PRIVACY POLICY

Introduction

TopSavings Inc. ("TopSavings", "we" or "us") is committed to protecting your privacy and confidentiality in accordance with its obligations under the Personal Information Protection and Electronic Documents Act and the applicable provincial privacy legislation.

This Privacy Policy (the "Policy") explains how we will collect, use and disclose your Personal Information. We urge you to read the Policy carefully in order to gain a clear understanding of how we may collect, use or disclose your Personal Information in the course of your use of its products and services. By registering for and using this app, you agree to the terms of the Policy.

The Policy covers the following:

What is Personal Information? What Personal Information do we collect? Why do we collect your Personal Information? How do we collect your Personal Information? How do we use your Personal Information? When may we disclose your Personal Information? How can you access or correct any inaccuracies in your Personal Information? How do we protect your Personal Information? Links to third party websites Resolving your privacy concerns Changes to this Privacy Policy

In the delivery of its products and services, TopSavings complies with the following principles set out in Schedule I to PIPEDA:

Principle 4.1 (Accountability) - An organization is responsible for personal information under its control and must designate an individual responsible for compliance with PIPEDA;

Principle 4.2 (Identifying Purposes) - An organization must specify why it is collecting personal information, and such purposes must be identified at or before the information is collected;

Principle 4.3 (Consent) - An organization must obtain an individual's consent for the collection of personal information and subsequent use and disclosure;

Principle 4.4 (Limiting Collection) - An organization must limit the collection of information to that which is necessary for the identified purposes;

Principle 4.5 (Limiting Use, Disclosure, and Retention) - An organization must not use or disclose personal information for a purpose other than for which it was collected, except with the consent of the individual or where required or permitted by law;

Principle 4.6 (Accuracy) - An organization must ensure that personal information it maintains is accurate, complete, and up to date;

Principle 4.7 (Safeguards) - An organization must take appropriate safeguards to protect personal information;

Principle 4.8 (Openness) - An organization must be open about its policies and practices;

Principle 4.9 (Individual Access) - An organization must provide individuals with a right of access to their personal information, subject to certain restrictions as set out in PIPEDA; and

Principle 4.10 (Challenging Compliance) - An organization must advise individuals of its complaint procedures.

1. What is Personal Information?

"Personal Information" means any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address).

The Policy does not cover business contact information or aggregated data from which the identity of an individual cannot be determined. TopSavings retains the right to use business contact information and aggregated data in any way that it determines appropriate.

2. What Personal Information do we collect?

We collect the following Personal Information from you during your use of the TopSavings app: information regarding the location and names of the stores you visit and the products that you scan by means of your electronic device during your use of the app. This data is then aggregated and used for the purposes of improving the provision of our products and services.

We may also collect your Personal Information, such as your name and contact information if you choose to contact us by e-mail or telephone, or respond to e-mails, newsletters or promotional or other information communications from us.

We may also automatically collect non-personally identifiable information about your use of our products and services when you interact with or use our products or services, in order to better understand how individuals use our Services, and to improve the Services to better meet your needs.

3. Why do we collect Personal Information? We may use the Personal Information you provide to improve the quality of our products and services. In order to provide you with the product and price information at nearby stores we may use your location.

4. How do we collect your Personal Information?

TopSavings only collects Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing you with our products or services. We use only fair and lawful methods to collect Personal Information.

Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and disclosure of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information.

In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, our products or services can only be offered if you provide your Personal Information to us. Consequently, if you choose not provide us with the required Personal Information, we may not be able to offer you these products or services. We will inform you of the consequences of the withdrawal of consent.

5. How do we use Your Personal Information?

We use the information we collect to provide you with our products and services, and to respond to your questions. We also use it to provide a better user experience and to continue improving the quality of our products and services.

We also use the information we collect to ensure that our products and services remain functioning and secure, or to investigate, prevent or act on any illegal activities or violations of the Terms of Use. Our use of Personal Information is limited to the purposes described in this Policy and we do not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information we have collected from you.

6. When may we disclose your Personal Information?

We may disclose your Personal Information to:

(a) Individuals or organizations who are our advisers or service providers; and (b) Individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading our computer systems.

(i) Third Party Service Providers or Contractors [if applicable]

We contract with third party service providers to provide support services required for the provision of our products and services. Where we transfer Personal Information to service providers or contractors that perform services on our behalf, we will require those third parties to use such information solely for the purposes of providing services to TopSavings or our users, and to have appropriate safeguards for the protection of that Personal Information. Sharing of information with third party service providers and contractors will occur only after those entities have entered into a confidentiality agreement that:

(a) prohibits them from using, allowing access to, or disclosing your Personal Information to any other party (unless required to do so by law); and

(b) requires them to have appropriate protections in place to ensure the ongoing confidentiality of your Personal Information.

We may transfer personal information to a service provider which is located outside of Canada where privacy laws may offer different levels of protection from those in Canada. Your personal information may also be subject to access by and disclosure to law enforcement agencies under the applicable foreign legislation.

(iii) Where disclosure can be made without consent

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where TopSavings is obliged to disclose information without your consent. Such circumstances may include:

(a) where required by law or by order or requirement of a court, administrative agency or governmental tribunal; (b) where TopSavings believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group; (c) where it is necessary to permit TopSavings to pursue available remedies or limit any damages that we may sustain; (d) where the information is public as permitted by law; (e) where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or (f) where it is necessary for the purpose of a prospective business transaction if the information is necessary to determine whether to proceed with the transaction or to complete the transaction, or a completed business transaction where the information is necessary to carry on the activity that was the object of the transaction. A "business transaction" includes:

the purchase, sale or other acquisition or disposition of an organization or a part of an organization, or any of its assets; the merger or amalgamation of two or more organizations; the making of a loan or provision of other financing to an organization or a part of an organization; the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities of an organization; the lease or licensing of any of an organization's assets; and any other prescribed arrangement between two or more organizations to conduct a business activity. Where obliged or permitted to disclose information without consent, we will not disclose more information than is required.

7. How can you access or correct any inaccuracies in your Personal Information?

TopSavings endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, we will revise the Personal Information and, if necessary, use its best efforts to inform third party service providers or contractors which were provided with inaccurate information so that those third parties may also correct their records.

TopSavings permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.

We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.

When your Personal Information is no longer required for our purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.

8. How do we protect your Personal Information?

TopSavings endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information. TopSavings further protects Personal Information by restricting access to it to those employees that require access to the information in order that we may provide our products and services.

A "breach of security safeguards" is defined as the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization's security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving Personal Information under TopSavings' control, we will notify the affected individual and the Privacy Commissioner of Canada if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the individual, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach.

9. Resolving your privacy concerns

In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) the Policy; please contact our Privacy Officer by sending an e-mail to privacy@TopSavings.com.

TopSavings will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.

10. Changes to this Privacy Policy

We will update this Policy from time to time if our practices change or if the law requires changes to it. We will post any Policy changes on this page, and, if the changes are significant, we will provide a more prominent notice and a summary of the relevant changes at the top of the page. You should review this Policy regularly for changes, and can easily see if changes have been made by checking the Effective Date below.

If you do not agree to the terms of this Policy, you should exit the app and cease use of all TopSavings services immediately. Your continued use following the posting of any changes to this Policy means you agree to be bound by the terms of the Policy.

Effective Date: This Policy was last updated on May 14, 2018.