We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

The Cozii Technologies Inc website, Services, apps, and their interactive properties are delivered (“the Services”), owned, operated, and distributed by us (referred to in this Privacy Policy as “we” and through similar words such as “Cozii,” “us,” “our,” etc.). This Privacy Policy outlines the personal information that we may collect, how we use and safeguard that information, and with whom we may share it. We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the Ontario Province, and we are responsible as controller of that personal information for the purposes of those laws.

THE SERVICES ARE OFFERED FROM ONTARIO, CANADA. For individuals located outside of Canada, please note that we are a Canada-based company. If you use the Services, all information, including personal information, will be transferred to us in Canada and used as described in this Privacy Policy.

1. Key Terms

It would be helpful to start by explaining some key terms used in this policy: “ We, us, Our, Cozii”

2. Personal Information We Collect About You.

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

3. How Your Personal Information is Collected

We collect most of this personal information directly from you—through our website and apps as you use the Services. However, we may also collect information:

• From publicly accessible sources (e.g., criminal records);

• Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

• From a third party with your consent (e.g., your bank); and,

• From cookies on our website.

4. How and Why We Use Your Personal Information.

Under data protection law, we can only use your personal information if we have a proper reason for doing so:

• To comply with our legal and regulatory obligations;

• To perform the Services;

• To prevent and detect fraud against you or any third party;

• For our legitimate interests or those of a third party; or

• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses as well as advanced fraud signals and information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including fraud detection. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

5.5. Promotional Communications.

We may use your personal information to send you updates by email, text message, telephone or post about our products and Services, including exclusive offers, or promotions.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to any other organization, except as part of a corporate merger, acquisition, or sale.

You have the right to opt-out of receiving promotional communications at any time by:

• Contacting us at suport@cozii.co

• Using the “unsubscribe” link in emails or “STOP” number in texts.

Who We Share Your Personal Information With

We routinely share personal information with:

• Our affiliates, including companies within the PropertyTek Group. Affiliate means any entity or individual that directly or indirectly controls, is controlled by, or is under common control as us.

• Service providers we use to help deliver the Services to you, such as (but without limitation) payment service providers, credit agencies, maintenance companies, property management companies, and property owners.

• Other third parties we use to help us run our business, such as website and cloud hosting services;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use the personal information we collect from you to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO[ or Investors in People] accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize the information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

• Our affiliates, including companies within the PropertyTek Group. Affiliate means any entity or individual that directly or indirectly controls, is controlled by, or is under common control as us.

• Service providers we use to help deliver the Services to you, such as (but without limitation) payment service providers, credit agencies, maintenance companies, property management companies, and property owners.

• Other third parties we use to help us run our business, such as website and cloud hosting services;

6.Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers).

• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, photographs, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, criminal history, bank account number, credit card number, debit card number, or any other financial information.

• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction our Services); and

• Geolocation data.

7.Where Your Personal Information is Held.

Information may be held at our offices and those of our service providers. Some of these third parties are based in the United States.

8.How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing [products AND/OR services] to you. Thereafter, we will keep your personal information for as long as is necessary

• To respond to any questions, complaints or claims made by you or on your behalf;

• To show that we treated you fairly; or

• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

9. Your Rights Under the CCPA.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

10. Keeping Your Personal Information Secure.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems, and we follow industry standards for information security. We also have procedures in place to deal with a suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Users of the Services are responsible for maintaining the security of any password, user ID or other forms of authentication involved in obtaining access to password-protected or secure areas of the Services. In order to protect you and your information, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

11.Third Party Advertisers.

We may allow other companies, called third-party ad servers or ad networks, to serve advertisements within the Services. These third-party ad servers or ad networks use technology to send, directly to your device, the advertisements and links that appear on the Services. They automatically receive your device ID and IP address when this happens. They may also use other technologies (such as cookies) to measure the effectiveness of their advertisements and to personalize the advertising content you see. You should consult the respective privacy policies of these third-party ad servers or ad networks for more information on their practices and for instructions on how to opt-out of certain practices. This Privacy Notice does not apply to them, and we cannot control their activities.

12. International Data Transfer.

If you are located outside the United States, in particular, if you are located in Switzerland, the United Kingdom, or the European Economic Area (“EEA”), please note that we and our servers are located in Canada and the United States. We do not market to or solicit customers from outside the Canada and the US; therefore, users of the Services should not expect to avail themselves of the rights provided under the EU’s General Data Protection Regulation (“GDPR”). If you use the Services, all information, including personal information, will be transferred to us in the US. By using the Services, you unambiguously consent to the transfer of your personal information and other information to the US and elsewhere for the purposes and uses described in this Notice.

13. Children’s Privacy

The Services are not intended for children under the age of 18, and we do not knowingly collect the personal information of children under the age of 18.

14.External Links.

The Services may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and we are not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information. You hereby acknowledge and agree that we are not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release us from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.

15. Cookies and Device Data.

When you use the Services, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Services, and your network location. We use aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Services and to create new features, promotions, functionality, and products by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Services through cookies and other technologies:

• Domain name
• Browser type and operating system
• Web pages you view
• Links you click
• IP address
• The length of time you visit the Sites, Portals, and/or Websites
• The referring URL or the webpage that led you to the Sites

We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on our behalf).

In addition, we may use “cookies,” clear gifs, and log file information that help us determine the type of content and pages to which you link, the length of time you spend at any particular area of the Services, and the portion of the Services you choose to use. A cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser. A cookie contains limited information, usually a unique identifier and the name of the site. Your browser has options to accept, reject or provide you with notice when a cookie is sent. Our cookies do not execute any code or virus; and they do not contain any personal information. Cookies allow us to serve you better and more efficiently, and to personalize your experience with the Services. We may use cookies for many purposes, including (without limitation) to save your password so you don’t have to re-enter it each time you use the Services, and to deliver content (which may include third-party property listings or other relevant \advertisements) specific to your interests.

We may use third-party service providers to help us analyze certain online activities and/or to analyze aggregated data provided by customers. For example, these service providers may help us measure the performance of our online campaigns or analyze user activity. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect such information on our behalf. Our third-party service providers are required to comply fully with this Privacy Notice

16. How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, please:

• Email us at support@cozii.co.

Please note that you may only make FIPPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:

• Enough information to identify you, specifically your full name, address, and account number
• Proof of your identity and address (e.g., a copy of your driving license or passport)
• A description of what right you want to exercise and the information to which your request relates

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

17. Changes to This Privacy Notice.

This privacy notice is published on January 1, 2025 and last updated on January 16, 2023.

We may change this privacy notice from time to time– when we do, we will inform you via account notification.

18. How to Contact Us.

Please contact us by email at support@cozii.co

19. Do You Need Extra Help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see “How to contact us” above).