Janus Concepts Inc. and our affiliates and subsidiaries (“we”, “us”, “our”) welcome all visitors to and users of (“you”), our website located at https://jci.technology (the “Site”). We are committed to ensuring the privacy and protection of all our clients. This policy was developed with this goal in mind and outlines the guidelines according to which we collect, maintain and protect personal information, and the use and disclosure of such personal 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.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

This policy applies to information we collect, use, or disclose about you on this Site, and in email, text and other electronic messages between you and us. This policy describes the various types of information we may collect from you or that you may provide when you visit the Site, or via such other email, texts and electronic messages. The Site 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.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Site after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT FROM YOU

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, fax number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you ("personal information").Please note that we provide an opportunity for any user to unsubscribe from our electronic messages or opt-out of contact for marketing or purposes on an ongoing basis by accessing our Site, using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to privacy@it-dept.ca

• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but 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 Site feature.

• Technical information, including information about your device, browser and internet connection and usage.

• Non-personal details about your Site interactions, including clickstream to, through and from our Site, or your time zone.

HOW WE COLLECT INFORMATION FROM YOU

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, e-mail, or otherwise. • User contributions, You may also provide information for us to publish or display on public Site areas or transmit to other Site users or third parties. • Automated technologies or interactions, as you navigate through our Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and/or other tracking technologies.

A: Information you provide to us, The information we collect directly from you on or through our Site may include:

• Information that you provide by filling in forms on our Site (including at the time of creating an account to use our Site, purchasing products and tracking orders, and posting material). We may also ask you for information when you participate in our CC Rewards program, and when you report a problem with our Site. • Records and copies of your correspondence (including e-mail addresses), if you contact us. • Details of transactions you carry out through our Site and of the fulfillment of your orders.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

We may also use these technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please consult the Digital Advertising Alliance of Canada Opt-Out Tool, located at https://youradchoices.ca/en/tools, for information on how you can opt out of behavioral tracking on our Site. You can also access this website to learn more about online behavioural advertising and how to stop third party servers/networks or websites from placing cookies on your devices. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns

The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site 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 Site according to your individual interests. • Speed up your searches. • Recognize you when you return to our Site.

HOW WE USE YOUR INFORMATION

• To present our Site and its contents to you. • To provide you with information, products, or services that you request from us (including, without limitation, to coordinate direct shipping from one of our manufacturers or suppliers to you). • 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 (for example, to administer our CC Rewards program). • To provide you with notices about your account. • 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 notify you about changes to our Site or any products or services we offer or provide though it. • To improve our Site, products or services, marketing, or customer relationships and experiences. • To allow you to participate in interactive features, social media, or similar features on our Site. • To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you. • In any other way we may describe when you provide the information. • For any other purpose with your consent.

We will not use any information our clients provide for any other commercial purposes, and such information will not be sold, rented, leased or forwarded to any third party other than as described in this policy. We may also use your information to contact you about goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data, adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails and/or e-mail us at privacy@it-dept.ca

DISCLOSURE OF YOUR INFORMATION

• To our subsidiaries and affiliates. • In accordance with applicable law, to a buyer or other successor in the event of a transaction, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our clients and users is among the assets transferred. • To third parties to market their products or services to you if you have consented to these disclosures. • To contractors/consultants, service providers, and other third parties we use to support our business (including without limitation analytics and search engine providers that assist us with Site improvement and optimization, suppliers, customer service providers, financial institutions, product service depots, warranty providers and delivery service providers) and who are contractually obligated to use personal information 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.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law. For example, we may be required to disclose personal information we receive from you (in any form) in connection with any investigation, prevention or the taking of any action regarding suspected or actual illegal activities. • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, or the rights, property, or safety of our clients, or others.

TRANSFERRING YOUR INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to use the personal information 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.

We may also transfer your personal information in the event of a merger, acquisition, reorganization or other sale of all or a portion of our assets (which may include the information).

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.

DATA SECURITY

The security of your personal information is very important to us. We use reasonable physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, taking into account the risks involved in the processing and the nature of the personal information.

We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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 your personal information transmitted to our Site. 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 Site.

DATA RETENTION

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.

CHILDREN UNDER THE AGE OF 13

Our site is not intended for children under 13 years of age. No one under age 13 may provide any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. 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@it-dept.ca.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

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.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an e-mail at privacy@it-dept.ca to request access to, correct, or delete any personal information that you have provided to us. 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 charge you a fee to access your personal information, however, we will notify you of any fee in advance.

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 are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at privacy@it-dept.ca.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Site users.

WITHDRAWING YOUR CONSENT

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@it-dept.ca. 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.

CHANGES TO OUR PRIVACY POLICY

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 e-mail to the e-mail address specified in your account and/or through a notice on the Site 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 Site and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: Privacy Manager: Ellis V. Email: privacy12@it-dept.ca Telephone: 647 792 9070 Mail: Janus Concepts Attention: Ellis V, Privacy Manager 18 King St East, Toronto, ON #1400

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.

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