UBC CANADA INC.

PRIVACY POLICY

Last modified March 1, 2024

1. INTRODUCTION

UBC CANADA INC. and our affiliates and subsidiaries (”Company” or “We”) respect your privacy and

are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and

website users (”you”).

• Describes the types of information we may collect from you or that you may provide when you

visit the website www.draymus.com (our “Website”).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by

applicable law. We take steps to ensure that the personal information that we collect about you is

adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an

identifiable individual, which includes information that can be used on its own or with other information

to identify, contact, or locate a single person. Personal information does not include business contact

information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

The Website may include links to third-party websites, plug-ins, services, social networks, or

applications. Clicking on those links or enabling those connections may allow the third party to collect

or share data about you. If you follow a link to a third-party website or engage a third-party plugin,

please note that these third parties have their own privacy policies and we do not accept any

responsibility or liability for these policies. We do not control these third-party websites, and we

encourage you to read the privacy policy of every website you visit.

This policy DOES NOT apply to information that:

• We collect offline or through any other means, including on any other Company or third-party

website (including our affiliates and subsidiaries).

• You provide to or is collected by any third party (including our affiliates and subsidiaries),

through any application or content (including advertising) that may link to or be accessible from

the Website.

Please read this policy carefully to understand our policies and practices for collecting, processing,

and storing your information. If you do not agree with our policies and practices, your choice is not to

use our Website. By accessing or using this Website, you indicate that you understand, accept, and

consent to the practices described in this policy. This policy may change from time to time (see

Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates

that you accept and consent to those changes, so please check the policy periodically for updates.

2. INFORMATION WE COLLECT ABOUT YOU

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We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as

your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address

used to connect your computer to the Internet, user name or other similar identifier, billing and

account information, and any other identifier we may use to contact you (”personal information”).

• We provide an opportunity for any user to unsubscribe from our product or platform on an

ongoing basis by e-mailing to info@ubcmrr.com.

• Business-related information, namely information that related to your business duties, including:

• title;

• duties;

• business address;

• business email address; and

• business telephone number.

• Non-personal information, that does not directly or indirectly reveal your identity or directly relate

to an identifiable individual, such as demographic information, or statistical or aggregated

information. Statistical or aggregated data does not directly identify a specific person, but we

may derive non-personal statistical or aggregated data from personal information. For example,

we may aggregate personal information to calculate the percentage of users accessing a

specific Website feature.

• Technical information, including your login information, browser type and version, time zone

setting, browser plug-in types and versions, operating system and platform, or information about

your internet connection, the equipment you use to access our Website, and usage details.

• Non-personal details about your Website interactions, including the full Uniform Resource

Locators (URLs), clickstream to, through and from our Website (including date and time),

products you viewed or searched for, page response times, download errors, length of visits to

certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),

methods used to browse away from the page, or any phone number used to call our customer

service number.

3. HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or

corresponding with us by phone, email, or otherwise.

• User contributions. You may also provide information for us to publish or display on public

Website areas or transmit to other Website users or third parties.

• Automated technologies or interactions, as you navigate through our Website. Information

collected automatically may include usage details, IP addresses, and information collected

through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information

provided at the time of registering to use our Website and its products, subscribing to our

service, posting material, and/or requesting further services.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Details of transactions you carry out through our Website and of the fulfillment of your orders.

You may be required to provide financial information before placing an order through our

Website.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas

of the Website or transmitted to other users of the Website or third parties (collectively, “User

Contributions”). Your User Contributions are posted on and transmitted to others at your own risk.

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Additionally, we cannot control the actions of other users of the Website with whom you may choose

to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized

persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use cookies or other automatic data

collection technologies to collect certain information about your equipment, browsing actions, and

patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other

communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating

system, and browser type.

The information we collect automatically is statistical information and may include personal

information, and we may maintain it or associate it with personal information we collect in other ways,

that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver

a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to

your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.

You may refuse to accept browser cookies by activating the appropriate setting on your

browser. However, if you select this setting you may be unable to access certain parts of our

Website. Unless you have adjusted your browser setting so that it will refuse cookies, our

system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies)

to collect and store information about your preferences and navigation to, from, and on our

Website. Flash cookies are not managed by the same browser settings that are used for

browser cookies. For information about managing your privacy and security settings for Flash

cookies, see Choices About How We Use and Disclose Your Information.

• Web Beacons. Pages of our Website [and our e-mails] may contain small electronic files known

as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the

Company, for example, to count users who have visited those pages or [opened an email] and

for other related website statistics (for example, recording the popularity of certain website

content and verifying system and server integrity).

4. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal

information:

• To present our Website and its contents to you.

• To provide you with information, products, or services that you request from us.

• To fulfill the purposes for which you provided the information or that were described when it was

collected, or any other purpose for which you provide it.

• To provide you with notices about your account/subscription, including expiration and renewal

notices.

• To carry out our obligations and enforce our rights arising from any contracts with you, including

for billing and collection or to comply with legal requirements.

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• To notify you about changes to our Website or any products or services we offer or provide

though it.

• To improve our Website, products or services, marketing, or customer relationships and

experiences.

• To allow you to participate in interactive features, social media, or similar features on our

Website.

• To measure or understand the effectiveness of the advertising we serve to you and others, and

to deliver relevant advertising to you.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

5. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any

individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy

policy:

• To our subsidiaries and affiliates.

• In accordance with applicable law, to a buyer or other successor in the event of a merger,

divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of

Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar

proceeding, in which personal information held by Company about our customers and users is

among the assets transferred.

