Your privacy is important to Knight Labs Inc, including its subsidiaries collectively referred to as Knightlabs. This Privacy Policy applies to our operations in Canada and the United States and describes our practices with respect to the collection, use and disclosure of personal information, as well as any rights you may have with respect to your personal information (as defined in the Definition of “Personal Information” section).

If you are a California consumer, you may have additional rights under the California Consumer Protection Act (“CCPA”), as detailed in the California Consumers section.

If you are in the European Union, you may have additional rights under the General Data Protection Regulation (“GDPR”), as detailed in General Data Protection Regulation section.

1. Scope and Application

This Privacy Policy relates to the personal information collected by Knightlabs. This Privacy Policy applies whenever you interact with us, including when you visit one of our websites or participate in market research conducted by Knightlabs. If you are a job candidate, please review our Privacy Notice fo8-r Candidates.

2. Definition of “Personal Information”

“Personal information” is any information that identifies, or could be reasonably associated with, an individual and their household (collectively, “individual” or “you”). This may include, for example, your name, contact information, and email-address. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

3. What Personal Information Do We Collect?

“Personal information” is any information that identifies, or could be reasonably associated with, an individual and their household (collectively, “individual” or “you”). This may include, for example, your name, contact information, and email-address. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

Personal information we collect may include:

Identifiers and contact information, such as your name, email, telephone number, Internet Protocol (IP) address (if it can identify you as an individual);

Demographic data, such as date of birth, age, gender;

Financial information may be collected in order to process honoraria payments or for legal required forms related to such payments (such as name and bank information);

Browsing activity on our websites, such as page and offers viewed, opt-out preferences, email bounce backs, click- throughs, content on social media, and IP addresses, if it can identify you as an individual (as further detailed in the How we Collect Personal Information section); and

Any other information you provide to us (as further detailed in the How we Collect Personal Information section).

4. How we Collect Personal Information

We collect personal information in a variety of ways, including: directly from you, from other sources, through online technologies (such as when you are interacting with us through our websites) and from third-party social networks.

More specifically, we collect personal information in the following ways:

a. Directly From You

We may collect personal information directly from you by email, over the telephone, through our website contact form or in any other direct manner, for instance when you participate in a survey, interview, or other market research.

b. From Business Partners

Occasionally, we may receive personal information from business partners with whom we provide services. We may also receive your personal information from other sources with your consent or when authorized by law.

c. Through Online Technologies

We may collect certain types of information electronically when you interact with our websites, emails, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies or single pixel gifs or analytics engines. This information helps us understand what actions you take on our websites and allows them to work correctly.

To learn more about the privacy choices available to you, please visit How Can You Change Your Privacy Choices?

The technologies we use include:

Cookies, which are small text files that are saved on your computer when you visit a website so that information can saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our websites.

Web beacons, and single pixel gifs, which are small image files that have information about you, such as your IP address, that can be downloaded when you visit a website or open an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.

Web analytics tools such as Google Analytics, which uses cookies to analyze your use of our websites, to create reports about visitor and user activities for us and to provide further services associated with the use of our websites and apps.

Analytics engines, which pull usage data from multiple sources and help manage and collect this data to gain insights into our customer needs and preferences.

Tools that help protect against inappropriate uses, such as Google Invisible reCAPTCHA, which collects hardware and software information, such as device and application data and the results of integrity checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis.

You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our websites. To learn more about the privacy choices available to you, please visit How Can You Change Your Privacy Choices?

d. Third-Party Social Networks

We may collect your personal information if you interact with us through our social media pages and accounts (e.g. Twitter, LinkedIn). For instance, we collect the personal information the respective social media platforms allow us to collect from our followers. We may also collect any content you upload to our social network pages (including photos or videos).

In addition, third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to LinkedIn) on our websites and apps may use cookies to gather information on your use of the websites and apps. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. Knightlabs encourages you to review the privacy policies of third parties as well. Third parties involved may use these tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of our websites and apps to any other personal information they may have collected on you. We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content Knightlabs promotes.

5. How we Use Personal Information

We may use all categories of personal information detailed in section 3 to provide you with our services, to manage our business operations and make hiring decisions, conduct market research and as otherwise permitted or required by law.

Learn more about how we use your personal information for: providing services, managing our business, marketing and advertising, and conducting market research and data analytics. We use your personal information for the following purposes:

a. Providing our Services

We use your personal information in order to provide our services, for instance responding to your inquiries.

b. Managing Our Businesses

We use your personal information to manage our business, for instance:Maintaining our programs, products and services;Managing and facilitating the use of our websites, which may include using cookies and other similar technology (as further detailed in the How we Collect Personal Information section);Protecting us and third parties from errors and fraud; andMeeting our contractual, legal and regulatory obligations.

c. Marketing and Advertising

We use your personal information to market our stores, brands, programs, products, services, special offers, promotions, contests or events, and those of third parties who may sell their products within our stores, that we believe may be of interest to you. We may do this in a variety of ways:By communicating with you by email and social media; andBy delivering online advertisements relevant for you.If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. For more information on managing your marketing preferences, see How Can You Change Your Privacy Choices?

d. Conducting Market Research and Data Analytics

We may use your personal information in order to conduct market research and data analytics by tracking and analyzing current or previously collected information for the following purposes:To learn more about consumer interests, data trends, behaviors, and pain points;Measure the effectiveness of our marketing; andWe may use your personal information to process an honoraria payment and provide you with legal required forms to such paymentsWe use the personal information we collect to conduct research and analysis that supports our business. In doing so we may generate reports that contain data about our clients’ business. When possible, we will use your information in an aggregated and/or de-identified format. We only disclose such reports to third parties after removing any information that identifies individuals or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify individuals.

