Section 1: Purpose of Privacy Policy

The purpose of this policy is to support Labourly™ users in understanding what personal information we, 2202245 Ontario Inc. (aka “Resonant Solutions”), collect and how it will be used when utilizing Labourly™.

This policy does not apply to information that is collected or stored by other users of Labourly™. That information is governed by the policies of the organization or of the persons for which the organization is collecting the data.

Our privacy policy is based upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.

By using Labourly™, the user expressly consents to our collection, use, disclosure and retention of the user’s information as described in this policy.

Section 2: What is Personal Information?

In this policy, “personal information” means information that identifies an individual, such as the name and date of birth of that individual, and includes non-personal information, that we link to personal information.

Section 3: What does Labourly™ Do?

Labourly™ is a smart and rapid-response platform which

1. connects businesses with qualified people in skilled trades and labour;
2. assists certified trades people in finding meaningful employment within Canada; and
3. helps track skilled trades and labour certifications so they are always up to date and people are always able to work

Section 4: What Personal information will be collected?

Labourly™ collects certain personal information of its users only to the extent required to perform the services of Labourly™. Examples of personal information that Labourly™ collects include but are not limited to:

• Contact Information. First and last name, postal address, telephone number, and email address;
• Billing Data. Including payment instrument number (such as a credit card), expiration date, and security code as necessary to process payments;
• Identity Information. Personal information, such as date of birth, postal address, copy of Identification;
• Financial Information. Credit card number, bank routing numbers, tax information, and other payment information, as applicable;
• Employment/Certification Information. Employment and education history, transcripts, work samples, and references, as necessary;
• Content Information. Any messages exchanged with other users or with the Labourly™ team; and
• Third Party Information. Social media logins for users, including, Google, Facebook, Microsoft, Twitter, LinkedIn.

Section 5: What Personal Information will Labourly™ Collect Automatically?

Labourly™ will automatically collect certain personal data when users access and use the platform. The types of information may include:

• Service use data, including data about features users use, pages visited, emails and advertisements viewed, parts of the Labourly™ platform that user views and interacts with, the time of day, etc.;
• Device data, including data about the kind of device or browser used, device’s operating system, net service provider, device’s regional and language settings, and device identifiers such as IP address;
• Information automatically through cookies or other technologies, including geographic region; and
• Location data, as well as imprecise location data.

Personal information will be retained only as long as it is necessary to fulfill the purposes for which it is collected.

Section 6: How will Personal Information be Used?

Labourly™ collects and uses information for business and commercial purposes in accordance with the practices described in this privacy policy. Business purposes for which collecting and using information may include:

• User authentication;
• Use data to connect users to enable them to connect businesses with qualified people in skilled trades and labour;
• To confirm in certifications of users;
• To track skilled trades and labour certifications so they are always up to date;
• For billing and scam prevention;
• To conduct identification and criminal background checks, if applicable and to the extent permitted by local law;
• To analyze platform usage as necessary for our interest in improving the platform;
• To contact users and deliver transaction information, clerical notices, marketing notifications, offers and communications relevant to the use of the platform;
• To provide user support;
• For troubleshooting difficulties for our interests in ensuring a safe and secure environment;
• To assist users in the solution of grievances and disputes between them; and
• To enforce the Labourly™ terms of use.

Section 7: Sharing Personal Information

Resonant Solutions may share user personal information for the reasons set out in this privacy policy or for additional purposes including:

• the purposes where users have provided consent;
• to third party financial institutions for processing payments; and
• where required or permitted to do so by law.

Resonant Solutions reserves the right to share or disclose users’ personal information when the disclosure of such information is necessary or appropriate, including to enforce rights against users or in connection with a breach by a user of this privacy policy or to prevent prohibited or illegal activities.

Section 8: Storing of Personal Information

User Billing Data and Financial Information as defined in Section 4 above will be stored by a third-party payment processor and stored on Payment Card Industry Data Security Standard (PCI DSS) servers.

Except for Billing Data and Financial Information, personal information pertaining to a user is stored on Resonant Solutions’ servers. Resonant Solutions will retain personal information pertaining to a user according to the requirements of the organization.

Resonant Solutions’ servers may not be located in the same country in which the user is located, but all of Resonant Solutions’ servers are located either in Canada or the United States.

Section 9: Security of Personal Information

Resonant Solutions takes security of user information very seriously and takes commercially reasonable physical, administrative, and technological measures to protect the information collected by Labourly™ against loss, theft and unauthorized use, disclosure, or modification. Nevertheless, no security system is fully impenetrable and therefore we cannot unequivocally guarantee the security of our systems. In the event that any personal information under our control is compromised as a result of a breach of security, we will take commercially reasonable steps to investigate the situation and where appropriate, notify those users whose information may have been compromised and take other steps, as may be required by and in accordance with any applicable laws and regulations.

Section 10: Accessing and Managing Personal Information

Through Labourly™ users may access, change, and modify their personal information. At any time, a user may cancel their account and their information will be removed and deleted entirely from the Labourly™ systems.

Section 11: Policy Changes

Resonant Solutions may change this policy from time to time and will use commercially reasonable efforts to notify all users of proposed and actual changes.

Section 12: Additional Information

Labourly™ uses cookies. A cookie is a small piece of data stored on your computer or mobile device by your web browser. Most web browser security settings can be modified to reject the use of cookies. However, if a user rejects cookies, they may not be able to access functionality of Labourly™ correctly, or at all.

Section 13: How to Contact Us

Resonant Solutions is responsible for maintaining and protecting the personal information under its control and has designated a Privacy Officer who is responsible for compliance with this privacy policy.

If you have any questions about this privacy policy or our use of the information Resonant Solutions collects from you, you may contact us by email at: [email protected] or by postal mail at 380 Wellington Street, Tower B 6th Floor, ON N5A 5B5 Attn: Privacy Officer/President.