UPDATES TO OUR PRIVACY POLICY

20 MAY 2020

The Fintech Sport Group Inc (“JustMove", “us”, “we”, “our”) owns and operates an interactive online platform (the “Platform"), mobile application (the “App”) and website www.justmove.app (the “Site”) (together the Platform, the App and the Site are the “JustMove Products”). JustMove takes all reasonable steps to preserve the confidentiality of Personal Information it collects and uses in a manner consistent with applicable law and reasonable technological security measures.

This Privacy Policy (the “Policy”) describes the manner in which JustMove collects, uses, discloses, and otherwise manages the Personal Information, Location Information, Activity Information and Preference Information you provide while using the JustMove Products. JustMove respects the current federal and provincial privacy laws and regulations in Canada including the Personal Information Protection and Electronic Documents Act (PIPEDA), the Digital Privacy Act, An Act Respecting the Protection of Personal Information in the Private Sector (Quebec), the Personal Information Protection Act (British Columbia), and the Personal Information Protection Act (Alberta).

Personal Information means information about an identifiable individual using the JustMove Products. An individual’s personal information includes his or her name, sex, height, weight, birthdate, and email address. Information such as metadata (IP address, browser, time and date of access) when used in conjunction with other information may become Personal Information. Location Information will form part of Personal Information.

Location Information includes your residential location, current login location (IP address), and/or GPS location (if you wish to share it with us through your mobile device settings), or other phone related location data (ex. Via WiFi or Bluetooth).

Activity Information includes fitness data (ex. workout start and end times, activity type), sensor data (this includes but is not limited to step goal, duration, pace, distance, speed, calories, score), and other data (ex. routes and photos) related to your use of the App.

Preference Information includes your preferred language, units (distance, weight, height) and personal goals (distance, steps).

COLLECTION AND USE OF PERSONAL INFORMATION

The type of Personal Information collected may also include a profile picture, social media identifiers and information passed along to us via your Facebook or Google account, and your device fingerprint should you choose to share and/or interact with us in this manner.

If you register to the App using your Facebook or Google sign-in account, we will receive the following information: First and last name, email address, gender, birthdate, profile picture.

Location Information is used to operate the JustMove Products and adapt them to your experience and location.

Activity Information is used to operate the JustMove Products and help you improve your performance goals as well as your user experience. This information may also be used to identify what activities might be best for you based on your usage patterns

Preference Information is used to provide convenience in using the App and Site.

JustMove processes your Personal Information to provide you a seamless user experience which includes operating the JustMove Products to authenticate your access, track and display your activities, and show your training progress and statistics. In addition, we use your Personal Information to make it easier for you to find and connect with others therefore using the information you shared within the App, including GPS data, to suggest connections between you and people you may know. We will also use your Personal Information to respond to your questions.

JustMove also processes your Personal Information to manage our own business needs, improve the use of JustMove Products and protect the security or integrity of the JustMove Products, their performance and functionality.

JustMove takes reasonable safeguards and measures to protect Personal Information against unlawful or unauthorized access, disclosure, copying, use or modification. This includes procedures and technologies to maintain the security of Personal Information from the point of collection to the point of destruction

COMMUNICATIONS

You may sign up to receive emails with event related information or other newsletters from us. When you sign up, we collect information such as your name and email address which we use to send you the communications you request to receive. You can opt-out of receiving these communications by following the unsubscribe instructions provided in the email, by changing the notification settings in your profile via the App or by contacting us as set out below. Please note, you may continue to receive emails for approximately 10 business days before we are able to update your request.

SHARING OR DISCLOSING PERSONAL INFORMATION

If you use your Facebook account to register or sign-in to the App, we will receive information about your friends on Facebook if you explicitly allow us to access it. We will use this information to make friend suggestions in the App, but we will not store this information.

We offer an automatic import of your fitness activity information from other platforms such as Apple Watch, Apple HealthKit, Garmin, Polar and Suunto. You must explicitly agree to connect your account from those platforms to your JustMove account beforehand in order to import such data.