• To advertisers and advertising networks that require the information to select and serve relevant

advertisements to you and others. We do not disclose data about identifiable individuals to our

advertisers, but we may provide them with aggregate information about our users (for example,

we may inform them that 400 women between 30 and 45 have clicked on their advertisement on

a specific day). We may also use such aggregate information to help advertisers target a

specific audience (for example, men in a specific location). We may make use of the personal

information we have collected from you to enable us to display our advertisers’ advertisement to

that target audience.

• To third parties to market their products or services to you if you have consented to/not opted

out of these disclosures.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or

regulatory request, in accordance with applicable law.

• To enforce or apply our terms of use or terms of sale and other agreements, including for billing

and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of

Company, our customers, or others. This includes exchanging information with other companies

and organizations for the purposes of fraud protection and credit risk reduction.

6. TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to

contractors, service providers, and other third parties we use to support our business (such as

analytics and search engine providers that assist us with Website improvement and optimization) and

who are contractually obligated to keep personal information confidential, use it only for the purposes

for which we disclose it to them, and to process the personal information with the same standards set

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out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with

different privacy laws that may or may not be as comprehensive as Canadian law. In these

circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may

be able to obtain access to your personal information through the laws of the foreign country.

Whenever we engage a service provider, we require that its privacy and security standards adhere to

this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer,

storage, or processing.

7. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have

created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser

cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash

cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse

cookies, please note that some parts of this Website may not be accessible or may not function

properly.

• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated

or non-agent third parties for promotional purposes, you can opt-out by by sending us an email

stating your request to info@ubcmrr.com.

• Promotional Offers from the Company. If you have opted in to receive certain emails from us but

no longer wish to have your contact information used by the Company to promote our own or

third parties’ products or services, you can opt-out by sending us an email stating your request

to info@ubcmrr.com. If we have sent you a promotional email, you may unsubscribe by clicking

the unsubscribe link we have included in the email. This opt-out does not apply to information

provided to the Company as part of a product purchase, warranty registration, product service

experience, or other transactions.

• Targeted Advertising. If you do not want us to use information that we collect or that you provide

to us to deliver advertisements according to our advertisers’ target-audience preferences, you

can opt out by by sending us an email stating your request to info@ubcmrr.com.

• We do not control third parties’ collection or use of your information to serve interest-based

advertising. However, these third parties may provide you with ways to choose not to have your

information collected or used in this way. You can opt out of several third party ad servers’ and

networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising

Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also

access these websites to learn more about online behavioural advertising and how to stop

websites from placing cookies on your device. Opting out of a network does not mean you will

no longer receive online advertising. It does mean that the network from which you opted out will

no longer deliver ads tailored to your web preferences and usage patterns.

8. DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and

administrative measures designed to secure your personal information from accidental loss and from

unauthorized access, use, alteration, and disclosure. We store all information you provide to us

behind firewalls on our secure servers.

The safety and security of your information also depends on you. Where we have given you (or where

you have chosen) a password for access to certain parts of our Website, you are responsible for

keeping this password confidential. We ask you not to share your password with anyone.

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Unfortunately, the transmission of information via the Internet is not completely secure. Although we

do our best to protect your personal information, we cannot guarantee the security of your personal

information transmitted to our Website. Any transmission of personal information is at your own risk.

We are not responsible for circumvention of any privacy settings or security measures contained on

the Website.

9. DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your

personal information for as long as necessary to fulfill the purposes we collected it for, including for

the purposes of satisfying any legal, accounting, or reporting requirements. Under some

circumstances we may anonymize your personal information so that it can no longer be associated

with you. We reserve the right to use such anonymous and de-identified data for any legitimate

business purpose without further notice to you or your consent.

10. CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide

any information to or on the Website. We do not knowingly collect personal information from children

under 13. If you are under 13, do not use or provide any information on this Website or on or through

any of its features/register on the Website, make any purchases through the Website, use any of the

interactive or public comment features of this Website, or provide any information about yourself to

us, including your name, address, telephone number, email address, or any screen name or user

name you may use. If we learn we have collected or received personal information from a child under

13 without verification of parental consent, we will delete that information. If you believe we might

have any information from or about a child under 13, please contact us at info@ubcmrr.com.

11. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep

us informed if your personal information changes. By law you have the right to request access to and

to correct the personal information that we hold about you.

We may request specific information from you to help us confirm your identity and your right to

access, and to provide you with the personal information that we hold about you or make your

requested changes. Applicable law may allow or require us to refuse to provide you with access to

some or all of the personal information that we hold about you, or we may have destroyed, erased, or

made your personal information anonymous in accordance with our record retention obligations and

practices. If we cannot provide you with access to your personal information, we will inform you of the

reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable

privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.

• Information that is part of a formal dispute resolution process.

• Information that is about another individual that would reveal their personal information or

confidential commercial information.

• Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may

contact info@ubcmrr.com.

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12. WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal

information, you may have the legal right to withdraw your consent under certain circumstances. To

withdraw your consent, if applicable, contact us at info@ubcmrr.com. Please note that if you withdraw

your consent we may not be able to provide you with a particular product or service. We will explain

the impact to you at the time to help you with your decision.

13. CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material

changes to how we treat our users’ personal information, we will notify you through a notice on the

Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for

ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically

visiting our Website and this privacy policy to check for any changes.

14. CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy

practices. Please contact us at info@ubcmrr.com.

We have procedures in place to receive and respond to complaints or inquiries about our handling of

personal information, our compliance with this policy, and with applicable privacy laws. To discuss our

compliance with this policy please contact us at info@ubcmrr.com.