We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy describes the privacy practices of Hero Innovation Group (“Hero”, “we”, “our” and “us”) and applies to your use of the products and services we offer (collectively, the “Services”). We provide the Services through our mobile applications, web based applications and our websites at www.HeroInnovationGroup.com, www.SideKickCard.com and www.herofinancials.com (collectively, the “Account”). By using the Services, you accept the practices described in this Privacy Policy.

This Privacy Policy explains:

• What information we collect and why we collect it.
• How we use that information.
• The choices we offer, including how to access and update your information.

Information We Collect

We collect information to provide, personalize and continually improve the Services and provide the best experience. This includes helping us to present relevant information to you within the Hero App and recognizing when you should receive discounts, incentives, rewards and other offers for an action you have taken.

While using the services gathered data further aims to prevent fraud and remain in compliance with data privacy and finance regulations such as, but not limited to, FINTRAC, AML, GDPR and LGPD.

We collect information in three ways:

1. Information you give us. Many of the Services require you to sign up for an Account. When you do, we will ask for personal information, such as your name, company name, address, email address, telephone number and/or loyalty, prepaid, debit or credit card information to store with your Account. To complete transactions using the Services, you will need to provide the account and card details for one or more loyalty, prepaid, debit or credit cards held by you. We will also retain feedback and social media information posted by you in connection with the Services.

2. Information we obtain from your use of the Services. We may collect information regarding your use of the Services including:

• Device Information. We collect device-specific information such as your hardware model, operating system and version, unique device identifiers, and mobile network information including phone number.
• Transaction Information. When you make, or request to make, a transaction, including a return or refund, we will receive details of the transaction including the amount of the transaction; the time of the transaction; the goods and/or services purchased; the details of any loyalty, points, discounts, incentives, rewards and other offers or benefits offered by, provided to or redeemed by or with you; and the details of the third party, including name, location and type of business.
• Location Information. We may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers. You may disable location services with the Hero App or generally on your mobile device.
• Local Storage and Cookies. We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches. We may also send one or more cookies or anonymous identifiers to your device when you interact with the Services or the services we offer to our partners, such as Hero or SideKick Card features that may appear on other sites.
  ● Log Information. We automatically collect and store certain information in server logs including details regarding your use of the Services; internet protocol address; device information; telephony log information such as your phone number; event information such as crashes, system activity, hardware settings, browser type, browser language and the date and time of your use; your interaction and viewing history for content within the Services; and cookies that may uniquely identify your browser or your Account.

3. Information we obtain from our partners. Your name and the name of any additional cardholder associated with any loyalty, prepaid, debit or credit card linked to your Account is received from the issuer of the card when it is linked to your Account. These details allow you to use other funding sources, access loyalty, points, discounts, incentives, rewards and other offers or benefits, and enable us to process transactions using the correct source of funds.

Information we collect when you use the Services, in addition to information we obtain about you from our partners, may be associated with your Account. When information is associated with your Account, we treat it as personal information.

Information Security

We work hard to protect our users from loss, interference, misuse and unauthorized access to, modification of and disclosure of information we hold. In particular:

• We encrypt many of our services using SSL.
• We offer password protection for your Account.
• We regularly review our information collection, storage and processing practices and security measures, to guard against unauthorized access.
• We restrict access to personal information to Hero employees, contractors, merchants and agents who need to know that information in order to provide the Services or to process it for us, and who are subject to strict contractual confidentiality obligations.

How We Use Information We Collect

We use the information collected about you to provide, maintain, protect and improve the Services, and to develop new products and services. We also use the information to protect you, other users and Hero.

Specific examples of the way we use your information include:

• To authorize and process transactions including returns and refunds.
• To apply discounts, incentives, rewards and other offers applicable to your transactions.
• To provide appropriate data and content to you including details of applicable discounts, incentives, rewards and other offers.
• To verify user identity and maintain and update our records.
• To comply with any applicable law, rule or regulation and to detect and prevent any unauthorized use of our services such as money laundering, terrorist financing or other criminal activities.
• To communicate with users, including dealing with user enquiries.
• To conduct product and marketing research.
• To improve our products and services.

We may use the name for your Account across all of the Services. In addition, we may replace past names associated with your Account so that you are represented consistently across all the Services.

When you contact us, we keep a record of your communication to help solve any issues you might be facing. We may use your telephone number to send you notifications and information relating to actions you have taken. We may also inform you about our services through email, SMS, push notifications or within the Hero App, such as letting you know about upcoming changes or improvements.