We share Personal Information with third parties if this is necessary to provide you a requested service; it is a request from a governmental authority, court ruling or required by law; if it is necessary to defend ourselves against any third-party claim or allegation; to protect the rights and safety of JustMove, our members and personnel; and/or if you have explicitly consented to this disclosure.

Your profile is fully visible to your friends on JustMove by default, however under your privacy settings of your profile you can limit your visibility to friends, only yourself or limit to race participants. Your name and profile photo are always visible to everyone. It is possible to share information through posts, likes and comments among the users of JustMove Products and this information will be automatically posted to the feed area.

SERVICE PROVIDERS AND THIRD PARTY LINKS

We share your Personal Information to others who help us provide and improve the JustMove Products (ex. Maintenance, analysis, audit, fraud detection, marketing and development). Service providers will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for any other purposes. These providers include, but are not limited to Google, Facebook and JustRun

JustMove analytics service providers may analyze engagement data for research purposes designed to provide a personalized experience. JustMove does not use information gained through service provider information for advertising or similar services. You can always stop JustMove from accessing your data by changing the settings of your mobile device.

We allow third parties to post links on the Site which we believe will be of interest to users. We do not endorse the security of these websites and encourage you to verify their privacy policy and security measures before using their services as we are unable to verify their level of security or practices.

Personal Information may be stored in the USA

INDIVIDUAL RIGHTS TO PERSONAL INFORMATION

You have the right to obtain a copy, update, and correct inaccuracies of your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may exercise these rights by writing to support@justmove.app. In responding to these requests, we may ask certain Personal Information for the purposes of verifying the identity of the individual seeking the details of their Personal Information.

LOCATION OF PERSONAL INFORMATION FOR EUROPEAN RESIDENTS

Personal Information captured on the App or the Site may be stored in the US and transferred to, stored or otherwise processed at a destination outside the European Economic Area (the “EEA”) including destinations not subject to the Data Privacy Provisions equivalent to those in the EEA countries in which you provided your Personal Information. We may transfer your Personal Information to any country in which we or any of our affiliates, subsidiaries, entities controlled by us, or our service providers are located, with your continued use of the JustMove Products. We shall perform all reasonable procedures required to ensure your Personal Information is processed and transferred safely.

RETENTION

JustMove retains your Personal Information for as long as you have an account with us. If you are an EU resident and you stop using our services without requesting we delete your Personal Information, your Personal Information will be deleted after account deletion. We will only retain Personal Information if it is legally necessary and for accounting purposes.

If you decide to delete your account, any details made public by you (eg. posts, routes, comments on other users’ profiles) will be anonymized, however JustMove reserves the right to use content such as photos and video in its marketing efforts

OTHER EUROPEAN USER RIGHTS

Under the General Data Protection Regulation (2016/679), if you are an EU resident and we are processing your Personal Information, you have the following rights:

To exercise any of these rights please contact us as outlined below and we will comply with your request where possible, within forty-five (45) days.

The legal basis on which we rely to process your Personal Information and data shall be:

CALIFORNIA RESIDENTS RIGHTS

Under the California Consumer Privacy Act (the “CCPA”) if you are a resident of the state of California and we are processing your Personal Information you have the following rights:

To exercise any of these rights please contact us as outlined below and we will comply with your request where possible, within forty-five (45) days.

CHANGES TO THE PRIVACY POLICY

This Policy may be updated periodically to reflect changes to our Personal Information practices. The revised Policy will be posted on the Site and the App. We strongly encourage you to refer to this Policy often for the latest information about our Personal Information practices.

CONTACTING US

Should you have any questions regarding this Policy or wish to exercise any of your rights as outlined in this Policy for your jurisdiction please write to us at: The Fintech Sport Group, 408 McGill Street, Montreal, QC, H2Y 2G1 or email us at support@justmove.app

LEGAL

JustMove, its service providers and third-party administrators or processors may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order which may include lawful access by Canadian or other foreign governmental authorities, courts, or law enforcement agencies to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian or other law.

We may also disclose Personal Information where necessary for the establishment, exercise or defense of legal claims, to detect, suppress or prevent fraud, and to investigate or prevent actual or suspected loss or harm to persons or property.