PRIVACY POLICY Last Updated: July 2023 1. ABOUT US 1.1 We are She’s Newsworthy Media Inc., a corporation incorporated under the federal laws of Canada (“She’s Newsworthy”, “we”,“us” or “our”). 1.2 1.2.1 We are the creators of and offer: a signature program that teaches and helps clients land media (“Media Coaching Program”); a signature program that teaches and helps journalists and public relations professionals their own coaching program for their own clients based on the Media Coaching Program (“Academy Program”); informational and education newsletters, resources and publications relating to media and public relations (“Publications”); and other media and public relations services. (collectively, the “Media Services”) 1.2.2 We also enable you to: find out more about She’s Newsworthy and our Media Services, book discovery calls and sign up for newsletters on our website at http://www.shesnewsworthy.com (“Website”); and receive Publications, review proposals for our Services, and enroll into and purchase our Services via our Third-Party Service Providers (“Third-Party Website”) (collectively, the “Web Services”) 1.2.3 The Media Services and Web Services shall collectively be referred to as the “Services.” 1.3 We also advertise and let the public know about our Services via ads on the internet and other web and mobile based applications, including but not limited to ads on Facebook, Instagram, Google Ads, etc. (“Ads”). 2. ABOUT OUR PRIVACY POLICY 2.1 This Privacy Policy applies to your access and use of our Services and your interaction with our Ads. We take great care to protect your personal information under applicable legislation. Before you start accessing the Services or interacting with our Ads, please take a moment to carefully read and understand this privacy policy (“Privacy Policy”), which tells you what personal information we collect about you, how we use that personal information, how this personal information may be shared, and what choices and rights you have with respect to this information. 2.2 This policy was originally written in English. To the extent a translated version conflicts with the English version, the English version governs. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control. 2.4 If you have questions or comments about this Privacy Policy, please contact us at: admin@shesnewsworthy.com 3. LEGAL BASES TO COLLECT, USE, SHARE AND OTHERWISE PROCESS INFORMATION We rely on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including: as necessary to provide the Services to you or to enable you to view or interact with our Ads. where you have consented to the processing of your personal information within our Services or the Ads; where necessary to comply with a legal obligation, such as a court order or to exercise or defend legal claims; to protect your vital interests, or those of others, such as in the case of emergencies; where necessary in the public interest; and where necessary for the purposes of our or a third party’s legitimate interests, such as those of our essential third-party service providers on whom we rely on in order to provide the Services or our Ads to you. 4. OUR LEGITIMATE INTERESTS The legitimate interests of She’s Newsworthy and our Third-Party Service Providers include: providing and improving our Services. We do so as it is necessary to provide our Services to you, and to keep developing and improving our Services. Enabling you to view and interact with our Ads. 5. INFORMATION WE COLLECT ABOUT YOU 5.1 When you use our Services or interact with our Ads we collect various types of personal information about you. Some of this information like email address, can be used to identify you (“Personally Identifying Information” or “PII”), and some of this information, like activity and log data, cannot be used to identify you (“Non-Personally Identifying Information” or “Non-PII”). 5.2 The amount and type of personal information we ask for depends on the nature of the interaction. We will only collect such personal information as is necessary or appropriate to fulfill the purpose of your requested use of our Services and interaction with our Ads. 5.3 We collect personal information in a few different ways, including personal information that you actively enter into a form (for example, when you enter your email address to book discovery calls, receive She’s Newsworthy Publications, or subscribe to our Publications), from third parties (for example, if you view our Ads on Facebook), and automatically when you use the Services (for example, when you browse our website or when you view our Ads on Facebook): 5.3.1 Information you provide us. We collect personal information that you provide us, including: Contact information: We collect personal information from you if you subscribe to our newsletter, book a discovery call, request to receive our Publications or interact with our Ads, including (i) your first name; (ii) your last name; (iii) your email address; and (iv) social media handle. Payment source information: If applicable, we collect certain personal information in order to process your subscription to our Services, such as billing address, credit card payment details, etc. Communications: When you communicate with us (via email, etc.), we store a copy of your communications, which may include your PII. 5.3.2 Information from third parties. We collect personal information that third parties provide us, including information from other third-party platforms, publicly available information, and information from our Third-Party Service Providers. Third-Party Platforms: If available, and if applicable, the Services may allow you to use single sign-on credentials that you had previously created with other third-party platforms, such as Google or Microsoft. If you access our Services via single sign-on with a third-party account, or if you view and interact with our Ads within a third-party application such as Facebook or Instagram, we will collect information that you have agreed to make available, such as