LINKIFY REWARDS — PRIVACY POLICY

DRAFT — pending legal review; not legal advice. This is an in-house draft produced from the Linkify Rewards decision register (LR-ENG-001 and LR-BUS-001 only) for review by Linkify's counsel before publication. It is not legal advice. Items in square brackets are facts to be confirmed by Linkify or resolved with counsel; nothing has been invented beyond the decision register.

1. INTRODUCTION

1.1 Linkify Solutions Inc. ("Linkify", "we", "us", "our") operates Linkify Rewards ("the Service"). This Privacy Policy explains what personal information we collect, why we collect it, how we use it, what participating merchants can see about you, and your rights.

1.2 Our registered office is at [registered address of Linkify Solutions Inc. — to be inserted].

Basis: LR-BUS-001 §1.1 (operator of record: Linkify Solutions Inc.).

1.3 We are accountable for the personal information under our control and comply with PIPEDA.

Basis: PIPEDA (accountability principle).

2. PERSONAL INFORMATION WE COLLECT

2.1 Account information. Your email address and name, and sign-in credentials. We use email OTP or, when available, Apple/Google sign-in. If a phone number is provided to us — for example, supplied by a social sign-in provider or collected through a future feature — we store only a salted hash of that phone number, used solely for account-uniqueness checks. Phone-number authentication is not used.

Basis: LR-ENG-001 §2.6.a (email OTP + Apple/Google sign-in; no phone auth), §2.6.b (hashes of email and phone for uniqueness); LR-TS-000 P0-R32 (email and, when later provided, phone).

2.2 Device information. A device token used for secure-store device binding, which supports fraud prevention.

Basis: LR-ENG-001 §2.6.b (device binding using the secure-store device-token mechanism); §8.3.

2.3 Transaction and points information. Your Points balances and history, visits, orders, and tender composition at each merchant.

Basis: LR-BUS-001 §5.4.c (tender composition displayed); §5.2.

2.4 Two-layer economy. The Service separates two layers: the closed, per-merchant loyalty layer (Points; free product only here, merchant-funded) and the open, cross-merchant discovery layer (discount coupons only, never free product). Your Points exist only in the loyalty layer.

Basis: LR-BUS-001 §5.1, §5.1.1, §5.1.2. Load-bearing for the tax treatment (LR-ENG-001 §7.1).

2.5 Payment information. Payments you make through the Service are processed by our payment processor; we do not store full payment card numbers.

Basis: LR-BUS-001 §8.1 (Stripe Express connected accounts; merchant of record).

2.6 We do not collect more personal information than is needed for the purposes described in this Policy.

Basis: PIPEDA (limiting collection).

3. HOW WE USE PERSONAL INFORMATION

3.1 We use personal information to:

• operate the Service, including earning, redemption, the wallet pass, and checkout;
• verify identity, detect fraud, and prevent abuse (including one-per-person offers);
• send notifications you have opted into;
• provide support; and
• meet legal and regulatory obligations.

Basis: LR-ENG-001 §2.6, §2.12, §8.6; PIPEDA.

3.2 We use the cross-merchant view of activity only to operate the Service and to support the platform's purposes; individual merchants do not see your activity outside their own locations (see Section 5).

Basis: LR-ENG-001 §8.5 (only Linkify holds the full graph).

4. CONSENT

4.1 We rely on your consent to collect, use, and disclose your personal information, except where PIPEDA permits collection, use, or disclosure without consent. Where required, we obtain consent when you create an account, when you opt in to notifications, and when your information is needed for a purpose not otherwise expected.

Basis: PIPEDA (consent principle).

4.2 You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect your ability to use parts of the Service (for example, push notifications).

Basis: PIPEDA (withdrawal of consent).

5. WHAT MERCHANTS CAN SEE

5.1 A participating merchant sees a limited customer profile: your first name and last initial; your visit and Points history at that merchant's locations only; and segment tags (new/regular/lapsed).

Basis: LR-ENG-001 §8.5 (first name + last initial; own-location visit/points history; segment tags).

5.2 A merchant does not see your email address, your phone number, or your behavior at other merchants. Merchants do not contact you directly; campaigns reach you through the platform.

Basis: LR-ENG-001 §8.5 (no email, phone, or cross-merchant behavior; campaigns reach customers through the platform).

5.3 Only Linkify holds the full cross-merchant view.

Basis: LR-ENG-001 §8.5 (only Linkify holds the full graph).

