App Privacy — SHOP THIS CITY

PRIVACY POLICY

Unless otherwise defined in this privacy policy all capitalized terms have the same meaning as in our Terms of Service.

Shop This City Online Inc. (“Shop This City” or “we”, “us”, or “our”) values your privacy. This privacy policy describes in detail the types of personal information we collect, use, and disclose when you visit the Website, use our application (“App”) or other services (collectively, “Service”), or communicate with us.

What information Shop This City collects

"User Personal Information" is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of “User Personal Information.”

User Personal Information does not include aggregated, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Service.

Information users provide directly to Shop This City

Registration information

We require some basic information at the time of account creation. When you create your own username and password, we ask you for a valid email address, optional demographic information, and your approximate location.

Profile information

You may choose to give us more information for your Account profile, such as your full name, an avatar which may include a photograph, your biography, your location, your shopping history, your favorites, and a URL link to a third-party social media profile. This information may include User Personal Information. Please note that your profile information may be visible to other Users of our Service.

Information Shop This City automatically collects

Usage information

If you're accessing our Service, we automatically collect the same basic information that most service providers collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the items you view, your search history, the referring site, your IP address and session information, and the date and time of each request. This is information we collect from every visitor to the Service, whether they have an Account or not. This information may include User Personal information.

As further described below, we automatically collect information from cookies (such as cookie ID and settings) to keep you logged in, to remember your preferences, to identify you and your device and to analyze your use of our Service.

Device information

We may collect certain information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include User Personal information.

What information Shop This City does not collect

We do not intentionally collect “Sensitive Personal Information”, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.

If you are a child under the age of 13, you may not have an Account on Shop This City. Shop This City does not knowingly collect information from or direct any of our content specifically to children under 13. If we learn or have reason to suspect that you are a User who is under the age of 13, we

will close your Account. Please see our Terms of Service for information about Account termination. Different countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not have an Account on Shop This City.

How Shop This City uses your information

We may use your information for the following purposes:

• We use your registration information to create your Account, and to provide you the Service.

• We use your User Personal Information, specifically your username, to identify you on Shop This City.

• We use your profile information to fill out your Account profile and to share that profile with other users if you ask us to.

• We use your email address to communicate with you, if you've said that's okay, and only for the reasons you’ve said that’s okay. Please see our section on email communication for more information.

• We use User Personal Information to respond to support requests.

• We use User Personal Information and other data to make recommendations for you, such as to suggest items you may want to view or local retailers you may want to follow. We learn from your behavior on Shop This City—such as the items you “like”—to determine your interests, and we recommend similar items.

• We may use User Personal Information to invite you to take part in special promotions, surveys, beta programs, or other research projects, subject, where necessary, with your consent.

• We use usage information and device information to better understand how our Users use Shop This City and to improve our Website and App.

• We may use your User Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm Shop This City, our Users or Retail Partners. • We may use your User Personal Information to comply with our legal obligations, protect our intellectual property, and enforce our Terms of Service.

• We may use your location information to indicate to our Retail Partners the traffic that we are bringing to their locations.

• We limit our use of your User Personal Information to the purposes listed in this privacy policy. If we need to use your User Personal Information for other purposes, we will ask your permission first.

Our legal bases for processing information

To the extent that our processing of your User Personal Information is subject to certain international laws (including, but not limited to, the European Union's General Data Protection Regulation (GDPR)), Shop This City is required to notify you about the legal basis on which we process User Personal Information. Shop This City processes User Personal Information on the following legal bases:

• Contract Performance:

o When you create a Shop This City Account, you provide your registration information. We require this information for you to enter into the Terms of Service agreement with us, and we process that information on the basis of performing that contract. We also process your username and email address on other legal bases, as described below.

o When you access the websites of our Retail Partners, we process usage information and additional elements in order to perform the contract that applies to those services.

• Consent:

o We rely on your consent to use your User Personal Information under the following circumstances: when you fill out the information in your user profile; when you decide to participate in a Shop This City promotion, research project, beta program, or survey; we rely on your consent to collect location information from you and for marketing purposes, where applicable. All of this User Personal Information is entirely optional, and you may withdraw your consent at any time by emailing us at privacy@shophis.city and asking us to delete your account and any personal information we have collected.

• Legitimate Interests:

o Generally, the remainder of the processing of User Personal Information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of Shop This City’s systems, Website, and Service.

• If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please contact our privacy officer at privacy@shopthis.city.

How we share the information we collect

We may share your User Personal Information with third parties under one of the following circumstances:

With your consent

We share your User Personal Information, if you consent, after letting you know what information will be shared, with whom, and why. For example, if we offer a special promotion that involves sharing your shopping habits over a period of time with our Retail Partners that may be of interest to you.