6. How we Share Personal Information

We may share your personal information within Knightlabs and companies within our corporate group or with our third party business partners (companies with which we provide services) and service providers (companies operating on our behalf) for the purposes described in this Privacy Policy and in accordance with applicable law. We will not share your personal information with any non affiliated third party without your prior consent, other than as provided in this Privacy Policy or as otherwise authorized by applicable law. We do not sell your personal information to any organization or person; the only exception to this would be if we sell or transfer any part of our business. If you are a California resident, please review the California consumers section for more information on our practices specific to the law applicable to you.

The de-identified data that Knightlabs collects may also be shared in aggregate format only with our clients funding the research. We do not share with our clients the Personal Information of our market research survey or interview participants without consent of the individuals involved, subject to the terms of this Policy.

Learn more about how we may share personal information: within Knightlabs, with third party service providers, in the course of a sale or transfer of business or other transaction, for other permitted reasons, and with your consent.

a. Within the Knightlabs Group

Knightlabs affiliates and subsidiaries in Canada, the United States and internationally may share personal information with each other and use it for the purposes described in this Privacy Policy. This allows Knightlabs and each entity within the group to comply with applicable laws, regulations and requirements and ensures that your information is consistent, accurate and up-to-date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with Knightlabs through easier access to your information within the group.

b. Service Providers

In the course of providing our services we may share all categories of personal information detailed in section What Personal Information do we Collect? with third party service providers who perform services on our behalf. These service providers help us operate our business, market research, and advertising and marketing. They provide services to us, such as sending emails, data hosting, providing advertisements, market research. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and require that those third parties adhere to confidentiality as well as security procedures and protections.

For example:

We use service providers to perform market research on our behalf, where personal information may be collected and/or stored.

We use service providers for exporting and storing de-identified and anonymized market research data.

We use service providers for processing honorarium payments to market research participants, that will have access to participants’ personal information as required to provide their services to Knightlabs.

c. Sale or Transfer of Business or Other Transaction

We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of our business (including the proceedings of insolvency or bankruptcy). In the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information, in compliance with applicable laws.

d. Other Permitted Reasons

Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect our group of companies, our employees, our customers, or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.

e. With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of our group of companies, in accordance with applicable laws.

7. How we Manage Consent

By subscribing to our services, participating in our market research and/or submitting information to us in connection with using our services or market research, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific service or market research you participated in. You may be entitled under applicable law to withdraw your consent (except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us).

For information on how to manage your privacy preferences, please see How Can You Change Your Privacy Choices? If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the programs, products, services, contests, promotions, events or information that you requested or that could be offered to you.

8. How Can You Change Your Privacy Choices?

We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: signing up for market research, contacting us directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.

Learn more about how to change your privacy choices when you register or by contacting us directly, and using third party unsubscribe functionality.

a. When Register or by Contacting Us Directly

You may opt in to receiving email marketing communications at the time that you register for our services or sign up for market research we are conducting.

You may opt out of:

Receiving email marketing communications, by clicking “unsubscribe” within any marketing email you following the opt-out instructions provided; and

Receiving interest-based advertisements by changing your browser settings on your device, and/or using third party unsubscribe functionality (e.g., via Google or LinkedIn) to change your preferences within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites.

Please note the following regarding withdrawal of consent or changes in your privacy preferences

Even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, service or reminder notices). We may also need to contact you with questions or information regarding your customer service inquiries.

b. Using Third Party Unsubscribe Functionality

We may use third parties (e.g., social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our websites and apps. You can manage your privacy preferences with respect to certain third parties, such as Google, by using the unsubscribe functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites and apps.

For example, Google Analytics uses cookies to analyze your browsing behaviour on our websites. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser. If you would like to opt out of Google’s ad settings, please go to www.google.com/settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout.

We also may embed links to other websites, including social media websites, on our websites and apps. For more information about social media plug-in protocols, such as “Like” buttons on Twitter, LinkedIn and their impact on your privacy rights, please visit the appropriate social media help centre (e.g., LinkedIn Help Center at https://www.linkedin.com/help/linkedin).

9. How we Store and Safeguard Personal Information

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. Your personal information may be stored in foreign jurisdictions, in which case it will be subject to foreign laws. We will store your personal information in accordance with our retention policies or as otherwise required or permitted by law.

