BOREAL TALENT SOLUTIONS INC. PRIVACY POLICY

1. OVERVIEW

At BOREAL TALENT SOLUTIONS INC. (the “Company”, “we” or “us”), we use our website and other internet-based tools for the following purpose:

Provision of talent acquisition services including recruitment and strategic talent acquisition consulting services.

We are required to collect and retain information about the people and companies that access and use the website (“Users” or “you”). This Policy applies to our privacy practices on all communications between the Company and Users, including but not limited to communication via:

1. the Company website (including the website hosted at www.borealtalent.com and any other web domain used by the Company to communicate with users now or in the future);

2. any mobile, computer, or tablet-based application currently offered by Company or developed in the future by the Company; and

3. all other services provided by the Company, as described on the Website (Items 1 to 3 are collectively referred to as the "Website").

This Privacy Policy (“Policy”) sets out how we use, protect, collect and preserve information submitted by Users, including User information gathered by our technology. This Policy should be read in conjunction with any Terms of Use or policies available on the Website.

By accessing or submitting any information through the Website, you are agreeing to the terms of this Policy. You are prohibited from accessing or using the Website unless you fully understand and agree to this Policy and all Terms of Use available for review on the Website.

If you have any questions about this Policy, please contact us by sending an email with your questions to privacy@borealtalent.com before accessing or entering any information on the Website.

When you access and use the Website, we will collect and retain all personal identifying information submitted to us.

We will take steps to protect the information submitted to us by Users and we will not disclose any personal identifying information without the consent of Users, unless otherwise set out in this Policy.

Personal identifying information may include but is not necessarily limited to:

Full Name, email address, company name

We will not use personal identifying information to contact you for any reason unrelated to your use of the Website or for commercial reasons unrelated to the business of the Company. Except with your consent or where required by law, we will not provide personal identifying information to any third party.

To facilitate the collection of information and to enhance the experience of Users of the Website, we use cookies which may be stored on Users’ computers and/or devices so that we can recognize Users when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, changing such settings may result in you not being able to use the Website, either in its entirety or certain features.

Using cookies, you may have the option to allow us to save your user ID and login password for future logins to the Website.

Cookies that are stored on your computer and/or device after visiting the Website may be recognized for advertising purposes and to show you targeted advertisements after you visit the Website.

For more information on the cookies we use or to opt-out, please contact us at privacy@borealtalent.com.

We use data collected from the Website for various purposes, including to: provide the Website to you and accompanying customer support; notify you about updates and changes to the Website; prevent and address technical issues with the Website; monitor usage of the Website.

Without restriction, we may use any information you submit through the Website for any purpose we deem appropriate so long as it is anonymous and stripped of any and all personal identifying information.

We may use the data collected from the Website, devices, browsers, and any other sources, for its own purposes, both related to and unrelated to improving the Website.

We may process your personal identifying information for a number of reasons, including:

• performing a contract with you relating to the Website;
• you have provided us consent to do so;
• fulfilling a legal obligation;
• fulfilling our legitimate interests, which are not overridden by your rights;
• for payment processing purposes.

If you wish to access or amend your personal information or to request that we permanently delete your personal information from our servers, please send an

email to privacy@borealtalent.com. We will ensure your personal information is accessible, amended and/or deleted in a reasonable time after receiving that request. Deleting such information may require us to terminate any account you may have created in its entirety and prevent you from using the Website.

So long as your account remains active, we will preserve your personal information in accordance with the Policy.

You may decline to share certain personal information with us, in which case you may not be able to use the Website, either in its entirety or certain features.

When deleting your information, whether by request or due to inactivity, we will use standard electronic means to remove your personal information from our files.

We will also retain any and all information that we are required to retain under any applicable laws for the full duration of time required under those laws.

We will store your information in electronic format on industry-standard servers that we have selected. Except where required to do so by law, we will not store your personal information in any physical or paper-based format.

The servers we select to store information engage security software and generally accepted standards to protect personal information. The software used by these servers is intended to prevent unauthorized access or improper use.

However, no security system is perfect and there is always a risk of unauthorized parties accessing your personal information. Therefore, we make no guarantees or representations as to the technical or legal compliance of the servers we use. We cannot guarantee the complete protection and security of your personal information.

Our servers may be located outside of Canada, and thus are potentially subject to the privacy and security laws in force in other countries. If you have concerns about your personal information being stored electronically in foreign jurisdictions, please contact us before proceeding to use the Website.

In the event the personal information of a User is disclosed as the result of any breach of security of the Website or its servers, regardless of who is at fault, we will take steps to advise all known affected Users within a reasonable timeframe of learning of the breach.

To provide an enhanced experience to Users, including to track conversions and analytics, we may engage services and features controlled by third-parties. We cannot control or dictate how any third-party application you use in conjunction with the Website, now or at any point in the future, will treat any personal information you transmit through their servers when using the Website. We advise you to contact these parties directly to review their privacy policies.

Without limitation, the Company uses or may use the following third-party applications and services in conjunction with the Website:

Google Analytics, Facebook

By using any of these third-party application to interact with the Website, we will not be given access to your login credentials, user name, password, payment information, or any information you may provide directly to these applications.

With the following restrictions, the Website may be accessed in certain circumstances by persons under the age of 18.

We take the following precautions to protect the safety and information of persons under the age of 18:

Persons under the age of 13 are prohibited from using the Website without the express permission and direct supervision of a parent or guardian. Persons under the age of 13 are prohibited from submitting any personal identifying information through the Website. The Company will immediately delete any personal identifying information submitted in violation of this Policy.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may disclose your personal information to third parties:

1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

2. If the Company or its assets are acquired by a third party, in which case personal data about Users may be one of the transferred assets.

3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use; or to protect the rights, property, or safety of the Company, our Users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

This Policy may be updated and amended from time to time. We reserve the right to change this Policy at any time, and any amended Policy is effective upon posting to the Website. We will make efforts to communicate any changes to this Policy we deem material, in our sole discretion, via email or notifications on the Website. Your continued use of the Website will be deemed acceptance of any amended Policy.

We encourage you to send us questions and inquiries on this Policy and the steps we take to keep your personal information secure. Please send us an email: privacy@borealtalent.com

We will respond to all inquiries on the Policy within 5 days.