With service providers

We share User Personal Information with a limited number of service providers who process it on our behalf to provide or improve our Service, and who have agreed to privacy restrictions similar to the ones in our privacy policy by making similar commitments. Our service providers perform analytics, search engine optimization, customer support ticketing, network data transmission, security, location tracking and other similar services. While Shop This City processes all User Personal Information in Canada our service providers may process data outside of Canada, the United States, or the European Union.

For legal disclosure

Shop This City strives for transparency in complying with legal process and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. Shop This City may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.

Change in control or sale

We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Website, through the App, or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will be asked to honor any promises we made in our privacy policy or Terms of Service.

Aggregate, non-personally identifying information

We may disclose certain aggregated, non-personally identifying information to others, including our Retail Partners about how our users, collectively, use Shop This City, or how our users respond to our other offerings, such as our promotions and advertising.

We may also disclose aggregate, non-personally identifying location information to our Retail Partners or other third parties such as the number of our Users who enter a physical retail store.

We do not sell your User Personal Information for monetary or other consideration. How you can access and control the information we collect

If you are already a Shop This City user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting Shop This City. You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by contacting Shop This City.

Data portability

As a Shop This City User, you can always take your data with you. Contact Shop This City regarding extracting your data from us.

Data retention and deletion of data

Generally, Shop This City retains User Personal Information for as long as your account is active or as needed to provide you the Services.

If you would like to cancel your account or delete your User Personal Information, you may do so by contacting Shop This City. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 90 days of your request. You may contact Shop This City to request the erasure of the data we process.

After an account has been deleted, all User Personal Information will be erased; however, certain data, such as de-identified aggregate data will remain.

Our use of cookies and tracking

Shop This City only uses cookies that are necessary. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors.

We use cookies solely to provide security and improve our Service. For example, we use them to keep you logged in, remember your preferences, identify your device for security purposes, analyze your use of our service, compile statistical reports, and provide information for future development of Shop This City.

By using our Service, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept these cookies, you may be unable to access certain parts of our Service.

How Shop This City Secures Your Information

Shop This City takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information. We do not ever store your password, and user

authentication is handled via a third party service (Google Firebase Authentication Services) which validates User identity to our application via token exchange. This third party service employs all reasonable security measures to protect your User Information and is used to increase security. All data exchanges regarding authentication are encrypted via SSH. Shop This City at no time has access to both your user information and passwords. We do store your email address in plain text on our servers.

In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected Users without undue delay.

Transmission of data on Shop This City is encrypted using SSH and HTTPS (TLS).

No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the security of your information.

Shop This City and Global Users

We store and process the information that we collect in Canada in accordance with this privacy policy, though our service providers may store and process data outside of Canada [and the United States].

We provide the same high standard of privacy protection—as described in this privacy policy—to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business.

In particular:

• Shop This City provides clear methods of unambiguous, informed, specific, and freely given consent at the time of data collection, when we collect your User Personal Information using consent as a basis.

• We collect only the minimum amount of User Personal Information necessary for our purposes, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.

• We offer you simple methods of accessing, altering, or deleting the User Personal Information we have collected, where legally permitted.

• We provide our Users notice, choice, accountability, security, and access regarding their User Personal Information, and we limit the purpose for processing it. We also provide our Users a method of recourse and enforcement.

How we communicate with you

We use your email address or App notifications to communicate with you, if you have said that's okay, and only for the reasons you’ve said that’s okay. For example, if you have signed up to follow a retailer or specific items, we will provide the information you requested through email or App notifications.

Depending on your email and app notification settings, Shop This City may occasionally send notifications and emails about promotions, new features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, based on your choices and

in accordance with applicable laws and regulations. There is an “unsubscribe” link located at the bottom of each of the marketing emails we send you. Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your profile to opt out of other communications.

Resolving complaints

If you have concerns about the way Shop This City is handling your User Personal Information, please let us know immediately. We want to help. You may contact us directly at privacy@shopthis.city with the subject line "Privacy Concerns." We will respond promptly.

Changes to our Privacy Statement

Although most changes are likely to be minor, Shop This City may change our privacy policy from time to time. We will provide notification to Users of material changes to this privacy policy through our Website and App at least 30 days prior to the change taking effect by posting a notice on our home page, or sending email to the primary email address specified in your Shop This City account, or sending a notification through the App. For other changes to this privacy policy, we encourage Users to check our Website privacy policy page frequently.

Contacting Shop This City

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

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.