Committment to Privacy

Kwesst Intelligent Micro Systems doing business as Kwesst ("Company") is committed to maintaining the security and privacy of your personal information. This Policy documents our on-going commitment to you and has been developed in compliance with the Freedom of Information and Protection of Privacy Act ("FIPPA").

Scope of Policy

In accordance with FIPPA, this Policy addresses personal information about individuals and does not apply to information about corporate or commercial entities who are our suppliers or customers. Commercial information may be subject to protection under other polices and practices and through contractual arrangements, including confidentiality agreements. This Policy does not impose any limits on the collection, use or disclosure of the following information by Company:

• your business contact information; or

• publicly available information recognized under FIPPA.

Accountability

Company is accountable and responsible for personal information under its control. Company has designated a Privacy Officer who is accountable for Company’s compliance with this Policy. Company will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy polices and procedures and communicate polices and procedures to you.

Purpose

Company has certain affiliates, subsidiaries or entities that are related to Company (together with Company, referred to as the “Corporate Group”) who share a common vision to work together to maximize customer satisfaction and improve products and services. To meet these objectives, Company shares your personal information with our affiliates, subsidiaries or entities that are related to Company. However, Company does not sell your personal information to any third party. Company collects your personal information for the following purposes:

• to determine which products and services of the Corporate Group may meet your potential needs, to share such information within the Corporate Group to improve the products and services, internal programs and operations of the Corporate Group and for internal statistical analysis purposes;

• to customize and optimize the websites and any promotional campaigns of the Corporate Group in accordance with your interests;

• to provide you with information, updates about new products, special offers, updates or other information relating to the business of the Corporate Group;

• to protect the Corporate Group, yourself and others from fraud and error and to safeguard the financial interests of the Corporate Group;

• to authenticate your identity;

• to contact you for market research or promotional purposes (which may be by e-mail, phone and/or mail) •to collect debts owed to Company;

• to manage or transfer assets or liabilities of Company, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a carrier;

• to comply with legal and regulatory requirements.

The purposes listed above are a reasonably necessary part of your relationship with Company. When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by FIPPA or other law.

Consent

Company will obtain your consent to collect, use or disclose personal information except where Company is authorized or required by PIPA or other law to do so without consent. Your consent may be express or implied, or given through your authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify Company that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice to you) or otherwise. For example, oral consent could be expressed over the telephone at the time information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form. You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to Company. Upon receipt of your written notice, Company will inform you of the likely consequences of the withdrawal, which may include the inability of Company to provide certain products or services for which the delivery of that information is a prerequisite.

Limits on Collection of Personal Information

Company will not collect personal information indiscriminately and will limit its collection of your personal information to what is reasonably necessary to provide a product or service and which is reasonably necessary for the purposes consented to by you. Company may also collect information as authorized by PIPA or other law.

Retention of Personal Information

Your personal information will only be used or disclosed for the purposes set out above and as authorized by PIPA and other law. Company will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision. Company will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. Company will take due care when destroying personal information so as to prevent unauthorized access to such information.

Accuracy

Company will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. Company will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate. If you notify Company of the inaccuracy or incompleteness of personal information, Company will amend the information as required. If appropriate, Company will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, Company will annotate the personal information under its control with a note that a correction was requested but not made.

Safeguarding Personal Information

Company protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. You should be aware that confidentiality and security are not assured when information is transmitted through e-mail or wireless communication. Company will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when information is transmitted by e-mail or wireless communication.

Providing Access

You have a right to access your personal information held by Company. Upon written request and authentication of identity, Company will provide you with personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to whom such information has been disclosed. Company may charge a reasonable fee for providing personal information in response to a FIPPA access request and will provide an estimate of any such fee upon receiving a written access to personal information request. Company may require a deposit for all or part of the fee. Company will make personal information available within 30 days or provide written notice where additional time is required to fulfill the request. In some situations, Company may not be able to provide access to certain personal information. Company may also be prevented by law from providing access to certain personal information. Where an access request is refused in whole or in part, Company will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.

Changes to Policy

To keep pace with economic, technological and regulatory changes, Company may revise this Policy from time to time. The revised Policy will be posted on our website, and will come into effect 30 days after it is posted.

Complaints

Any inquiry, complaint or question regarding this Privacy Policy must be directed in writing to the Company Privacy Officer.

Contact Information:
Privacy Officer
Kwesst Intelligent Micro Systems
info@kwesst.com

Definitions

In this Policy: The terms "Company” or "our" refer to Kwesst Intelligent Micro Systems (doing business as Kwesst), an Ontario based Company; "collection" means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means; "consent" means voluntary agreement to the collection, use and disclosure of personal information for specified purposes; "disclosure" means making personal information available to a third party; "personal information" means information about an identifiable individual but does not include his or her business contact information. Personal information does not include (a) information concerning corporate or commercial entities or (b) publicly available information. It also does not include information that cannot be associated with a specific individual; "FIPPA" means the Freedom of Information and Protection of Privacy Act; "Privacy Officer" means an individual designated by Company who is accountable for compliance with this Policy by Company and whose contact particulars are set forth in this Policy; "third party" means an individual or organization other than Company and you; "use" means the treatment and handling of personal information by and within Company.

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