6. DISCLOSURE AND SERVICE PROVIDERS

6.1 We disclose personal information to service providers who help operate the Service, subject to contractual safeguards. Current categories of providers include:

• cloud hosting and media storage [providers — confirm; e.g., [OCI VM], [Cloudflare R2]];
• email delivery;
• payment processing (Stripe);
• error and crash monitoring (GlitchTip);
• product analytics (PostHog); and
• session replay (PostHog, with masking enabled).

Basis: LR-ENG-001 §4 (analytics/observability stack: GlitchTip, PostHog incl. session replay — Clarity dropped, owner decision 2026-08-15); LR-BUS-001 §8.1 (Stripe).

6.2 We do not sell personal information.

Standard; consistent with LR-ENG-001 §8.5.

6.3 We may disclose personal information where required by law, or to protect our rights, the rights of others, or the security of the Service.

Basis: PIPEDA (disclosure without consent where required by law).

7. PUSH NOTIFICATIONS

7.1 We send push notifications only with your consent (opt-in).

Basis: LR-ENG-001 §8.6 (pushes to opted-in customers).

7.2 Notifications are subject to per-merchant monthly quotas and enforced quiet hours. Cross-merchant discovery notifications are curated by the platform.

Basis: LR-ENG-001 §8.6 (per-merchant quota 2–4; quiet hours; platform-curated digests).

7.3 You may change your notification preferences or withdraw consent at any time through the Service.

Basis: LR-ENG-001 §8.6; PIPEDA (withdrawal of consent).

8. RETENTION

8.1 Points at a merchant expire after [12–18 months — final value set at Phase 3] of no activity at that merchant. You are warned 30 days and 7 days before expiry.

Basis: LR-ENG-001 §8.1 (platform-wide inactivity expiry; 30/7-day warnings).

8.2 We retain personal information only as long as necessary for the purposes described in this Policy or as required by law.

Basis: PIPEDA (limiting retention).

9. ACCOUNT DELETION

9.1 You may request deletion of your account at any time by contacting support@linkifyrewards.com. Once an in-app deletion flow ships, you may also request deletion through the Service. We will honor deletion requests within PIPEDA-consistent timeframes.

Basis: PIPEDA-compatible account deletion; LR-ENG-001 §2.12 (support channel), §3 (TLM legal precedent — delete-account flow, adapted). Phase 1 ships no self-serve deletion endpoint — this clause states the request-based right.

9.2 On account deletion, we will delete or de-identify your personal information, subject to legal retention requirements (for example, records required for tax or fraud-prevention purposes).

Basis: PIPEDA (deletion/de-identification; limited retention exceptions).

10. SECURITY

10.1 We use appropriate administrative, technical, and physical safeguards to protect personal information, including encryption in transit and at rest, and access controls.

Basis: PIPEDA (safeguards principle); LR-ENG-001 §2.5.b (RLS on tenant tables).

11. ACCESS AND CORRECTION

11.1 You may request access to, and correction of, your personal information. We will respond within the timeframes PIPEDA requires (typically within 30 days, depending on the request).

Basis: PIPEDA (individual access; accuracy).

11.2 To make a request, contact us using the details in Section 15.

12. CROSS-BORDER PROCESSING

12.1 Personal information may be processed outside Canada by our service providers. We remain responsible for the protection of personal information under PIPEDA wherever it is processed.

Basis: PIPEDA (cross-border transfer accountability).

13. CHILDREN

13.1 The Service is not directed to children under [age — confirm]. We do not knowingly collect personal information from children. If you believe a child has provided us personal information, contact us so we can delete it.

Standard; pending legal review. No register decision on minimum age — flag for counsel.

14. CHANGES TO THIS POLICY

14.1 We may update this Policy. Material changes will be posted in the Service and, where appropriate, notified to you.

Standard legal boilerplate; no conflicting register decision.

15. CONTACT AND PRIVACY OFFICER

15.1 For privacy questions, complaints, or to exercise your rights, contact:

• [Privacy officer name/title — to be inserted]; or
• support@linkifyrewards.com.

Basis: LR-ENG-001 §2.12 (support@linkifyrewards.com). Privacy officer identity is a bracketed fact.

15.2 You may also contact the Office of the Privacy Commissioner of Canada.

Basis: PIPEDA (right to complain to the supervisory authority).

16. EFFECTIVE DATE

16.1 [effective date — to be inserted]