Privacy Policy

Watt Share, Inc., its subsidiaries, related companies, and/or affiliates ("Watt Share," "we," "us," or "our") offer marketing services ("Marketing Services") regarding the location and potential availability of certain parking spots ("Parking Spots") to users ("Users") through our website, www.wattshare.ca and associated software application(s) ("Apps") (collectively, the "Site"). In so doing, we market the Parking Spots on the Site and facilitate the reservation ("Reservations") of Parking Spots between Users of the Site and owners, lessors, managers or operators of Parking Spots ("Licensors") (collectively, Users and Licensors of the Site may be referred to as "you" or "your").

Watt Share values individual privacy rights and wants to allow you to understand the kind of information that we collect and how you can control our collection, use, and sharing of your information, including Personal Information (defined below), as detailed in this privacy policy ("Privacy Policy"). By using the Marketing Services or the Site, you agree that you have read and understood the Privacy Policy. The Privacy Policy describes:

• the information that Watt Share collects from you;
• how that information is used, transferred, and disclosed by Watt Share; and
• the rights and options available to you.

This Privacy Policy is incorporated into the Watt Share Terms and Conditions. It does not apply to workforce-related Personal Information collected from job applicants.

We collect, transmit, and store information that you provide directly to us through (i) use of the Site or Apps, (ii) creation or modification of an account, (iii) requesting to use Watt Share's Marketing Services as a User or Licensor, (iv) contacting of customer support or other similar communications; and (v) other instances where you may voluntarily provide it to us.

While our information collection varies based on our interactions with you, we may collect certain personal information. For purposes of this Privacy Policy, "Personal Information" means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information does not include publicly available information from government records, deidentified or aggregate information, or information excluded from the scope of applicable data privacy laws.

The type of Personal Information we may collect, use, transmit, and store is described below:

• Identifiers. When you create a Watt Share account as a User or Licensor, we store and use information you provide during the account creation process as a User or account onboarding process as a Licensor, such as first and last name, email address, phone number, postal address, login and password information, vehicle information such as, license plate information and make/model/year of a vehicle, and other similar account information ("Account Information")
• Payment Information. When you use our Site or Marketing Services as a Licensor, we may collect financial information, such as bank account or wire transfer information to facilitate payments directly to you. Suppose you are using the Site to create Reservations. In that case, limited credit card and bank account information may be collected by Watt Share, and more detailed credit card or bank account information may be collected by our payment processor, Stripe (https://stripe.com/en-ca/privacy). We never have access to your full credit card number, but, to administer your account and prevent fraud, we may have limited access to the following: the type of credit card you used (Visa, AmEx, etc.), the last four digits of the card number, and the card's expiration date;
• Internet or Other Similar Network Activities. The IP address from which you access the Site; cookie data; network connection type; browser type; the name of the domain from which you access the internet; the type of device, browser and operating system used to access the Site; the date and time you access the Site and the duration and stop time of such access; the information about any person or entity from whom you were referred; the pages, files, documents and links that you visit; the internet address of the website from which you linked to the Site;
• Commercial Information and Inferences. Information about your use of the Site or your usage of the Marketing Services generally; information you provide voluntarily when participating in surveys or product improvement interviews; and
• Geolocation Information. Geolocation information, including, with your consent, precise geolocation information.

Consistent with the permission you give us to collect Personal Information from you, Watt Share may use such Personal Information for the following legitimate business purposes:

• To provide, personalize, and improve your experience with the Marketing Services and Site and our advertising made available on or outside of the Site;
• To ensure technical functionality of the Marketing Services, develop new products and services, and analyze your use of the Marketing Services, including your interaction with applications, advertising, products and services that are made available, linked to, or offered through the Marketing Service;
• To communicate with you for Marketing Service-related or research purposes including via e-mails, notifications, text messages, or other messages, which you agree to receive;
• To communicate with you, either directly or through one of our partners, for marketing and promotional purposes via e-mails, notifications, or other messages consistent with any permissions you may have communicated to us;
• To facilitate payment processing through our third party payment processor, Stripe, or prevent or detect fraud;
• To facilitate on-site access to the Parking Spots for which you have made a Reservation;
• To manage, either directly or through one of our partners, your long-term Reservations and associated recurring billing;
• To facilitate payments directly to you as a Licensor;
• With your consent, to calculate distance to available Parking Spots and show you Parking Spots near your location;
• To enforce this Privacy Policy, the Terms and Conditions, and any other terms that you have agreed to, including to protect the rights, property, or safety of Watt Share, Users, Licensors, or any other person, or the copyright-protected content of the Marketing Services;
• To fulfill the purpose for which you submitted the information and for other uses consistent with that purpose; and
• As otherwise stated in this Privacy Policy.

