Privacy Policy

INTRODUCTION

Your privacy is important to the Sobol Inc. This Website Privacy Policy explains how Sobol Inc collects, uses and discloses personal information in connection with the Sobol Inc. website (the “Website”).

1. YOUR CONSENT

By providing Sobol Inc with your personal information, you consent to the collection, use, disclosure and retention of that information by Sobol Inc in connection with the Website in accordance with this Website Privacy Policy and as otherwise permitted by applicable law.

2. HOW Sobol Inc DEFINES PERSONAL INFORMATION

In this Website Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business. Personal information also does not include information that has been aggregated or anonymized, as explained in Section 10, below.

3. PERSONAL INFORMATION THAT Sobol Inc COLLECTS

(a) Information You Provide You may be asked to voluntarily give your personal information to Sobol Inc when you interact with the Website. For example, we may collect:

The Website may use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to collect information that assists Sobol Inc to improve its products, services, customer communications and advertising and to prevent fraud. Sobol Inc may use information collected through technological means to recognize you as a user of the Website, to facilitate and improve your use of the Website, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of the Website. Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and Sobol Inc will handle that non-personal information as explained below in this Website Privacy Policy unless applicable law requires otherwise. 4. HOW Sobol Inc USES PERSONAL INFORMATION Sobol Inc may use your personal information collected by Sobol Inc for purposes relating to or arising from your relationship and transactions with Sobol Inc and as otherwise set out in this Website Privacy Policy or permitted by applicable law, including:

5. HOW Sobol Inc DISCLOSES PERSONAL INFORMATION

(a) Specific Consents Sobol Inc may disclose your personal information to other persons in accordance with express or implied consents that you give during your interactions and transactions with Sobol Inc. (b) Suppliers and Service Providers Sobol Inc may disclose your personal information to its suppliers and service providers (including service providers that provide information technology, payment processing, email delivery, marketing and customer support services, product measurements, installation and maintenance) to assist Sobol Inc in the provision of information and services to you, to provide services to Sobol Inc, to assist Sobol Inc to use your personal information as set out in this Website Privacy Policy and as otherwise permitted by applicable law. (c) Partners and Other Third Parties In some circumstances, Sobol Inc may share personal information with its partners and other third parties. Sobol Inc will only disclose your personal information to a third party if we have obtained your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so. For example, if you register for an event offered by Sobol Inc that involves third parties, we may disclose information to that third party to the extent necessary to provide that event to you. (d) Law Enforcement/Legal Disclosures Sobol Inc may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. Sobol Inc may disclose your personal information to law enforcement agencies or other independent organizations if Sobol Inc reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if Sobol Inc reasonably believes the disclosure is necessary or appropriate to protect and enforce Sobol Inc’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Sobol Inc or other persons (including to detect and prevent fraud and other illegal activities, or to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of Sobol Inc’s products or services). Sobol Inc has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom Sobol Inc discloses the information in the foregoing circumstances, and the collection, use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Website Privacy Policy. (e) Business Transactions Sobol Inc may disclose your personal information in connection with a proposed or actual business transaction in which Sobol Inc is involved (e.g. a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of Sobol Inc’s business or assets), and in those circumstances Sobol Inc will require the information recipient to agree to protect the privacy of your personal information in accordance with applicable law.

6. WITHDRAWING CONSENT

When you interact with Sobol Inc, you consent to the collection, use, disclosure and retention of personal information as set out in this Website Privacy Policy. You may withdraw your consent in the following ways: Disabling Automatic Website Collection: You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of the Websites. Contacting Us: You may withdraw your consent for other purposes (such as receipt of a newsletter) by contacting us using the information set out at the end of this Website Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

7. RETENTION OF PERSONAL INFORMATION

Sobol Inc will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Website Privacy Policy and to comply with Sobol Inc’s legal obligations or enforce or protect Sobol Inc’s legal rights, or a longer period required or permitted by applicable law. Sobol Inc will delete or dispose of your personal information, or depersonalize the information, when Sobol Inc is no longer required or permitted by applicable law to retain the information for the purposes set out or referenced in this Website Privacy Policy.

