PRIVACY POLICY

TECHNOLOGIES SNAPCYCLE INC.

(the "Company")

LAST UPDATED: MARCH 3, 2026

1. Introduction

The Company recognizes the importance of protecting the Personal Information (as defined in Section 2) that you provide to us. Therefore, we have implemented this Privacy Policy which describes the Company's policies and procedures on the collection, retention, use, and disclosure of personal information that may be transmitted to the Company when a User visits and/or uses the CIRCUIT application (the "Application") or our website https://www.snapcycle.ca/ (the "Site").

As we are a private company, this privacy policy is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and its regulations ("PIPEDA") as well as applicable provincial privacy laws and regulations, including the Act respecting the protection of personal information in the private sector (Quebec).

Please note that our privacy policy is subject to revision. The privacy statement posted below is our effective policy as of the date indicated at the top of the page.

BY PROVIDING PERSONAL INFORMATION TO THE COMPANY OR ITS PROVIDERS, THROUGH OUR APPLICATION, BY TELEPHONE, BY EMAIL, BY TEXT MESSAGE, IN PERSON, OR BY ANY OTHER MEANS, YOU CONSENT TO YOUR PERSONAL INFORMATION BEING COLLECTED, USED, DISCLOSED, RETAINED, AND DESTROYED AS PROVIDED IN THIS PRIVACY POLICY AND APPLICABLE LAWS AND REGULATIONS.

2. Personal Information

Personal information is information that relates to a natural person and allows that person to be identified, directly or indirectly.

3. Collection and Use

Information you give us. We collect information you provide to us, for example, when you use and/or register for services offered via the Application or our website (e.g., when you create your profile, search for the nearest recycling center, take a photo of your products to recycle, etc.), submit a comment or question on our mobile application or website by any means of communication, or send us any document containing personal information.

On each of these occasions, you may provide, including but not limited to, the following personal information:

• your first and last name;
• your place of residence;
• your date of birth;
• your username, your password;
• your contact information such as your email address, mailing address, phone number;
• your photo if you decide to associate a photo with your profile;
• any information concerning your use of our application or Site, including your browser cookies, IP address, preferences, and interests;
• your location when enabled and/or when the application is open;
• the items you scan when using the application;
• any other personal information you choose to provide to us.

3.1 Users of the Application and/or Website or interaction with us by email or text message

When you browse our Application or website or interact with us by email or text message, we may collect information about you as described below, some of which is collected automatically:

• Connection data, which may include your IP address, the date and time of your visit to the application, information about your device (such as make, model, and operating system), your language preferences, unique connection information, and cookies. Usage data and analytics, which may include login frequency, features you use, duration, and time of use.
• If you ask a question or wish to obtain additional information about our services or use our features, we may ask you to provide contact information, such as your first and last name, phone number, mailing address, and email address, as well as certain information about your needs or preferences or your social networks that you choose to share with us.
• Technical support questions, general comments you choose to provide.
• Any other Personal Information provided.

This information is collected to help us better understand your needs, preferences, and interactions with our application and the services offered, to conduct statistical, market, and performance studies to help us evaluate our services.

3.2 Phone Calls

If you contact us by phone, we may record the call and ask you to provide contact information, such as your name, address, phone number, and email address.

3.3 Disclosure

The Company retains Personal Information for as long as necessary to achieve its objectives.

The Company limits the communication and disclosure of your Personal Information for purposes other than those mentioned above, while taking into account the following clarifications and exceptions:

3.3.1 Law Enforcement

We may share your Personal Information to respond to law enforcement requests, court orders, or other legal processes, or if we believe that such disclosure is necessary to investigate, prevent, or respond to illegal activities, fraud, physical threats, or as required by any other applicable law or regulation, and to the extent necessary to protect the property, interests, and rights of the Company.

3.3.2 Our Employees and Authorized Service Providers

Authorized personnel may have access to your Personal Information to help us provide services to you.

Employees access and use this Personal Information in accordance with our instructions, only if they need to know this information, and by complying with strict confidentiality and security obligations.

Rest assured that our employees handle this information with the utmost discretion and rigor and have committed to acting in accordance with this privacy policy and applicable legal and regulatory requirements.

We ensure when necessary that the Personal Information to which our employees may have access is anonymized for all data provided.

3.3.4 Explicit Consent

The Company may also disclose your Personal Information if you expressly request it or consent to it.

4. Use of Your Information

The Company uses the personal information we collect to operate the Application or provide the services offered via the Application or the Site, provide customer support, diagnose the Application or the Site, monitor the use of Services, detect, prevent, and resolve technical problems, maintain security, personalize content, ensure compliance with laws and the general terms and conditions of the Application or the Site, remember information to help you effectively access your account, analyze aggregate data, and track user content and users as required or useful to comply with the Copyright Act, Canada's Anti-Spam Legislation, the Quebec Act respecting the protection of personal information in the private sector, the Personal Information Protection and Electronic Documents Act, and other applicable laws (the "Purposes").