your name, email address, public profile information, etc. This information is collected by the third-party platform and is provided to us under their privacy policies. The personal information we receive from these third-party platforms will generally be considered Personally Identifiable Information. You can generally control the information that we receive from these sources using the privacy settings in your third-party platform account. Publicly available information: We may collect information that you make available to the public, such as when you make a post about out Services on your Facebook page. 5.3.3 Information automatically collected when you use the Services We collect certain personal information automatically whenever you use the Services: Device information: We collect information that your device provides us in connection with your use of the Web Services or interaction with our Ads, such as your desktop device type, system language, browser type, IP address, etc. Cookies and similar tracking technology: We use cookies in connection with your use of the Web Services or interaction with our Ads to collect information related to what you see and interact with. Cookies are small files placed on your hard drive that assist us in providing our services. We may use cookies to collect usage information, determine our total audience size and traffic and determining which areas of our Website, Third-Party Website or our Ads are of greatest interest to users. Web Beacons/Pixel Tags. These are invisible tags may be placed certain screens of our Website, Third-Party Website or Ads. When you access these screens, pixel tags generate a notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous website visit. We may use web beacons to recognize users and access traffic patterns. 6. USE OF INFORMATION 6.1 In general, we use both Personally Identifiable Information and Non-Personally Identifiable Information in order to administer, operate and provide the Services and the Ads to you. 6.2 How we use your Personally Identifiable Information. We use your PII to: add you to our mailing list in accordance with applicable law; send you our newsletters and other information about She’s Newsworthy and our Services in accordance with applicable law; to provide you with the Services to provide you with notifications integral to the core offering of the Services that you are subscribed to or enrolled in; trouble shooting technical issues that you encounter; to analyze, evaluate and improve the functionality and experience of our Services; to respond to customer service inquiries when you contact us; to prevent fraud and to maintain a quality experience for our business purposes or legal reasons; to enforce any applicable terms of service and terms in any other agreement that may exist between you and She’s Newsworthy; to provide you with system or administrative messages relating to our Services; to let you know about new features or updates to our Privacy Policy; to send you information about your relationship with us; to send you marketing communications (where you have opted-in to receive such messages); to administer surveys (to the extent that you have opted-in to participate in these). 6.3 How we use your Non-Personally Identifiable Information. We use your Non-PII to: to analyze, evaluate and improve our Services, our Adds and your experience with us. to personalise your Services and Ads. 6.4 Aggregated Data. We may also produce or generate data, information or other materials in an aggregated and anonymous manner to derive statistical, performance, functional information related to the provision and operation of the Services and Ads and that are not identified as relating to a particular individual or company (such data, information and materials, the “Aggregated Data”). We may use Aggregated Data for any purpose and without restriction or obligation to you, including without limitation to improve and enhance our Services and Ads, provided that in all use instances She’s Newsworthy does not attempt to re-identify the identity of any individual or company user, as applicable, as the source of such Aggregated Data. 6.5 Any use of your personal information that is incompatible with these foregoing uses will be disclosed to you in advance so that you may opt out of such uses at your discretion. 7. SHARING YOUR INFORMATION 7.1 We will not rent or sell your personal information to anyone. If any of your personal information is shared or disclosed to third parties, it will only be in accordance with this Section. 7.2 Service Providers. We may share your personal information with third parties who provide services to us, including but not limited to discovery call booking by Squarespace Scheduling, email notifications and management by ConvertKit, analytics and reporting by Google Analytics and other similar service providers, proposal/contract management by Dubsado, e-commerce checkout by Thrivecart, etc. (“Third Party Service Providers”). For a list of current Third-Party Service Providers, please send us an email at admin@shesnewsworthy.com. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. Except as otherwise stated in this Privacy Policy, these Third-Party service providers are required not to use your information other than to provide the services requested by us. 7.3 Legal Requests. We cooperate with law enforcement inquiries and demands for personal information that are made under force of law. Therefore, we may disclose your information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations), in accordance with the applicable law (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding, in accordance with the applicable law (c) as otherwise required under any applicable law. 7.4 Protecting Rights. We may also disclose your personal information if we determine in good faith that disclosure is reasonably necessary or appropriate to protect the property rights of She’s Newsworthy, third parties, yourself or the public at large. 