Preceptor Business Solutions Incorporated (“Preceptor Business Solutions”) respects your privacy and is committed to protecting your personal data.

This privacy notice will inform you as to how we look after your personal data and tell you about

your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

Please also use the glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Preceptor Business Solutions collects and processes your personal data when you visit our website or when we communicate with you, as a customer, potential customer, supplier, potential supplier, for marketing purposes or as part of the performance of our existing or potential contract with you, including any data you may provide through this website when you sign up to our newsletter, purchase a product or purchase a service.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Preceptor Business Solutions, (“Company”) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, namely Preceptor Business Solutions and its subsidiaries.

In this notice, references to ‘we’ or ‘us’ mean the Company Preceptor Business Solutions and its subsidiaries.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: Preceptor Business Solutions

Name or title of data privacy manager: Data Privacy Manager

Email address: [email protected]

Postal address: Box 607 Fairview Alberta T0H 1L0

You have the right to make a complaint at any time to the Office of the Privacy Commissioner of Canada (OPC),

the federal authority responsible for overseeing privacy matters in Canada (www.priv.gc.ca).

We would, however, appreciate the chance to deal with your concerns before you approach the OPC, so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated in February 2025 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, title, job title and gender. Contact Data includes billing address, delivery address, company address, email address and telephone numbers. Financial Data includes bank account and payment card details (if you have provided those to us). Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or newsletters or other publications; request marketing to be sent to you; enter a competition, promotion or survey; request to be invited to our events or give us some feedback. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

(a) analytics providers such as Google based outside of Canada.

(b) advertising networks based inside OR outside of Canada; and

(c) search information providers based inside OR outside Canada.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside of Canada. Identity Data and Contact Data from data brokers or aggregators such as Dun and Bradstreet based outside of Canada. Identity and Contact Data from publicly availably sources such as Companies House, government websites and LinkedIn and which our subcontractors outside of Canada then aggregate together and/or manage. Identity, Contact, Financial, Transaction, Usage, Technical, Profile, Marketing and Communications Data from our principals and regional directors who have been in contact with you for the delivery or potential delivery of services, invitation to our events or subscription for our newsletter and who are based inside or outside of Canada.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data.

To register you as a new customer or supplier, to process and deliver or receive your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us, to manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey, to enable you to partake in a prize draw, competition or complete a survey, to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), to use data analytics to improve our website, products/services, marketing, customer relationships and experiences, to make suggestions and recommendations to you about goods or services that may be of interest to you, and to invite you to events and send you our newsletters.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers, newsletters or events may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if
you provided us with your details when you registered for a newsletter or event and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Preceptor Business Solutions for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4 above.

External Third Parties as set out in the Glossary Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Many of our External Third Parties are based outside of Canada, so their processing of your personal data will involve a transfer of data outside of Canada. Whenever we transfer your personal data out of Canada, we ensure a similar degree of protection is afforded to it.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Canada.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In any event, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for
six years after they cease being customers for tax purposes.

In addition, when we rely on the legitimate interest lawful basis to process your data, we will keep the data while that legitimate
interest subsists unless another lawful basis continues to apply.

In some circumstances you can ask us to delete your data:
see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Object to processing of your personal data. Request restriction of processing your personal data. Request transfer of your personal data. Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or
to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

EXTERNAL THIRD PARTIES

Service providers acting as processors based within or outside of Canada who provide IT and system administration services such as Finastra, Quickbooks, Dext, Sage, SAP, DocuSign, Calypso and Google Drive. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. Service providers who provide us with market research services or marketing services such as data research, data management, telemarketing, direct marketing and may be based in India, Mexico or the Philippines.

YOUR LEGAL RIGHTS

As a data subject, you have the following rights:

Access to Your Data: You may request access to the personal data we hold about you, commonly known as a "data subject access request." This allows you to obtain a copy of your personal data and verify that we are processing it lawfully.

Correction of Data: You may request that we correct any inaccurate or incomplete personal data we hold about you. We may need to verify the accuracy of the new data you provide before making any corrections.

Erasure of Data: You may request the deletion or removal of your personal data where there is no valid reason for us to continue processing it. This includes cases where you successfully object to processing, where we have processed your information unlawfully, or where local laws require us to erase your data. However, in some cases, we may be unable to comply with your request due to specific legal obligations, which we will communicate to you if applicable.

Objection to Processing: You may object to our processing of your personal data when we rely on a legitimate interest (or that of a third party) and you believe it affects your fundamental rights and freedoms. Additionally, you may object if we process your data for direct marketing purposes. In certain cases, we may demonstrate compelling legitimate grounds for processing that override your objection.

Restriction of Processing: You may request that we suspend the processing of your personal data under the following circumstances: If you contest the accuracy of your data and we need time to verify it. If our processing is unlawful, but you prefer restriction over erasure. If you need us to retain the data for legal claims, even if we no longer require it. If you object to our processing, but we need to verify whether we have overriding legitimate grounds to continue.

Data Portability: You may request the transfer of your personal data to yourself or a third party in a structured, commonly used, and machine-readable format. This right applies only to automated data that you provided consent for us to use or where we processed the information as part of a contract.

Withdrawal of Consent: If we rely on your consent to process your personal data, you may withdraw it at any time. However, this does not affect the legality of processing carried out before your withdrawal. If you withdraw consent, we may be unable to provide certain services or products, and we will notify you accordingly.

If you wish to exercise any of these rights, please contact
our data privacy manager using the contact details provided in this notice.