8. PROTECTION OF PERSONAL INFORMATION

The privacy and security of your personal information is extremely important to us. Sobol Inc uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Sobol Inc’s possession or under Sobol Inc’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks.

9. ACCURACY AND ACCESS TO PERSONAL INFORMATION

Sobol Inc will rely on you to ensure that the personal information that you provide to Sobol Inc is as accurate, complete and up to date as necessary for the purposes for which Sobol Inc uses the personal information. You will promptly notify Sobol Inc of any changes to the personal information that you provide to Sobol Inc using the procedures made available for that purpose by Sobol Inc or by contacting Sobol Inc’s Privacy Officer using the contact information set out in Section 18 at the end of this Website Privacy Policy. You may reasonably request access to your personal information collected by Sobol Inc and information about Sobol Inc’s use, disclosure and retention of that personal information by submitting a written request to Sobol Inc’s Privacy Officer using the contact information set out in Section 18 at the end of this Website Privacy Policy. Sobol Inc may decline to process a request that is unreasonably repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted or required by applicable law.

10. NON-PERSONAL INFORMATION

Sobol Inc may use your personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Sobol Inc may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with your personal information, then Sobol Inc will treat the combined non-personal information as personal information for the purposes of this Website Privacy Policy for as long as the non-personal information is combined with your personal information.

11. OTHER WEBSITES AND BUSINESSES

This Website Privacy Policy only addresses the collection, use, disclosure and retention of personal information by Sobol Inc on the Website. The Website and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses or Sobol Inc may otherwise refer you to or provide information to you about independent businesses. Sobol Inc has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Website Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

12. SOCIAL MEDIA AND SIMILAR SITUATIONS

When you use certain aspects of the Website or other services to access or post information to social media websites, the personal information that you post or share in connection with these third party websites is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages to you. When you click on a link to a social media website, you will leave the Website and go to that social media website. Any information provided to such third party social media websites and other websites is governed by their own privacy policies, which you may read on the applicable website. You are solely responsible for the personal information that you choose to post or share in those situations. Sobol Inc has no control over, or responsibility or liability for, the collection, use, disclosure and retention of the personal information that you disclose in those situations, and this Website Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites.

13. CHILDREN AND PERSONAL INFORMATION

We do not knowingly collect personal information from children without the consent of a legal guardian. To register for a membership account with us or purchase our products and services, we must obtain the consent of your parent or legal guardian if you are under the age of majority and consent is a requirement in the jurisdiction of your residence. If we learn we have collected or received personal information from a child where parental confirmation was required, we will delete that information. If you believe we might have any information from or about a child where we should have obtained parental consent, please contact Sobol Inc’s Privacy Officer using the contact information set out in Section 18 at the end of this Website Privacy Policy.

14. CHANGES TO THIS WEBSITE PRIVACY POLICY

Sobol Inc may change this Website Privacy Policy as it applies to Sobol Inc from time to time by posting a new version of this Website Privacy Policy on the Website. Sobol Inc’s collection, use, disclosure and retention of your personal information will be governed by the version of this Website Privacy Policy in effect at that time. Your continued interactions with Sobol Inc after any change to this Website Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by Sobol Inc as set out in the changed Website Privacy Policy. Accordingly, you should check the “Last Updated” date of this Website Privacy Policy (at the top of this Website Privacy Policy) and review any changes since the last version. If we make material changes to the ways in which we collect, use, disclose and retain your personal information, we will provide you with appropriate notice.

15. NOTICES TO YOU

You consent to Sobol Inc sending you emails (to the email address you provide to Sobol Inc) regarding this Website Privacy Policy and related matters.

16. CONTACTING US

If you have any comments or questions about this Website Privacy Policy or Sobol Inc’s collection, use, disclosure and retention your personal information, please contact the Privacy Officer at: Attention: Sobol Inc. Tel: (647) 287-2724 Email: info@sobolinc.com 80 Forest Manor Road Toronto, Ontario, M2J 1M6