7.5 Related Business Affiliates. We may share your personal information with affiliates under common control with us, who are required to comply with the terms of this Privacy Policy with regards to your information. 7.6 Sale of Business. If we become involved in a business merger, acquisition, securities offering, bankruptcy, reorganization, dissolution or other similar transaction, we may share or transfer your personal information in connection with such transaction. If we do this, such disclosure will be subject to confidentiality arrangements that are typical of such transactions. 7.7 Marketing. We do not share your personal information with third parties for promotional purposes unless you have opted-in to such disclosure. If you have opted-in to have your information shared, you may choose to opt-out from receiving further communications from any third party that is not our agent or service provider at any time by contacting the marketing partner/affiliate directly. 7.8 FAQ/Knowledge Database. If you send us a request for information or support in relation to our Services, we reserve the right to publish the content of your request (with any PII removed) for the purposes of clarifying our Service for other users in a Frequently-Asked-Questions publication or knowledge database. 8. PROTECTING YOUR INFORMATION 8.1 We strive to protect your personal information. We use commercially reasonable administrative, technical, and physical measures to safeguard your personal information in our possession against loss, theft and unauthorized use, disclosure or modification. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. Our Third-Party Service Providers are reputable third-party service providers whose privacy, security, transparency and industry-specific standards are best-in-class. Our systems and databases are backed up regularly to help protect your information in case of an incontrollable catastrophe. 8.2 Unfortunately, no data transmission over the internet and no storage of data can be guaranteed to be 100% secure. Therefore, while we strive to make all reasonable efforts to use commercially acceptable means to protect your information, we cannot warrant the security of any personal information you transmit to us, and you acknowledge that there is always some risk when transmitting personal information to us through the Services or the Ads. 9. DATA RETENTION 9.1 Unless otherwise specified herein, your PII will generally be kept until you no longer wish to receive our Services or you ask us to delete it, whichever comes first. Notwithstanding the foregoing, we may however retain information to comply with the law, to prevent fraud, in accordance with this Privacy Policy, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce this Privacy Policy and take other actions permitted by law. The personal information we retain will, of course, be subject to this Privacy Policy. 9.2 Personal information about you that is no longer necessary and relevant to provide our Services or Ads to you may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to us, such as statistics related to the use of the Services. 10. MANAGING YOUR SETTINGS 10.1 Adjusting Notification and Email Preferences. If you originally subscribed or opted-in to receive newsletter or other marketing communications from us, you may unsubscribe by following the instructions contained at the bottom of each type of email. 10.2 Updating Account Information. You may correct, amend or update your PII by contacting us at admin@shesnewsworthy.com. 10.3 Deleting Information and Accounts. Subject to section 9.2, you may request that we delete your PII by contacting us at admin@shesnewsworthy.com. 11. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION Our Website and Third-Party Websites are hosted within the United States or Canada and is operated from within Canada. If you are located outside of the United States or Canada and choose to use the Services or provide personal information to us, you acknowledge and understand that your personal information will be transferred, processed and stored in the United States or Canada, as it is necessary to provide the Services. 12. CHILDREN The Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18 years of age. In the event that we learn that we have collected personal information from a child under 18 years of age, we will take appropriate steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us at admin@shesnewsworthy.com. 13. ADDITIONAL DETAILS Feedback. We welcome any feedback you may have as a potential or current member of the She’s Newsworthy community. Please feel free to send us comments, register a complaint, or ask questions about our Services. We may store your communications, including any personal information you include in them, so that we can effectively respond to you. Links To Other Websites. Our Website or Third-Party Website and other electronic communications that you may receive as part of the Services may contain links to other websites on the internet maintained by third parties. Clicking on a link to a third party site will make you leave out Website or Third-Party Website and go to the site you requested. We cannot control the activities of third parties. Therefore, we cannot accept responsibility for any use of your PII by such third parties, and we cannot guarantee that these third parties will adhere to the same privacy practices as ours. We encourage you to carefully review the privacy policies of any other service provider from whom you request services. 14. CHANGES IN THIS PRIVACY POLICY We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion, so please check back frequently. If we decide to change our privacy practices, we will post the changes to this Privacy Policy our Website, or by sending you an e-mail update, and/or any other places we deem appropriate so that you can be made aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. 15. QUESTIONS If you have questions about this Privacy Policy, please contact us at admin@shesnewsworthy.com.