We expressly acknowledge that we will not use your Personal Information for purposes other than the Purposes without your consent. Furthermore, we will only collect Personal Information to the extent necessary for the Purposes described above.

5. Notifications Sent to the User

We may use the email address provided by the user when creating their user account on the Application to send notifications related to it (including notices required by applicable law in lieu of communication by postal mail) while respecting the rules of Canada's Anti-Spam Legislation (CASL). If the user does not wish to receive such messages, the user may always unsubscribe by following the instructions contained in the message. If the user corresponds with us by email, we may retain the content of the emails, the user's email address, and their responses.

6. Your Personal Information and Third-Party Websites

Advertisements may appear on the Application. Our application may contain links to independent third-party websites. These independent third-party websites ("Third-Party Websites"), links to which are provided solely for your convenience, are not under our control and may be governed by their own privacy policies. The Company does not guarantee and is not responsible for the collection, use, retention, or disclosure of your Personal Information by these Third-Party Websites. The Company assumes no responsibility for the use of these Third-Party Websites or access to Third-Party Websites through the Application and/or the Site. By using our Application or the Site or by accessing Third-Party Websites through the Application or the Site, you release the Company from any liability regarding the actions, practices, and omissions of these third parties.

These advertisements may appear based on items scanned in real-time, but also and without limitation, based on our contest proposals or discount offers offered by our commercial partners.

8. Transfer of Personal Information Abroad (Applicable to Quebec Only)

Personal Information relating to personal data collected in the province of Quebec through the Application or the Site is currently stored in Canada, in the province of Quebec.

However, in the future, we may engage third-party service providers to process, manage, and host Personal Information on our behalf, which could be stored outside the province of Quebec. To the extent permitted by law, your personal information may be transferred to and stored on other servers located outside your jurisdiction. Before communicating your personal information outside of Quebec, we will conduct a privacy impact assessment in accordance with applicable law. By accepting this Privacy Policy, you consent to such transfer.

However, we will ensure to protect the Personal Information in our custody, including Personal Information entrusted to a service provider. Our policies and practices regarding the protection of Personal Information require that a written undertaking be signed by this service provider to respect its obligation to preserve the confidentiality and security of the Personal Information entrusted to it. This includes, among other things, the implementation of robust and effective security measures, as well as the prohibition of disclosing, transferring, or using your Personal Information to third parties, in accordance with applicable privacy legislation in the province of Quebec.

9. Protection of Personal Information

We take appropriate measures to ensure the confidentiality of Personal Information and to protect it against loss, as well as unauthorized access, disclosure, copying, use, or modification, taking into account the sensitivity of the information and the purposes for which it is intended.

The Company uses commercially reasonable and appropriate physical, electronic, and managerial procedures, as well as generally accepted industry standards, to safeguard and secure the Personal Information it collects.

To this end, we ensure to restrict access to our offices and computer equipment, train our staff, and require our agents and providers of goods and services with access to Personal Information to sign confidentiality agreements and implement equivalent security measures.

Please note, however, that since no mechanism offers maximum security, using the Internet to transmit, create, or host Personal Information always involves some risk.

If you believe your Personal Information has been compromised, we invite you to contact our Privacy Officer at the contact details listed in Section 17 of this policy.

10. Minors

The Company complies with the requirements of the Act respecting the protection of personal information in the private sector, CQLR, c. P-39.1 and the guidelines issued by the Office of the Privacy Commissioner of Canada (OPC).

The Company does not knowingly collect Personal Information from persons under the age of 18.

If a minor under the age of 14 wishes to use the Application, our Websites, our services, or contact us in any other way, the collection of Personal Information from this minor will not take place without the consent of the holder of parental authority or guardian.

If we learn that we have inadvertently collected Personal Information from persons under the age of 14 without the consent of the holder of parental authority or guardian, we will ensure that this information is removed from our records as soon as possible.

If you are the holder of parental authority or guardian of a minor under the age of 14 and you know that your minor child has provided us with Personal Information, we invite you to contact our Privacy Officer at the contact details listed in Section 17 of this policy so that we can take the necessary measures.

11. Retention Period

Unless a longer or shorter period is required by law, users' personal information is retained by the Company only for the duration necessary for the purposes for which it was collected. If we no longer have a legitimate and serious interest in continuing to process users' personal information, we will delete or anonymize it to the extent permitted by law. Destruction is carried out confidentially, either: by manual shredder or through a company specializing in secure certified shredding, if it concerns paper-based information; or by computer deletion, if it concerns information on technological media.

If you wish to know more about the retention period of your Personal Information, we invite you to contact our Privacy Officer, whose contact details appear in Section 17 of this policy.