We use information we collect and may combine information from any of the Services with information, including personal information, from other Hero services to improve your user experience and the overall quality of our services.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

Information We Share

We do not share personal information with companies, organizations and individuals outside of Hero unless one of the following circumstances applies:

Transaction processing, including processing discounts, incentives, rewards and other offers

• We provide personal information to our affiliates or other trusted persons to process your transactions, based on our instructions and in compliance with our Privacy Policy and any other legally required confidentiality and security measures.

Legal reasons

• We will share personal information with persons outside of Hero if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• comply with any applicable law, rule, regulation, legal process or enforceable governmental request;
• enforce applicable Terms of Service, including the investigation of potential violations;
• detect, prevent or otherwise address fraud, security or technical issues; or
• protect against harm to the rights, property or safety of Hero, our users or the
• public as required or permitted by law.

Aggregated/anonymised data

• We may share aggregated, non-personally identifiable information publicly and with our merchants, partners or connected sites. For example, we may share information publicly to show trends about the general use of our services.

Program operators

• We may share personal information, including transaction data, with our program operators for billing and accounting purposes and resolving technical issues.

Corporate transactions

• If we are involved in a major corporate transaction such as a merger, acquisition or sale of all or substantially all of our business or one or more divisions of our business, we may disclose certain personal information to potential buyers, underwriters and advisors. If we do this, we will take reasonable precautions to ensure that recipients of any personal information are obligated to keep it confidential. To the extent that we transfer our business or a division of our business to which personal information is relevant, such personal information will be also be transferred and the new owner or newly controlling party will be permitted to use such personal information in accordance with this Privacy Policy.

With your consent

• We will also share personal information with persons outside of Hero when we have received your consent to do so.

Our Communications with You

Among other things, we will communicate with you on a regular basis via email, SMS push notifications or within the Hero App. We may also communicate by phone to resolve user complaints or investigate suspicious transactions. Communications will be made for various reasons, including sending records of transactions requested or made, sending information about important changes to the Services, and to send notices and other disclosures required by law. You agree to receive such communications electronically until you advise us otherwise. We may send you promotional messages about new services, discounts, incentives, rewards and other offers or opportunities that may interest you. If you do not want to receive promotional messages or other communications from us, please adjust the settings within the Hero App or under your Account. However, we reserve the right to send you notices for customer service reasons, including notices about your account or transactions using the Services. Also, to help us make communications more useful and interesting, we may receive a confirmation when you open or receive communications from us.

Accessing and Updating Your Personal Information

Whenever you use the Services, we aim to provide you with access to your personal information. If that information is incorrect, we provide ways to update it quickly or to delete it (unless we need to keep that information for legitimate business or legal purposes). When updating or correcting your personal information, we may ask you to verify your identity before we can act on your request.

We may reject requests for access to or to correct your personal information if they are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or we are legally obligated to do so.

Where we can provide you with access to your personal information, we will do so for free, unless providing the information means we will incur an unreasonable cost. In such cases, we may charge you a fee commensurate with such cost but will advise you of any such charge in advance.

We aim to maintain our services in a manner that protects your personal information from accidental or malicious destruction. Because of this, after you delete any such information from the Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems to ensure compliance with regulations such as FINTRAC.

When This Privacy Policy Applies

This Privacy Policy applies to all of the services we offer, both directly and through our subsidiaries and affiliates, and any services offered by any of them on other sites and through other mobile apps. This Privacy Policy excludes services that have separate privacy policies which do not specifically reference or incorporate this Privacy Policy.

This Privacy Policy does not apply to services offered by other persons, including sites that may include Hero services, or other sites linked from our services unless those services specifically reference or incorporate this Privacy Policy. This Privacy Policy does not cover the information practices of other persons who advertise our services.

Opting Out, Corrections and Complaints

Upon request, we will (a) correct or update your personal information; (b) stop sending communications to you via email, SMS or push notifications; (c) stop disclosing non-public personal information about you to non-affiliated third parties; or (d) disable your account. Some of these requests can be satisfied by changing settings within the Hero App. To the extent that you are unable to do so within the Hero App, you may submit such requests to:

Hero Innovation Group. Attn: Privacy Officer 170 – 422 Richards Street Vancouver, BC V6B 2Z4

Email: privacy@herofinancials.com.

Please do not email or mail your account number or other sensitive information.

We may need to communicate with you about certain issues that we are legally permitted to regardless of your desire to opt out of receiving such communications; accordingly, you will be unable to opt out of these communications.

You may also register any complaints pertaining to the use by us of your personal information not in accordance with this Privacy Policy in the above manner.

Compliance and Cooperation with Regulatory Authorities and Complaints

We regularly review our compliance with this Privacy Policy. We also adhere to several self- regulatory frameworks.

We will work with appropriate regulatory authorities, including local privacy protection authorities, to resolve any complaints regarding the transfer of personal information that we cannot resolve with our users directly.

Changes

This Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.