Kouvre Privacy Policy

"App" means the Kouvre mobile application and associated digital platforms.

"Member" (also "you", "your") refers to a consumer who has registered an account on the App.

"Merchant" means an independent, third-party business that utilizes the App to host its loyalty program.

"Personal Information" means any information which relates to a natural person and allows that person to be identified directly or indirectly.

In accordance with Law 25, Kouvre has designated a Person in Charge of the Protection of Personal Information (the "Privacy Officer"). The Privacy Officer is responsible for ensuring Kouvre's compliance with this Privacy Policy and applicable privacy legislation. You may contact the Privacy Officer at: privacy@kouvre.com.

We collect only the Personal Information strictly necessary to provide the App's functionality and facilitate Merchant loyalty programs.

Account Registration Data: To create an account, you must provide your First Name and an Email Address. Alternatively, you may authenticate via third-party services (e.g., Apple Sign-In or Google Sign-In), in which case we collect the authentication tokens and email addresses provided by those platforms. We acknowledge that Apple Sign-In users may utilize the "Hide My Email" relay service. We do not require or collect your Last Name or Phone Number.

Optional Profile Data: You may optionally provide your Date of Birth for the purpose of receiving birthday-related Rewards Milestones.

Transaction and Loyalty Data: We collect data regarding your interactions with Merchants, including timestamps of QR code scans, transaction totals (for calculating Points), Points accrued, and Rewards Milestones redeemed.

Geolocation Data (Off by Default): In accordance with Law 25's "privacy by default" mandate, any GPS or location-tracking features within the App are deactivated by default. If you explicitly opt-in to location services to discover nearby Merchants, your location data is processed locally on your device to display eligible rewards and is not stored in our databases.

We use your Personal Information to:

• Create, maintain, and secure your Kouvre account and facilitate account recovery.
• Generate your Digital Cards and track your Points balances and Rewards Milestones.
• Provide your First Name to Merchant employees at the physical counter upon scanning your Digital Card, strictly for the purpose of personal recognition and customer service.
• Analyze aggregated, de-identified data to improve App functionality, using third-party analytics providers subject to strict confidentiality agreements.

5.1 Strict Data Siloing: Kouvre acts as an intermediary. When you join a Merchant's loyalty program via the App, the Merchant does not receive direct access to your personal profile, your email address, or your Date of Birth.

5.2 Permitted Disclosures to Merchants: Merchants are only permitted to view:

• Your First Name (displayed exclusively at the counter via the Merchant-facing system when your Digital Card is scanned).
• Fully aggregated and anonymized statistical data (e.g., total number of program members, total Points issued system-wide, total Rewards Milestones claimed).

5.3 Merchant Communications: If a Merchant wishes to run promotional campaigns or distribute offers, Kouvre's proprietary system handles the delivery of these campaigns to eligible Members. At no point is the Member's contact information transferred to or possessed by the Merchant.

Email Marketing: In compliance with Canada's Anti-Spam Legislation (CASL), consent for promotional emails is strictly "opt-in." The toggle to receive marketing emails is disabled (unchecked) by default upon account creation. If you choose to enable it, you may withdraw your consent at any time by clicking the "unsubscribe" link in any promotional email.

Push Notifications: We may request your permission to send push notifications regarding point accumulations, milestone achievements, or local offers. You may opt-in during account creation and may revoke this permission at any time via your mobile device's operating system settings.

We retain your Personal Information only as long as necessary to fulfill the purposes outlined in this Privacy Policy.

Inactivity: If your account remains inactive for twelve (12) consecutive months, your Digital Cards and Points will expire (as per our Rewards Terms). Following prolonged inactivity, Kouvre will routinely purge inactive Personal Information in accordance with our data retention schedule.

Account Deletion: If you formally request the deletion of your account via the App settings, we will permanently delete or anonymize your Personal Information, save for any transactional records we are legally required to retain for tax, audit, or anti-fraud purposes.

Under Quebec law, you possess the right to:

• Access the Personal Information Kouvre holds about you.
• Rectify any inaccurate, incomplete, or ambiguous Personal Information.
• Withdraw your consent to the communication or use of your Personal Information (which may require the deletion of your account).
• Data Portability (where applicable under the phased rollout of Law 25 regulations).

To exercise any of these rights, please submit a written request to the Privacy Officer at privacy@kouvre.com. We will respond to your request within thirty (30) days.