Privacy Policy

Updated July 18, 2025
TechPOS International Corp. (“TechPOS”, “We”, “Us”) has created this privacy policy (“Policy”) in order to set out
how we collect, use, and disclose information about identifiable individuals (“Personal Information”) through the
TechPOS Platform and related Services (as those terms are defined in our Terms of Use).
TechPOS Platform is a customer relationship management and content management software-as-a-service
platform which allows cannabis retailers and producers (our “Clients”) to manage product content and monitor
their customers’ (“Customers”) purchase patterns and preferences, review meaningful analytics, and help retailers
to better cater their services to their customers. The Platform integrates into any point-of-sale system to collect
customer information and report it to Us to be aggregated and anonymized into usable statistics.
The privacy of our users is of great importance to us. By visiting our website located at TechPOS.ca or by using our
Platform or the Services in any manner, you acknowledge that you accept the practices and policies outlined in this
Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance
with this Policy.

1. WHAT DOES THIS POLICY COVER?
This Policy covers our collection, use and disclosure of Personal Information. This Policy does not apply to the
practices of companies that we do not own or control. We do not knowingly collect or solicit Personal Information
from anyone under the age of 18 or knowingly allow such persons to register for the Services. Our Clients are
responsible for maintaining their own privacy policies governing the collection, use and disclosure of Customer
Personal Information.

2. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
2.1 TechPOS Account Information
In order to use certain aspects of the Services, users may be required to have a valid TechPOS account to log in to
the Platform (“Account”). When you register for the Services, TechPOS collects Your Account username and
password in order to authenticate Your Account access and provide You with access to the Services.
2.2 Customer Information
In order to provide the Services to our Clients, TechPOS collects Personal Information about Customers from our
Clients including, but not limited to the following (collectively “Customer Data”):

  • Full name, email address, and phone number
  • Cannabis usage habits and preferences

We do not collect protected health information or other sensitive data. The information we do collect is used by
our Clients to manage their customer relationships and provide product recommendations. TechPOS stores and
processes this Customer Data on behalf of our Clients.
All Customer Data collected by the Platform is aggregated and anonymized by Us to create statistical data
(“Statistical Data”) which we use to provide insights to cannabis producers and our other business partners,
including statistics about the demographics of Customers; and cannabis usage data and preferences. For greater
certainty, Statistical Data does not include any Personal Information.

2.3 Usage Data
TechPOS may also collect certain information from or about users of the Website and Services, such as Internet
addresses, time spent logged into the Services and other site and service usage data. This information is logged to
help diagnose technical problems, and to administer our Website and Services including to constantly improve the
quality of the Services.

2.4 Cookies and Related Technologies
Technologies such as cookies, tracking pixels, beacons, scripts, and tags are used by us and our third-party
partners. These technologies are used in analyzing trends, administering the website, tracking users’ movements
around the Website or Platform, and gathering demographic information about our user base as a whole. We may
receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Various browsers may offer their own management tools for removing these types of tracking technologies.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two
flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your
computer when you close your browser software or turn off your computer. Persistent cookies remain on your
computer after you’ve closed your browser or turned off your computer. They include such information as a
unique identifier for your browser.
TechPOS uses session cookies containing encrypted information to allow the system to uniquely identify you while
you are logged in. This information allows TechPOS to process your online transactions and requests. Session
cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the
Service.
TechPOS uses persistent cookies that only TechPOS can read and use, to identify the fact that you are a TechPOS
user. We are especially careful about the security and confidentiality of the information stored in persistent
cookies. Users who disable their web browser’s ability to accept cookies will be able to browse our Website but
may not be able to use all features of our Service.
With Client consent, TechPOS may use tracking pixels and related technologies to provide personalized Customer
content on the menu portion of Clients’ websites and to facilitate advertising targeted to Customers on other
websites. TechPOS may share data derived from emails and other online identifiers collected on Client websites
with our advertising partners. This allows our partners to recognize and deliver ads to Customers regarding their
products and services across devices and browsers. Where tracking pixels are used, Client is responsible for
ensuring that its privacy policy contains all appropriate disclosures and consents.

3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
TechPOS stores data, including Personal Information, on servers located in Canada. By submitting information, you
agree to this transfer, storing or processing of your Personal Information in Canada. You acknowledge and agree
that your Personal Information may be accessible to law enforcement and governmental agencies in Canada under
lawful access regimes or court order.
If you are accessing our Services from outside of Canada, please be aware that your information will be transferred
to, stored, and processed in Canada where our servers are located. We take appropriate safeguards to ensure that
your data is protected.

