Privacy Policy

NEKSA COACHING TECHNOLOGIES LTD. PRIVACY POLICY

Welcome to https://www.NEKSA.com (together with all subdomains, the “Website”). The Website is owned and operated by NEKSA Coaching Technologies Ltd. (the “Company,” “we,” “us,” “our”). This privacy policy (this “Policy”) outlines the privacy compliance by the Company when in custody of personal information, and applies to all individuals who access the Website. You may obtain this Policy and any related information from the Website or upon request by contacting our Chief Privacy Officer.

Personal information is any information about an identifiable individual, but does not include the name, business title, business address, or telephone number of employees of organizations (“Personal Information”). The protection of your Personal Information is very important to us.

1. YOUR ACCEPTANCE OF THE WEBSITE PRIVACY POLICY

1.1 Privacy Policy

This Policy constitutes a legal agreement and is entered into, by, and between you and the Company. You should read this Policy in conjunction with the Website Terms and Conditions www.NEKSA.com/pages/terms as both of these documents govern your use of and access to the Website.

1.2 Acceptance

By accessing or using the Website, or by purchasing any goods or services from us, you accept and agree to be bound by and comply with this Policy. If you are using the Website on behalf of any person or entity, you represent and warrant that you are authorized to accept the terms and conditions of this Policy on such person or entity’s behalf. If you do not agree to the Website Terms and Conditions or this Policy, you must not access or use the Website.

1.3 Modifications

We reserve the right, in our sole discretion, to revise and update this Policy from time to time. Any and all such modifications are effective immediately upon posting and apply to all access to and continued use of the Website. You should periodically review this Policy in order to be aware of any such modifications. Your continued use of the Website constitutes your acceptance of such modifications

2. OUR PRIVACY PRINCIPLES

We are committed to maintaining the accuracy, confidentiality, and security of Personal Information that we collect from you. As part of this commitment, we have adopted the following principles:

2.1 Accountability

We are responsible for protecting the Personal Information that we collect, and we have designated a Chief Privacy Officer to be the primary individual accountable for compliance with these principles. Our Chief Privacy Officer can be contacted as follows

E-mail: [email protected]

Address: 585-1122 Mainland St, Vancouver, BC, Canada - 2 -

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2.2 Consent

Subject to applicable law and regulations and applicable legal exceptions, we will make reasonable efforts to identify the purposes for which we collect, use or disclose your Personal Information before or at the time such Personal Information is collected, used or disclosed. In some circumstances, applicable law and regulations permit us to collect, use or disclose Personal information without consent, or consent for collection, use or disclosure is implied to have been given.

2.3 Identifying Purposes

If you wish to access the Website or to receive career coaching services, career development services, or other goods or services from us, you may be required to register for a user account by providing us with information about yourself or the person or entity on whose behalf you are registering. You may also provide us with your Personal Information by completing your user profile. The primary purposes for which we collect, use or disclose Personal Information are to:

(a) manage and promote the activities and operations of the Company;

(b) provide career coaching, career development, or other goods or services;

(c) where appropriate, provide Personal Information to third parties including, without limitation, third party suppliers with whom you or we choose to deal for the purpose of providing or receiving career coaching, career development, or other goods or services, as applicable;

(d) better understand the needs of our users and customers, including, without limitation through periodic surveys; and

(e) comply with applicable legal and regulatory requirements.

2.4 Limiting Collection

In general, we will make efforts to limit the amount and type of Personal Information that we collect from you to that which is necessary for the purposes identified by us.

2.5 Limiting Use, Disclosure, and Retention

In general, we will only use or disclose your Personal Information for the purposes for which such information was collected, unless you have otherwise consented or when such use or disclosure is required or permitted by applicable law.

We will retain Personal Information only as long as necessary for the fulfillment of the purposes for which such information was collected, subject to legal retention requirements and best practices. When we dispose of Personal Information, such disposal is done with appropriate care to prevent unauthorized access to same.

