be published or displayed (hereinafter, "posted") on the Website or transmitted or made available to other users of the Website or third parties (collectively, "User Contributions", as further defined in Terms of Service. Your User Contributions are posted on and transmitted to others at your own risk. We cannot and do not guarantee that unauthorized persons will not view your User Contributions.

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Information We Collect Through Cookies and Other Automatic Data Collection Technologies  

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:

• 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.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

We use Google Analytics, which uses cookies to track information about traffic and visitors and sends such information (i) to Google servers in the United States and (ii) to us.  Google Analytics does not identify any individual users or associate your IP address with any other data held by Google.   We uses such information in the aggregate to compile statistical reports about the activity on the Website and our services as well as to benchmark the Website and our services to other third parties who also use Google Analytics.  This information is used by us to improve the Website and our services and their functionality. Google’s privacy policy can be found here: policies.google.com/privacy 

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How We Use Your Information

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We use information that we collect about you or that you provide to us, including any personal information:

• to present and provide our Website and its contents to you and other users;
• to allow you to participate in interactive features or similar features on our Website;
• to facilitate transactions between you and us, and between you and other users; 
• 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.
• to provide you with notices about your account or subscription, including expiration and renewal notices.
• to establish and maintain responsible commercial relations with you;
• to permit our payment provider, to provide payment services;
• to respond to any correspondence you may direct to us;
• 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;
• to provide you with information, products, or services that you request from us;
• to notify you about changes to our Website or any products or services we offer or provide though it;
• to improve our Website, products or services, marketing, or customer relationships and experiences;
• in any other way we may describe when you provide the information; and
• for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

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Consent

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We respects your privacy and, unless otherwise required by law, we will not collect, use or disclose your personal information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally or through any electronic means.  In certain circumstances, your consent may be implied by your actions.  For example, providing us personal information to register for our services is implied consent to use such information to provide you the associates services.

Where appropriate, we will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when we] wants to use information for a purpose other than those identified in this Privacy Policy).  

The form of consent sought by us may vary, depending upon the circumstances and type of information disclosed. 

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Withdrawing Your Consent

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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 at privacy@ghostretail.com. 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. 

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Disclosure Of Your Information

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We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• 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 Ghost Retail Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ghost Retail Inc. about our customers and users is among the assets transferred.
• To contractors, service providers, and other third parties we use to support our business (such as payment providers, 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.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of service and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ghost Retail Inc., our customers, or others. 

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Links To Third Party Services

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• 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.
• You may create links between Ghost Retail Inc.’s services or Ghost Retail Inc.’s Website and social media online services.  If You do so, Ghost Retail Inc. may be able to publish updates about Ghost Retail Inc. or our services to your social media service accounts through the links that You establish. You may terminate those links at any time by modifying your social network account.  
• You may change the way social media services and our services or Website interact by modifying your privacy settings in your social media account. You can also log-out of your social media account before using our Website or services. For more information, please refer to your social media services’ privacy policy, which governs your use of these features.

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Transferring Your Personal Information Outside Of Canada

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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.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

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Choices About How We Use And Disclose Your Information

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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: 

• 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. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to Privacy@ghostretail.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to us as part of or messages related to our services you have purchased or other transactions.

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Data Security

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The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you or where you have chosen a password or other access credentials for access to certain parts of our Website, you are responsible for keeping these credentials confidential. 

The transmission of information via the Internet is not completely secure. 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. 

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Data Retention

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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. 

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Children Under The Age Of 13

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Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Website. We do not knowingly collect personal information from children under 13. 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 at Privacy@ghostretail.com.

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Accessing And Correcting Your Personal Information

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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.

You can review and change your personal information by logging into the Website and visiting your account profile page. 

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 Privacy@ghostretail.com to request access to, correct, or delete any personal information that you have provided to us. 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 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. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. 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.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.

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 been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Service.

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Changes To Our Privacy Policy

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It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. 

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 address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

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Contact Information And Challenging Compliance

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We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: 

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Privacy Officer

93-301 Dunlop St. E

Barrie, ON

L4M 1A8

Or:

Privacy@ghostretail.com 

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We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.