Privacy — Ledge

The Ledge Inc.

Privacy Notice

1. Introduction

The Ledge Inc. ("Ledge" also referred to as "we" or "us") understands and respects the importance of the Personal Information we collect to manage our business and maintain commercial relationships. The Ledge has developed the present privacy notice (the "Notice") to explain how we collect, use, and disclose (“Process”) information about identifiable individuals (“Personal Information”) such as you. This Notice also describes your Personal Information protection rights and how to exercise them.

Some provisions may exceed regulatory requirements. In such circumstance, Ledge has full discretion with respect to their application.

2. Notice Requirements

2.1 Accountability: Who is Responsible for my Personal Information?

Ledge is responsible for the Personal Information we Process. We have appointed a Chief Privacy Officer ("CPO") to oversee our compliance with applicable Personal Information protection legislation.

2.1.1 Ledge Contact details

127 Davenport Rd
Toronto, Ontario
M5R 1H8
+1 (437) 993-1563

2.2 What Personal Information do we Process?

Ledge Processes the following Personal Information:

(a) Identity and contact information: including your name, location, phone number, email address and age.

(b) Profile and usage information: including passwords to our app or password protected platforms or services, your preferences in receiving marketing information from us, your communication preferences and information about how you use our app including the services you viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, and mouse-overs).

(c) Technical information: including information collected during your visits to our app, the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating systems and platform.

Please note: If you provide Personal Information to us about anyone other than yourself, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsources service providers, to us it.

2.3 Why do we Process your Personal Information?

Ledge processes your Personal Information to manage our business and to maintain and develop commercial relationships. We only Process such information as is necessary for those purposes. If we are required to Process your Personal Information for a purpose that differs from the purposes described herein, we will obtain your consent before doing so except in those circumstances set out in Section 2.8 of the Notice.

Purposes for which we Process Personal Information are as follows:

(a) As required by us to conduct our business and pursue our legitimate interests in particular:

(i) to provide our services and to respond to and address any questions or concerns relating to our services;

(ii) to analyse and improve our services and communications including our app operations and to monitor compliance with our policies and standards;

(iii) to manage access to our premises and for security purposes;

(iv) to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;

(v) for insurance purposes; and

(vi) to collect information about your preferences to personalize and improve the quality of our communications with you; and

(b) As required by us to conduct marketing or other promotional activity including to communicate promotional material that you have requested and to which you may unsubscribe by clicking on the Unsubscribe link or following the Unsubscribe instructions included in every mail;

(i) to protect our rights and safety as well as that on any third parties;

(ii) to comply with any legal requirements or court orders;

(iii) to prosecute and defend a court, arbitration, or similar proceeding; and

(iv) to communicate this information to any advisors who assists us in complying with legal, accounting, or security requirements, and

(d) as otherwise permitted by law.

Ledge will only provide you with marketing related information after you have, where legally required to do so, opted to receive that communication, and having provided the opportunity for you to opt out at any time.

Ledge will not use your Personal Information for taking any automated decisions affecting or creating profiles other than as described above.

Ledge will not use Personal Information for a purpose other than for which it was collected except with your consent unless:

(a) legal, medical or security reasons make it impossible to obtain consent; or

(b) Ledge is permitted or required to do so by applicable laws.

2.4 How do we collect your Personal Information?

The circumstances in which Ledge may collect Personal Information about you include:

(a) when you use our app;

(b) when you provide services to us;

(c) when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including in conversation with our employees;

(d) when you or your organization browse, complete a form (including information reporting a problem with the app) or make an enquiry or otherwise interact on our app or other online platforms you are willingly providing information which could be included in the collection of Personal Information. Depending on the circumstances, this may include Personal Information such as, but not limited to, physical mailing address, personal email address, phone number(s), and other details like gender, occupation, and other demographic information. More information on how our app Processes Personal Information can be found in section 2.7 below; and

2.5 What Happens if I don’t Provide my Personal Information?

Where we need to collect Personal Information by law or in order to Process your instructions or perform a contract we have with you and you fail to provide that Personal Information when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.

2.6 How much Personal Information do we Require?

Ledge limits the Personal Information we Process to what is necessary for managing our business and maintaining and developing our commercial relationships.

2.7 How is your Personal Information Processed when using our App?

2.7.1 Information Collected from your Use of Our App

To ensure our App is optimized for ease of use, and/or for future communications, Ledge or our service provider(s) may collect standard information about how and when you use the app. This information may include but is not limited to your IP address and location data, weblogs, time, date, language preferences, browser used, referring web addresses, other communication data, searches conducted and pages visited.

Our email marketing communications may contain a single, campaign-unique "web beacon pixel" to tell us whether our email is opened and combined with other technology verify any clicks through to links within the email. We may use the information for purposes including determining which of our email is more interesting to you and to query whether users who do not open our email wish to continue receiving them. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, through email you can opt not to download images from Ledge.

You may also choose not to click in the email marketing communications that we send you. This information may be connected to your personal identity.

2.7.2 Social Media Widgets

Ledge's app may include widgets, such as the "Share This" button or interactive mini-programs that run on our app. Social media features and widgets are either hosted by a third party or hosted directly on our app. Your interactions with these features are governed by the privacy policy of the company providing such service.

2.7.3

Ledge's app includes links to other apps or internet sites, the privacy practices of which may differ from ours. If you submit Personal Information to any of those apps or internet sites, your information is governed by the Personal Information protection policies of those apps or internet sites, and we do not accept any responsibility or liability in respect of third-party apps or sites. Please check the privacy policies published on any third-party app or site which you may access thought our app before submitting Personal Information to them.