2.6 Accuracy and Correction

It is important to us that the Personal Information which we collect is accurate and complete. However, we do not routinely update Personal Information in our possession or control, and we rely on you to keep your Personal Information as accurate, complete, and up-to-date as may be necessary to fulfill the purposes for which such information is to be used. - 3 -

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If an individual successfully demonstrates to us that their Personal Information is inaccurate, incomplete, or not up-to-date in our records, we will revise our records accordingly and, where relevant, make reasonable efforts to advise relevant third parties to whom that information has been disclosed. Please direct all requests for revision of Personal Information to our Chief Privacy Officer.

2.7 Security and Safeguards

We maintain appropriate security safeguards and procedures to protect Personal Information against loss, theft and unauthorized access. The nature of such safeguards and procedures varies with the nature and sensitivity of such information. These measures include physical measures, such as locked storage, and organizational measures such as need-to-know access policies, and technological measures.

2.8 Access

An individual has the right, upon submitting a request to us, to be informed of the existence, use and disclosure of their Personal information under our control, subject to certain exceptions set out in applicable law. Please direct your requests for access to your Personal Information to our Chief Privacy Officer. We may request that you provide us with sufficient detail and information to verify your identity and to enable us to adequately respond to your request. We will attempt to respond to requests promptly and, in any event, within such timelines as may be stipulated by applicable law. As permitted by applicable law, in some circumstances, we may require you to pay certain charges with respect to a request.

2.9 Challenging Compliance and Dispute Resolution

Any complaints, disputes, or other feedback concerning our privacy practices, procedures, and this Policy should be submitted directly to our Chief Privacy Officer. If there is a dispute regarding your Personal Information or this Policy, you agree to use reasonable efforts to resolve such dispute with us informally and to consult and negotiate with us in good faith to reach a fair and equitable solution. If the dispute is not resolved through an informal process within 30 days, either you or the Company may consult the Information and Privacy Commissioner of British Columbia:

Website: www.oipc.bc.ca

Phone number: (250) 387-5629

E-mail: [email protected]

3. WHAT INFORMATION DO WE COLLECT?

3.1 Account Information

The Company does not, as a matter of course, gather any of your Personal Information while you are using the Website. However, if you voluntarily complete an online form or register for a user account, we may collect certain Personal Information including, without limitation, your full legal name, your address, your phone number and your e-mail, your credit card and billing information, your demographic information, and other information including, without limitation, learning preferences, course content preferences, and level of education. We will only use Personal Information and other information which we collect for the stated purpose or for other purposes required or permitted by applicable law. - 4 -

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3.2 Statistical and Analytical Information

The Company may collect certain information, including through the use of third party analytics programs, to:

(a) help us understand how our users use the Website;

(b) compile statistics, reports and analyses;

(d) understand trends in Website usage.

This information may include IP addresses, browser and computer or mobile device type, date, time and location of Website access in accordance with your browser settings, and the pages and content viewed or downloaded. While some of this information does not specifically identify individuals, the extent of potential identification may depend on protocols maintained by the internet service provider. We do not use this information to specifically identify individuals unless required to do so by applicable law.

3.3 Cookies

Cookies allow a server to recall previous requests, registration, or IP addresses to analyze website use patterns. We use cookies to better understand how our Website is used, and to improve Website performance and presentation. By using this Website, you consent to the use of cookies. You may set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You may also set your browser to turn off cookies. If you do, however, some areas of the Website may not function adequately.

Advertisements displayed on our website may also contain cookies provided by third parties. We do not have any control over or responsibility or liability for the use or disclosure of information collected through third party cookies.

3.4 User Submissions

Unless we indicate otherwise, this Policy does not apply to, and we do not collect, any Personal Information or other submissions which you make to the Website through functionalities such as forums, bulletin boards, or other messaging systems. Other users and third parties may be able to identify you or associate you with your account if you submit Personal Information through such functionalities. The Company is not responsible for any Personal Information you submit through these functionalities.

4. COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

4.1 Promotional Material

Occasionally, we may wish to feature some of your Personal Information and User Submissions (as defined in our Website Terms and Conditions) which you have voluntarily provided to us or submitted on or through our Website including, without limitation, images or social media commentary, in our promotional material.

4.2 Service Providers and Third Party Suppliers

In the course of our operations, we may transfer Personal Information to third party service providers, some of whom may be located outside of Canada. This means that - 5 -

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your Personal information may become subject to the laws of the jurisdiction in which the third party service provider or its storage facilities are located.

For example, our Website and career coaching and career development courses are hosted by Thinkific Labs Inc. (“Thinkific”). Thinkific stores your data on a secure server protected by a firewall. In addition, if you make a purchase from us, we may use third party payment processors such as Stripe or PayPal. In all such circumstances, we use contractual and other means to ensure that such information is used and disclosed only for the limited purpose of the service provider’s engagement with us, and that reasonable and comparable safeguards are in place while the information is in the custody of the third party service provider.

Certain third party service providers, such as payment gateways and other payment transaction processors, have their own terms of service and privacy policies with respect to the Personal Information that we are required to provide to them for your purchase-related transactions. We recommend that you read these terms of service and privacy policies to understand the manner in which your Personal Information will be handled by these third party service providers.

4.3 Anti-Spam Practices and Marketing Arrangements

We only use your e-mail address as permitted under applicable anti-spam legislation. If you have registered a user account with us or purchased or used our goods or services, we may use your Personal Information for selected direct marketing purposes, to administer your user account, or to send you course registration, course content or other related updates and information. You may opt out of receiving these communications by clicking the “unsubscribe” link in any such communication or by contacting the Chief Privacy officer.

We may engage third party vendors, including Google, to display our promotional material on various websites. Any service provider or vendor that we use is prohibited from using Personal Information which we provide to them for any purpose, other than providing the remarketing services requested by us. Such third parties may use cookies, web beacons and other similar technologies to collect or receive information from the Website and elsewhere on the internet, and use that information to provide measurement services and target ads. You may choose to opt out of certain directed remarketing conducted by our third party vendors and service providers by visiting the third party’s settings and opt-out pages, such as Google Ads Settings. For additional information, please contact our Chief Privacy Officer.

4.4 Your Consent to Use of Personal Information

Providing us with your Personal information is always your choice. When you register for a user account or complete your user profile, you consent to our collection, use, and disclosure of the Personal Information you provide to appropriate third parties for purposes in this Policy or otherwise identified by us, and authorize us to use and retain such Personal Information as long as may be required for such purposes, subject always to applicable law. Your consent remains valid even after the termination of our relationship with you, unless you provide us with written notice that such consent is withdrawn.

If you withdraw or do not provide us with your consent to our collection, use, and disclosure of your Personal Information, you may limit or prevent us from being able to provide you with functionalities, goods or services desired. - 6 -

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5. SHARING YOUR PERSONAL INFORMATION WITH OTHERS

5.1 General Non-Disclosure

Except as provided in this Policy or otherwise indicated by the Company, the Company does not sell, rent, trade, license, or otherwise disclose any Personal Information we collect to third parties.

5.2 Internal Disclosure

We may disclose collected Personal Information to our affiliates, successors, business partners, and other service providers or agents who perform various functions for us. As the Company continues to develop and grow, we may buy, merge, or sell parts of our business. Personal Information may be an asset that is transferred in such a transaction.

5.3 Risk

Despite our best efforts to ensure that third parties will not access or obtain collected Personal Information in contravention of this Policy, we cannot and do not guarantee complete confidentiality and security of your Personal Information, as communication via the internet is subject to interception, loss, or alteration. You acknowledge and agree that any information you communicate to us over the internet is at your own risk.