In certain circumstances, we may disclose your Personal Information to third parties for a business purpose, as described below. Otherwise, we do not sell, rent, lease, or "share" Personal Information. We will not disclose your Personal Information to third parties for their direct marketing without providing notice to you.

With our Affiliates

We share your Personal Information with our affiliates, subsidiaries, and other companies under common control, including companies within the Watt Share group, and require them to honor this Privacy Policy.

With Licensors

If you are a User, we share your Personal Information with Licensors for, among other things, facilitating Reservations, confirming your Reservation on-site, troubleshooting on-site Reservation issues, and otherwise for the Licensors' business uses, including marketing to you.

With Users

If you are a Licensor, we share your information with Users to facilitate Reservations and provide customer support.

With our Service Providers

We share your Personal Information with our service providers who assist us in performing certain services and functions necessary to operate our business, the Site and provide our Marketing Services to you, including services related to communications and hosting, security and fraud prevention, technical and customer support, tracking and reporting usage, marketing, payment processing and other functions. Watt Share shares Personal Information with its service providers subject to obligations consistent with this Privacy Policy and on the condition that Personal Information is only used on Watt Share's behalf and under our instructions.

With Business Partners

Watt Share works closely with a number of business partners, including parking technology system providers, that assist us and/or Licensors in facilitating Reservations. When one of these companies assists us or a Licensor in facilitating your Reservation, we may need to share Personal Information related to that Reservation to enable the company to process, complete, and/or manage your Reservation, including payment information and vehicle information. In some cases, Watt Share also provides or facilitates access to services provided by these business partners, such as monthly parking subscription services and simplified on-site access and payment services. In each case, these business partners' processing of your Personal Information will be governed by their own privacy policies. We encourage you to read the privacy policies of these third parties.

With Payment Processors

We share your Personal Information with our third party payment processor, Stripe, so that you can pay for Reservations made through the Site or Apps. If you are a Licensor, we share your Personal Information with banks and other financial institutions in order to make payments to you.

To Complete Business Transfers

If we become involved in a transaction involving the sale of all or substantially all of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your Personal Information as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your Personal Information pursuant to its own privacy policies, and those policies may be different from this Privacy Policy.

With Marketing, Advertising, and Analytics Service Providers

We may share Personal Information about you with our data analytics and advertising service providers, such as Google Analytics and Rakuten Advertising, to help us measure traffic and usage trends for the Site and to understand more about the demographics and behaviors of our Users and Licensors. These companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. To learn more about Google's privacy practices, click here. To access and use the Google Analytics Opt-out Browser Add-on, click here. To learn more about Rakuten's privacy practices, click here. To learn more about your rights with respect to Rakuten, click here.

To Protect Rights and Property

We may disclose your Personal Information to third parties when we believe in good faith that disclosure is necessary to protect our rights, our property, personal safety, or the interests of you or any other person, and to detect, prevent and/or otherwise address fraud, risk management, security or technical issues.

To Comply with and as Required by Law

We may disclose your Personal Information to government authorities or other relevant third parties in order to comply with applicable legal requirements, judicial proceedings, court orders, legal process, or lawful requests from governmental authorities. We may also disclose your Personal Information in the good-faith belief that such action is necessary to protect our rights, interests, or property or to protect your safety or the safety of others.

Aggregate or Anonymous Information

We share User information in the aggregate with third parties, such as Licensors that use our Marketing Services. For example, we may disclose the number of Users that have booked a Reservation in a particular city or a particular location.

At Your Request

We also share your Personal Information as directed or requested by you, or otherwise with your consent.

We disclose (and have disclosed within the previous 12 months) the categories of Personal Information identified in Section 1 to the categories of third party recipients indicated below, in each case for one or more of the lawful business purposes described in this Section 3:

• Affiliates;
• Licensors;
• Other Users;
• Service Providers;
• Business Partners;
• Law Enforcement/Government Authorities; and
• Third Parties to a Business Transfer

In addition to Personal Information, we may also collect deidentified information from you and aggregate information that may not by itself reasonably identify you as the source when you navigate the Site ("Deidentified Information"). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law. When we receive or use deidentified information, we maintain it in deidentified form and do not attempt to reidentify the information.

When you use the Site, we may collect and store general location information, such as an IP address. If you permit us to access location services through the permission system used by your mobile operating system or browser, we may also collect the precise geolocation of your device when the Site is running in the foreground or background of your device. This information may be used to help you locate parking spots near you. You do not have to enable precise geolocation data to use the Site, but its functionality may be affected by your choice.

