Privacy Policy

Updated as of: August 4, 2022 Centro Commerce Inc. and its affiliates (collectively, “we”, “our” or “us”) recognize the importance ofprivacy. The purpose of this privacy statement (“Privacy Statement”) is to inform you about our privacy practices, including how we collect, use and disclose your Personal Information. This Privacy Statement applies to all of our operations in Canada or operations in connection with Canada, unless we have provided you with a separate privacy statement for a particular product, service or activity.

Privacy Statement Updates

This Privacy Statement is current as of the “updated” date which appears at the top of this page. We maymake changes to this Privacy Statement from time to time, which will become immediately effective when published in a revised Privacy Statement posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means.

Please review this Privacy Statement carefully. By submitting your Personal Information to us, byregistering for or using any of the services we offer, by using our website, or by voluntarily interactingwith us, you consent to our collecting, using and disclosing your Personal Information as set out in thisPrivacy Statement, as revised from time to time.

What’s in this Privacy Statement?

This Privacy Policy covers the following topics:
• Meaning of Personal Information
• Your Consent to Collection, Use and Disclosure
• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Opting Out of Communications
• Retention of Personal Information
• Information Security
• Accessing and Updating Your Personal Information
• Third Party Websites and Services
• How to Contact Us

Meaning of Personal Information

"Personal Information" means information about an identifiable individual as described under Canadian privacy laws, which may include, but is not limited to, your name, e-mail address and telephone number. Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work e-mail address. Personal Information also does not include information that has been anonymized or aggregated in such a way thatthere is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

Your Consent to Collection, Use and Disclosure

We collect, use and disclose your Personal Information with your consent or as permitted or required by Canadian privacy laws. How we obtain your consent may be express or implied and will depend on the circumstances, as well as the sensitivity of the information collected. If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of that Personal Information as outlined in this Privacy Statement.

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us using the contact information in the “How to Contact Us” section below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products orservices.

Personal Information We Collect

Products and Services. For individuals located in Canada, we may collect information from you or from your use of our products or services.

• We collect Personal Information that you submit through your use of our products or services, such as your company name, your name, company e-mail address, business, role and/or title and company billing address, and other contact information.
• We may automatically collect usage data that is identifiable with you when you use our products and services.
• We collect information about your business that you submit through your use of our products or services or through the online e-commerce platforms, vendors and warehouses you may link toour products or services, including, but not limited to, sales and order information, inventory levels, supplier and vendor information, order fulfillment information, and other information related to your supply chain.
• We will aggregate and anonymize certain data collected in connection with your use of our products and services, which may be stored and used separately from the data and Personal Information referred to above.

Website. For individuals located in Canada who visit our website located at www.centrocommerce.comor any of our related websites (collectively, “our website”), we may collect information from you or fromyour activities on the site.

• Like most websites and other Internet services, we may collect certain technical and device information about your use of our website, which may include your Internet protocol address, information about your device, browser and operating system, and the date and time of your visit, as well as the region or general location where your device is accessing the internet, and other information about the usage of our website, including a history of the pages you view.
• We may also use “cookies” or enlist third party services which use cookies to track your preferences and activities on our website. Cookies may store a variety of information, including the number of times that you access a site, your language preferences and the number of times that you view a particular page or other item on the site.
• If you enter information in the “Contact Us” section, we collect your name, email address, company you represent, country, business contact information, company size, revenue of company and details of your inquiry to enable us to respond to a general/business inquiry made by you on behalf of your company.
• Other Interactions. For individuals located in Canada who otherwise interact with us, whether inperson, by phone or email, through social media or otherwise, including individuals who might be interested in acquiring our products or services, who sign-up to receive newsletters or other communications, or who respond to surveys and questionnaires, who may interact with us attrade shows or other in-person events, we may collect information that you provide to us during these interactions. This information may include your company name, your name, business e-mail address and other contact information.

How We Use Your Personal Information

We may use your Personal Information for purposes such as:
• Providing you with our products and services and supporting your use of our products andservices;
• Contacting you relating to our products and services;
• Monitoring the usage of our products and services to support their proper functioning and further improvement;
• Analyzing the needs and activities of our customers to help us better serve them;
• Generating de-identified and/or anonymized data to conduct research, analysis and general insights related to our industry, business, products and services;
• Responding to inquiries and other requests;
• Collecting opinions and comments about our products and services;
• Developing marketing materials;
• Providing you with information that we think may interest you, including information about ourproducts and services;
• Investigating legal claims; and
• For such other purposes as you may otherwise consent from time to time. We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable Canadian privacy laws. We will process collect, use, and disclose information received through our website only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with you and your company, and to enhance user experience by analyzing your use of our website.

We do not use the information we collect to advertise third party products and services or targeted advertising of our products and services across third party websites or service offerings.

How We Share Your Personal Information

We rely on third party services providers to perform a variety of services on our behalf, such as ecommerce providers (including Shopify), payment card processors, telephone and technical support providers, data storage, hosting and processing service providers, and research and analytics providers.

If we provide information to service providers, we require that the service providers keep your Personal Information secure, and only handle it for limited purposes. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that thirdparty and the purpose for the disclosure, and obtain your consent.

Not withstanding the above, we may share information that does not identify you or your company(including information that has been aggregated or de-identified) with third parties except as prohibitedby applicable law.

Opting Out of Communications

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by Canadian privacy laws.

If your Personal Information was collected in connection with your use of our products and services, upon request by you within thirty (30) days after the effective date of termination or expiration of the applicable term for such product or service, we will make any Personal Information related to those products or services for which such term has expired or been terminated, available to you. After such 30-day period, we will have no obligation to maintain, provide or make available such Personal Information, and we may thereafter delete or destroy all copies of the Personal Information in our systems or otherwise in its possession or control, unless legally prohibited from doing so.

International Transfer and Storage of Information

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party service providers, Amazon Web Services, in Canada and the United States. Other jurisdictions may have different data protection rules than Canada. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located. Those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, contact our Privacy Information Officer at the email address below.

Information Security

We have implemented physical, organizational, contractual and technological security measures with aview to protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reasonto believe that your interaction with us is no longer secure (for example, if you feel that the security ofany information that you provided to us has been compromised), please contact us immediately using thecontact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

We expect you, from time to time, to supply us with updates to your Personal Information, when required. We will not routinely update your Personal Information, unless such a process is necessary.

You may make a written request to review any Personal Information about you that we have collected, used or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws. You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct yourPersonal Information. Any such identifying information will be used only for this purpose.

Third Party Websites and Services

This Privacy Statement does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Children's Information

Our products and services are not intended for children under the age of 16, and we do not knowingly collect Personal Information from children under the age of 16.  Children under the age of 16 should not use our products and services and should not provide us with their Personal Information.

How to Contact Us

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be sent to our Privacy Officer as follows:

Address: Attention: Privacy Officer 66 The Westway, Toronto, ON M9P 2B2

By e-mail:

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