Learn more about how we protect personal information, where we keep personal information and cross-border transfers and how long we keep personal information.

a. How we Protect Personal Information

We employ organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored.

b. Where we Keep Personal Information and Cross-border Transfers

We may share personal information within the Knightlabs group of companies, including in Canada, the United States and the European Union. Some of our service providers may also access, process or store your personal information outside of the country where we are located and where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

c. How Long we Keep Personal Information

We will store your personal information in accordance with our retention policies or as otherwise required or permitted by law, after which your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

10. Accessing and Correcting Your Personal Information

You may have the right to access and rectify the personal information we hold about you under the law applicable in the jurisdiction where you reside. In this case, upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting the applicable Privacy Office as described in the “Who Can You Contact With Privacy Questions?” section. If you are residing in California, please refer to the California Consumers section for more information on how to exercise your rights

11. Childrens Privacy

We do not knowingly request or collect personal information from children under 13 years of age without prior verifiable consent of his or her parent or legal guardian and complying with any other legal requirements. If we become aware that we have unknowingly collected personal information about a child without verifiable parental or legal guardian consent, we will delete this information from our records or take reasonable steps to de-identify the information.

12. California Consumers

This section describes the rights you have under the CCPA if you are a consumer residing in California.

The categories of personal information we collect about California consumers (and that we may have collected in the last twelve months) and the purposes for which we collect this personal information are listed, respectively, in sections What Personal Information do we Collect?, How we Collect Personal Information and How we Use Personal Information of this Privacy Policy. We do not sell your personal information. We may disclose all personal information we collect for business purposes to service providers (and may have done so in the last twelve months), as further detailed in the How we Share Personal Information section of this Privacy Policy.

a. Request to Know about the Personal Information we have Collected and Disclosed

Once every 12 months, you may submit a verifiable request that we disclose the following information to you:

The categories or specific pieces of personal information that we have collected about you in the last 12 months, as well as the sources from which personal informal is collected, the business and commercial purposes for collecting it, the categories of third parties with whom we have shared it; andThe categories of personal information about you that we have disclosed for a business purpose in the last 12 months.

b. Right to Request that we Delete your Personal Information

You may submit a verifiable request that we delete any personal information that we have collected about you, subject to the exceptions provided by the CCPA.

c. Methods for Exercising your Rights and Verification of your Identity

You may exercise these rights using one of the methods detailed in the “Who Can You Contact With Privacy Questions?” section.

In accordance with applicable law, we must take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we may verify your identity through existing authentication practices for the account, such as you username and password. We may also verify your identity by matching two or three data points of identifying information you provide to data points we already maintain about you and have determined to be reliable for the purposes of verification, depending on the nature of your request.

You can authorize an agent to exercise any of these rights on your behalf, but we will take additional measures to verify the legal authority of your agent.

d. Non-Discrimination Right

We will not, because you have exercised any of the rights detailed in this section 12, deny you any goods or services, charge different prices or rates for goods or services, or provide you with a different level or quality of goods or services.

13. General Data Protection Regulation

This section describes the rights you have under the GDPR if you are a consumer residing in Europe.

The categories of personal information we collect about European consumers (and that we may have collected in the last twelve months) and the purposes for which we collect this personal information are listed, respectively, in sections What Personal Information do we Collect?, How we Collect Personal Information and How we Use Personal Information of this Privacy Policy. We do not sell your personal information. We may disclose all personal information we collect for business purposes to service providers (and may have done so in the last twelve months), as further detailed in the How we Share Personal Information section of this Privacy Policy. Information on transferring international personal data is listed in section Where we Keep Personal Information and Cross-border Transfers.

Should you wish to report a complaint or if you feel that Knightlabs has not addressed your concern, you may contact your local European Data Protection Authority: https://edpb.europa.eu/about-edpb/board/members_en.

Under the GDPR, individuals are entitled to the following protection rights:

The right to access. Request from Knightlabs to access your personal data;

The right to erasure. The right Request that Knightlabs erase personal data under certain conditions;

The right to rectification. Request that Knightlabs correct any information that is believed to be inaccurate, or complete any information that is believed to be incomplete;

The right to restrict processing. Request that Knightlabs restrict the processing of personal data, under certain conditions;

The right to object to processing. Object to the processing of your personal data, under certain conditions;

The right to data portability. Request that Knightlabs transfer the data that has been collected to the data subject or another organization, under certain conditions; and

The right to withdraw informed consent. Request that informed consent be withdrawn at any time during the research process

14. Changes To Our Privacy Policy

We may make changes to this Privacy Policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our websites. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to participate in our market research, and/or use our services after the modified version of the Privacy Policy has been posted or you have been informed of such update, you are accepting the changes to the Privacy Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated.

15. Who Can You Contact With Privacy Questions?

If you have any questions about how we handle your personal information, please contact us as indicated below. If you have a service, or are participating in market research that is offered by us with a third party, the third party may hold your personal information. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.

Please contact Brian Knight, President, Knightlabs at brian@klabs.com or by mail:

If you are in the U.S.: 1800 North Vine Street, Los Angeles, CA 90028

If you are in Canada: 150 King Street West, Suite 200 Toronto, ON M5H1J9