2.8 Do we Share your Personal Information?

Ledge shares your Personal Information only in the following circumstances and with the following recipients:

(i) on a confidential basis with third parties for the purpose of collecting your feedback on our service, to help us measure our performance and to improve and promote our services;

(ii) with companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such Personal Information is shared;

(iii) with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;

(iv) with service providers who we engage within or outside of Ledge, domestically or abroad, (e.g. shared service centres), to Process Personal Information for any of the purposes listed above on our behalf and in accordance with our instructions only; and

(v) if we engage in a commercial or business transaction - as defined by applicable privacy legislation - in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.

Please note: Ledge, its third-party service providers and other third parties to whom we disclose information under the Notice may perform activities outside of Canada.

Any Personal Information that is Processed in countries outside of Canada may be subject to the laws of those countries (e.g. where a third party service provider operates internationally). As a result, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement officials in countries outside of Canada.

You may seek additional information regarding the Processing of your Personal Information outside of Canada by contacting our CPO at the contact details found in Subsection 2.1.2 above

2.9 How long do we Retain your Personal Information?

Ledge will not retain Personal Information longer than is necessary to fulfil the purpose for which it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. As this purpose varies depending upon the Personal Information involved, we invite you to contact our CPO for any inquiries pertaining specifically to you.

Inactive files will be kept 12 months after the last recorded date of activity. Upon expiry of the applicable retention period we will securely destroy your Personal Information in accordance with applicable laws and regulations and with our document retention policy.

2.10 How do we Ensure your Personal Information is Accurate?

Ledge uses reasonable efforts to ensure that your Personal Information is kept as accurate, complete and up to date as possible. We do not routinely update your Personal Information, unless such an update in necessary. In order to help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide to us.

2.11 How do we Safeguard your Personal Information?

Ledge is committed to protecting the confidentiality, integrity, and availability of your Personal Information. We employ security safeguards that are customary in the gaming sector and appropriate to the sensitivity of the information, including physical, organizational, and technological measures. Examples of such measures include training of personnel, limiting access to information on a "need-to-know" basis, using passwords and well-defined internal policies and practices.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of data transmitted to our app. Any transmission you provide is at your own risk. Once we have received your information, we will apply our security practices to try to prevent unauthorized access, use and/or disclosure.

Ledge may store and Process your Personal Information at our offices in Toronto. We use contractual and other means to provide a comparable level of protection while information is being stored, handled, and Processed using any third party service providers.

2.12 Whom to Contact with Questions

Ledge is committed to being transparent about our policies and invites you to contact the CPO with any question you may have or to visit our app.

2.13 What are your Rights?

Depending on the jurisdiction in which you reside, you have various rights with respect to our use of your Personal Information:

(a) Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information. To do so, please contact us at the details provided at Subsection 2.1.2.There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information.

(b) Accuracy: We aim to keep your Personal Information accurate, current, and complete. We encourage you to contact us to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.

(c) Withdraw Consent: If you have provided your consent to the Processing of your Personal Information, you have the right to fully or partly withdraw your consent. To withdraw your consent please follow the opt-out links on any marketing message sent to you or contact the CPO. Once we have received notification that you have withdrawn your consent, we will no longer Process your information for the purpose(s) to which you originally consented unless there is another legal ground for the Processing. Withdrawal of consent to receive marketing communications will not affect the Processing of Personal Information for the provision of our services.

(d) Cessation of Dissemination: You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order.

You also have the right to request that we cease disseminating your Personal Information where the following conditions are met:

(i) the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;

(ii) the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

(iii) the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

(e) De-indexation: You have the right to request that we de-index any hyperlink attached to your name that provides access to information by a technological means if the dissemination is contrary to the law or a court order.

You also have the right to request that we de-index a link providing access to information where the following conditions are met:

(i) the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;

(ii) the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

(iii) the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

(f) Re-indexation: You also have the right to request that we re-index a link providing access to information where the following conditions are met:

(i) a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected;

(ii) the injury caused by a failure to re-index is greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

(iii) the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.

(g) Mobility: You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.

(h) Complaints: If you believe that your Personal Information protection rights may have been violated, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts.

You may enquire about your Personal Information by contacting our CPO or making a request to view your Personal Information by clicking here {⚫}.

Ledge will generally respond to all access requests within 30 days of the receipt of all necessary information. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.

Ledge may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request.

2.14 How do we Resolve your Concerns?

Any report, concern, complaint or incident of which we become aware that involves conduct that may contravene the Notice will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry and implement solutions, as appropriate.

2.14.1 Incident Reporting and Escalation Process

We take all potential or actual Personal Information breaches seriously.

You may report your concerns about the Processing of your Personal Information directly to our CPO.

The CPO will engage the appropriate levels of management to assist with resolution of the issue.

2.14.2 Alternative Actions

While we are committed to resolving all Personal Information matters internally, nothing in the Notice precludes you from contacting the appropriate federal or provincial privacy commissioner.

2.14.3 Prohibition Against Retaliation

We will not retaliate against a Person who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.

3. Maintenance and Review

The Notice is effective May 1, 2023, and supersedes all prior versions.

Ledge reserves the right to interpret the Notice at its sole discretion and to make changes as it deems appropriate from time to time without the requirement of advanced notice.

Personal Information protection legislation continues to evolve and, as a result, this Notice may be amended by us from time to time at our full discretion without any prior notice or liability to you or any other persons. The Processing of your Personal Information by us will be governed by the version of this Notice in effect at that time