4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Disclosure of Statistical Data
TechPOS discloses Statistical Data to its partners and clients, such as cannabis producers and other third parties,
who may use the data for business purposes. This information does not include any Personal Information or
otherwise identify any individual Customers.

4.2 Service Providers and Business Partners
We may from time to time employ other companies and people to perform tasks on our behalf and need to share
Customer Data with them to provide the Services to you. Unless we tell you differently, such third parties do not
have any right to use the Personal Information we share with them beyond what is necessary to assist us. This
includes third party companies and individuals employed by us to facilitate our Services, including the provision of
maintenance services, database management, Web analytics and general improvement of the Services, and
businesses who engage our Services (to the extent provided for above).

4.3 Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through
some other change of control, Personal Information may be made available or otherwise transferred to the new
controlling entity, where permitted under applicable law.

4.4 With Your Consent
If we need to use or disclose any Personal Information in a way not identified in this Policy, we will notify you
and/or obtain your express consent as required under applicable privacy laws.

5. RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as
required by law, which may extend beyond the termination of our relationship with you. We may retain certain
data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of
aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal
Information will remain subject to the terms of this Policy.

6. ACCESS, CORRECTION, AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal
Information we have collected in respect to you and to have a general account of our uses of that information.
Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in
certain limited circumstances, and as permitted under law, we may not be able to make all relevant information
available to you, such as where that information also pertains to another user. In such circumstances, we will
provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and
modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will
provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As
appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to
disclose your information. Having accurate Personal Information about you enables us to give you the best
possible service.

7. CHANGES TO THIS POLICY
We may amend this Policy from time to time. Use of Personal Information we collect is subject to the Policy in
effect at the time such information is collected, used or disclosed. If we make material changes or changes in the
way we use Personal Information, we will notify you by posting an announcement on our Website, the Platform or
otherwise through the Services or by sending you an email prior to the change becoming effective. You are bound
by any changes to the Policy when you access or use the Website, Platform or Services after such changes have
been first posted.

8. ADDITIONAL INFORMATION
Questions regarding this Policy or privacy practices of TechPOS should be directed to privacy@techpos.ca or by
using our contact form https://techpos.ca/get-connected/ and marking it for the attention of our Privacy Officer.

Internal Employee Policy

Updated July 18, 2025
1. PURPOSE
This policy outlines how TechPOS employees must handle personal information in accordance with privacy laws
and internal security standards. All employees are required to follow this policy when accessing or processing any
personal information, whether it belongs to customers, clients, or coworkers.
2. SCOPE
This policy applies to all employees, contractors, and service providers who access personal information through
TechPOS systems, platforms, or tools.
3. DEFINITIONS
Personal Information: Any information about an identifiable individual, such as name, email, phone number, or
purchase history.
Customer Data: Personal Information about customers collected by TechPOS on behalf of our clients.
Confidential Information: Any internal business information not meant for public disclosure.
4. COLLECTION AND ACCESS
Employees must only access the personal information necessary to perform their job functions. Access to
customer or employee data must be logged and monitored. Unauthorized access, use, or disclosure is strictly
prohibited.
5. USE OF PERSONAL INFORMATION
Personal information must be used only for legitimate business purposes, such as supporting clients, fulfilling
service obligations, or troubleshooting issues. It must not be used for personal gain, shared informally, or stored
on unapproved devices or systems.
6. DATA PROTECTION
All devices must be secured with passwords and encryption where applicable. Personal data must not be stored on
personal devices or outside of approved platforms (e.g., avoid emailing spreadsheets to personal accounts). Any
printed materials containing personal information must be securely stored or shredded.
7. SHARINGA ND DISCLOSURE
Do not share personal data with unauthorized team members or third parties. Any sharing of personal information
must be done through approved secure channels and only when necessary. All third-party vendors must have
appropriate privacy agreements in place.
8. DATA RETENTION AND DISPOSAL
Retain data only for as long as required to fulfill business purposes or comply with legal obligations. Dispose of
personal information securely when no longer needed — use document shredders, secure deletion software, or IT
approved disposal methods.
9. TRAININGA ND ACCOUNTABLITY
All employees must complete privacy and data security training annually. Violation of this policy may result in
disciplinary action, up to and including termination.
10. ADDITIONAL INFORMATION

Questions regarding this Policy or privacy practices of TechPOS should be directed to privacy@techpos.ca or by
using our contact form https://techpos.ca/get-connected/ and marking it for the attention of our Privacy Officer.