12. Access, Rectification, Update of Personal Information and Withdrawal of Consent

In accordance with applicable privacy laws, you have the following rights regarding your personal information:

• Right of access: you can ask if we hold personal information about you and, if so, ask to access it and obtain a copy. Access to your personal information is free. However, reasonable fees may be charged for the transcription, reproduction, or transmission of this information. The Company will inform you of the approximate amount payable before proceeding with the transcription, reproduction, or transmission of your information.
• Right of rectification: if personal information concerning you is inaccurate, incomplete, or equivocal, or if its collection, communication, or retention is not compliant or authorized by law, you can require its rectification.
• Right to information: upon request, we also inform you of the personal information we have collected from you, the categories of persons who have access to your personal information within the Company, the retention period of personal information concerning you, as well as the contact details of the Privacy Officer within the Company.

If you wish to proceed with the review, consultation, rectification of this information, or to exercise your aforementioned right to information, or to exercise any other right that applicable law grants you, please send a written request to the following email address: support@snapcycle.ca.

In accordance with the law, the Privacy Officer will respond in writing to the request for access or rectification, and no later than 30 days from the date of receipt of the request. Failing to respond within 30 days of receiving such a request, the officer is deemed to have refused to accede to it.

The aforementioned Privacy Officer will justify any refusal to accede to a request for access and rectification and will indicate the provision of the law on which this refusal is based, the remedies available to you under the Act respecting the protection of personal information in the private sector, CQLR, c. P-39.1, and the time limit within which you can exercise them. They will also provide assistance, at your request, to help you understand the refusal.

You may at any time decide to no longer consent to your personal information being retained and/or disclosed and/or used, by sending a written request to support@snapcycle.ca. Upon receipt of the notice of revocation of your consent, we will cease to retain and/or disclose and/or use your personal information within a reasonable time, which will vary depending on the personal information we have collected and the purposes for which we collected it. Please note that we will send you a confirmation email upon receipt of your request. Please note that if you choose to withdraw your consent, your experience using the services and browsing offered by the application may no longer be optimal and you may no longer have access to all our services, all our features, and the entire Application or Site.

13. Electronic Communications (Emails)

Your email address may be used to send you electronic communications from time to time. You may at any time ask us to stop sending you electronic communications by contacting our Privacy Officer at the contact details listed in Section 17 of this policy or by following the unsubscribe instructions at the bottom of these communications, if applicable.

14. Cookies and Other Tracking Technologies on our Application and Website, through our services and in email communications

We use common information collection tools, such as usage data collection tools, cookies, and similar technologies to automatically collect information that may contain personal data from your computer or mobile device when you browse our Application or Site or interact with emails or text messages we have sent you.

By accessing and browsing our Application and Site, you consent to the use of cookies in accordance with this privacy policy and the terms of use of the application and Site. You can control and manage cookies in several ways. Be aware that removing or blocking cookies may have a negative impact on your user experience and that some parts of the Application and Website may no longer be fully accessible. Most browsers automatically accept cookies, but you can choose to accept or decline cookies through your browser controls, which are often found in the "Tools" or "Preferences" menu of your browser.

15. Changes

The Company reserves the right to modify this privacy policy at any time. These changes will be published on the Application and our Site and will take effect immediately upon publication. We will take reasonable steps, if necessary, to inform you of any material changes.

You can contact our Privacy Officer at the address or phone numbers indicated in Section 17 to obtain an up-to-date copy of the privacy policy.

16. Complaint Handling Process (Applicable to Quebec Only)

16.1 Receipt

Any complaint regarding the application of this privacy policy must be addressed in writing to our Privacy Officer at the email address indicated in Section 17.

The complaint must contain the name of the complainant, their contact details, including a phone number, as well as the subject and reasons for the complaint with enough detail to allow the Company to evaluate the complaint. Our Privacy Officer may request any additional information deemed necessary to evaluate the complaint.

16.2 Processing

Please note that the Company undertakes to treat all complaints received confidentially. Once the complaint is received, accompanied by any additional information deemed necessary and requested by our Privacy Officer, the Company will have thirty (30) days to analyze it.

At the end of their analysis, our Privacy Officer will provide the complainant with a written response explaining why the complaint was accepted or rejected.

The Company undertakes to make all reasonable efforts to process each complaint within thirty (30) days. However, if a complaint cannot be processed within this period, the complainant will be informed of the reasons for the extension, the status of the complaint, and the reasonable time required to provide a final response.

A separate file will be created for each complaint received, if applicable. The file must contain the complaint, the analysis and documentation supporting its evaluation, as well as the response sent to the person who filed the complaint.

You can also file a complaint in writing with the Commission d'accès à l'information - Direction de la surveillance at the following address: 900-2045, rue Stanley, Montréal, Québec, H3A 2V4 or by email at cai.communications@cai.gouv.qc.ca. However, we invite interested persons to first address our Privacy Officer and wait for the Company to have completed the complaint handling process.

17. Questions, Comments and Privacy Officer

The Company is responsible for the Personal Information in its custody or control and has designated a person responsible for ensuring compliance with this privacy policy and applicable Personal Information legislation.

If you have any questions, concerns, or complaints regarding this privacy policy or the Personal Information the Company holds about you, please contact our Privacy Officer +1 (581) 980-3768.