Watt Share may use the mobile phone number or similar contact information that you provided to us to send text messages to provide you with the Marketing Services and to facilitate your Reservations. For example, Watt Share may send you a text message containing a parking pass or other information allowing you to access a Parking Spot or garage. Watt Share may also use the mobile phone number or similar contact information that you provided to us to send marketing and promotional text messages with your consent. Additionally, Watt Share may send you a text message containing a link to download its Apps, based on your request. Each text will contain instructions permitting you to "opt-out" of receiving future text message communications. However, you cannot revoke your authorization for fraud related communications or legally required communications.

The Marketing Services and Site are not intended for use by persons under the age of 16 in the United States (or under the age of majority in Canada, as applicable). We do not seek or knowingly collect Personal Information from individuals under the age of 16, and we request that such individuals do not provide such information. If you are under 16 and a resident of the United States (or under the age of majority in your respective Canadian jurisdiction), you may not use either the Marketing Services or Site. If we learn we have collected or received Personal Information from a child under the age of 16, we will take reasonable measures to promptly delete such information from our systems.

Cookies and similar tracking technologies, such as beacons, scripts, web beacons and tags, are small bits of text, that are stored on browsers or devices by websites, apps, online media and advertisements. We use cookies and similar tracking technologies for purposes such as: authenticating Users, remembering Users' preferences and settings, and understanding the behaviors and interests of Users who interact with or use the Site or Marketing Services.

Note that some content or applications, including advertisements, on the Site may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

You can learn more about our use of cookies, as well as your choices related to various tracking technologies, by visiting our Cookie and Interest-Based Advertising Policy.

Watt Share provides ways for you to access and delete your personal information as well as exercise applicable data rights that give you certain control over your personal information. Your Rights and Choices include:

• Email Subscriptions. We may, from time to time, communicate with you via email. If you no longer wish to receive promotional emails from us, please let us know by clicking unsubscribe in those messages or by emailing us at support@spothero.com. Please note that, although you can opt not to receive promotional emails, we reserve the right to send you informational emails about any administrative notices regarding the Site and Marketing Services or important information about your account, as permitted under the CAN-SPAM Act (15 U.S.C. §7701 et seq.).
• Text Messages. You can opt-out of receiving text messages by texting STOP from the mobile device receiving the messages. Opting-out of receiving text messages may limit your ability to take advantage of our full range of features and services.
• Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Site or Marketing Services.
• Location Information. You can prevent your device from sharing location information through your device's system settings. If you do, this may limit our ability to provide you our full range of features and services.
• Cookie Tracking. You may also enable online, where available, a universal opt-out preference tool (such as the Global Privacy Control ("GPC") signal) that automatically communicates your opt-out preferences, which we intend to respect. Some internet browsers may transmit "do-not-track" signals to websites with which the browser communicates. The Site does not currently respond to these "do-not-track" signals.
• Accessing Your Account. You can access or correct your account information at any time by logging into your account or by contacting admin@wattshare.ca.
• Deleting Your Account. You can delete your User account through the Watt Share iOS mobile app by opening the Watt Share app, clicking Account -> Privacy -> Delete My Account. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. Please note that deleting your account is permanent and cannot be undone.
• State and Country Specific Rights. Some states provide specific, additional rights to their residents regarding Personal Information. For more information about these rights and how to exercise them, see the State and Country Specific Rights section below.

The Site may contain links to other websites or applications ("Linked Sites") that are not owned by Watt Share, such as websites of Licensors. We do not control the collection or use of any information, including Personal Information, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Site are framed within the Site.

We utilize information technology security to keep the information that you provide to us through the Site secure. We also attempt to have privacy protection controls in place with our vendors in order to ensure that your Personal Information is protected from unauthorized access or disclosure. Only authorized employees are permitted to access your personally identifiable information or that of other visitors touring the Site. Notwithstanding, as effective as our reasonable security measures may be, no security system is impenetrable nor is any method of transmission over the Internet or via mobile device, or method of electronic storage, 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information we cannot guarantee its absolute security.

Under applicable Canadian privacy legislation, you have the following rights:

• Access. Watt Share permits the reasonable right of access to your Personal Information. Upon written request and authentication of identity, we will provide you with access to your Personal Information under our control, subject to any legal requirements and applicable exceptions to the right of access. We will make the information available within thirty days or provide written notice where additional time is required to fulfill the request. Where an access request is refused, we will notify you in writing and provide our rationale for refusal along with a list of next steps available to you.
• Accuracy. If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third party service providers to whom the information has been disclosed.
• Complaint. You may also have the right to complain to the Office of the Privacy Commissioner of Canada or the appropriate provincial Information and Privacy Commissioner if you have concerns related to our privacy practices.

If you are a resident of Canada and would like to exercise any of the aforementioned rights, please send us an email at admin@wattshare.ca.

This Privacy Policy was last modified as of the effective date printed above. This version of the Privacy Policy replaces and supersedes any prior privacy policies applicable to the Site or Marketing Services.