WHIP BAY INC. PRIVACY POLICY

WHIP Bay Inc. (the “Company”) is committed to maintaining robust privacy protections for its users. Our

the information you provide to us and to assist you in making informed decisions when using our Service.

For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at

www.whipbay.ca.

“Service” refers to the Company’s services accessed via the Site, in which users can submit vehicle data

to view personal analytics as well as aggregated, anonymous analytics of other users.

The terms “we,” “us,” and “our” refer to the Company.

“You” refers to you, as a user of our Site or our Service.

By accessing our Site or our Service, you accept our Privacy Policy and Terms and Conditions, and you

consent to our collection, storage, use and disclosure of your Personal Information as described in this

I. INFORMATION WE COLLECT

We collect both "Non-Personal Information" and "Personal Information." Non-Personal Information

includes data that cannot personally identify you, such as aggregated usage data and general

demographic information. This may include location data provided during registration, which is used solely

for generating area statistics and does not directly identify individual users. Personal Information

encompasses your name, email, phone number, and dealership license number. All information submitted

during the registration process on the Site is collected in accordance with this Privacy Policy.

1. Information collected via Technology

The Company does not use cookies or similar tracking technologies to collect personal information. We

do not track users' browsing activities on our Site or across third-party websites. We rely solely on the

information provided by users during the registration process to deliver our Service.

2. Information you provide us by registering for an account

To become a subscriber to the Service you will need to create an account. In order to register for an

account and access our Service, we require certain personal information from you. This includes your

name, email address, phone number, dealership name, license number, and address. Your name and

email address are used to create and manage your account, while your dealership information is

necessary for verification purposes. Additionally, your dealership license number is required to confirm

your eligibility to use our Service. We collect this information to provide you with access to our Service

and to communicate with you regarding your account and our services. By registering, you are authorizing

us to collect, store and use this information in accordance with this Privacy Policy.

3. Children’s Privacy

The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly

collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign

up for the Service. In the event that we learn that we have gathered personal information from anyone

under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as

possible. If you believe we have collected such information, please contact us at admin@whipbay.ca.

II. HOW WE USE AND SHARE INFORMATION

Personal Information:

Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for

marketing purposes your Personal Information with third parties without your consent. We do share

Personal Information with vendors who are performing services for the Company, such as the servers for

our email communications who are provided access to the user's email address for purposes of sending

emails from us. Those vendors use your Personal Information only as necessary to provide services to

the Company.

In general, the Personal Information you provide to us is used to help us communicate with you. For

example, we use Personal Information to contact users in response to questions, solicit feedback from

users, provide technical support, and inform users about promotional offers.

We may share Personal Information with outside parties if we have a good-faith belief that access, use,

preservation or disclosure of the information is reasonably necessary to meet any applicable legal

process or enforceable governmental request; to enforce applicable Terms of Service, including

investigation of potential violations; address fraud, security or technical concerns; or to protect against

harm to the rights, property, or safety of our users or the public as required or permitted by law.

Non-Personal Information:

In general, we use Non-Personal Information to help us improve the Service and customize the user

experience. We also aggregate Non-Personal Information in order to track trends and analyze use

patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal

Information and we reserve the right to use and disclose such Non-Personal Information to our partners,

advertisers and other third parties at our discretion.

Analytics and Aggregate Statistics:

We use the data submitted by users to generate personalized analytics, which are presented back to the

respective users. These analytics provide insights and statistics based on the data provided, allowing

users to better understand their own usage patterns or trends.

Additionally, we aggregate data from all our users to generate area statistics. These area statistics

provide aggregated insights on a broader scale, allowing users to compare their individual statistics to

those of a given area or radius. It's important to note that the area statistics are presented anonymously

and do not reveal the specific data submitted by individual users. They are presented in aggregate form to

provide generalized insights and trends.

We retain the data submitted by users for the area insights and trends we present, even after users have

deactivated their service. This retention ensures that the presented area data remains consistent over

time. However, users can request to have their submissions removed after they cancel their subscription,

or they can delete their submissions while they have access to the Site.

The generation of analytics and area statistics helps us improve our Service and customize the user

experience. This Privacy Policy applies to the collection, use, and sharing of both individual analytics and

aggregate statistics in accordance with the principles outlined herein.

Business Transfers:

In the event of a business transaction such as a merger, acquisition, or sale of assets, your Personal

Information may be among the transferred assets. While we cannot control how the acquiring entity may

handle your Personal Information, we will take reasonable steps to ensure the protection and

confidentiality of your information, in accordance with applicable privacy laws.

If our information practices change at any time in the future, we will post the policy changes to the Site so

that you may opt out of the new information practices. We suggest that you check the Site periodically if

you are concerned about how your information is used.

III. HOW WE PROTECT INFORMATION

We implement security measures designed to protect your information from unauthorized access. Your

account is protected by your account password and we urge you to take steps to keep your personal

information safe by not disclosing your password and by logging out of your account after each use. We

further protect your information from potential security breaches by implementing certain technological

security measures including encryption, firewalls and secure socket layer technology. However, these

measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by

breach of such firewalls and secure server software. While we implement security measures designed to

protect your information from unauthorized access, it's important to note that no method of transmission

over the internet is 100% secure. By using our Service, you acknowledge that you understand and agree

to assume these risks.

IV. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION

Under applicable data protection laws, you have the right to access and correct your personal information.

You may also withdraw consent for its use or disclosure. You can make such requests by contacting us at

admin@whipbay.ca. If we cannot fulfill your request, we will provide reasons for denial. If you believe we

have not complied with data protection laws, you may lodge a complaint with us or the appropriate

authority.

You have the right at any time to prevent us from contacting you for marketing purposes. When we send

a promotional communication to a user, the user can opt out of further promotional communications by

following the unsubscribe instructions provided in each promotional email. Please note that

notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the

Account page of the Site, we may continue to send you administrative emails including, for example,

periodic updates to our Privacy Policy.

V. LINKS TO OTHER WEBSITES

As part of the Service, we do not provide links to other websites or applications. Therefore, this Privacy

Policy applies solely to information collected by us through the Site and the Service. We do not assume

responsibility for the privacy practices employed by other websites or applications.

VI. CHANGES TO OUR PRIVACY POLICY

The Company reserves the right to change this policy and our Terms and Conditions at any time. We will

notify you of significant changes to our Privacy Policy and effective date by sending a notice to the

primary email address specified in your account or by placing a prominent notice on our site. Your

ongoing use of the Sites after an update to this Policy signifies your acknowledgment that you have read,

understood, and accepted the latest version of the Policy. Non-material changes or clarifications will take

effect immediately. We also suggest that you check the Site periodically for any updates to this privacy

page. If our information practices change at any time in the future, we will post the policy changes to the

Site so that you may opt out of the new information practices.

VII. CONTACT US

If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by

sending an email to admin@whipbay.ca.

Last Updated: May 24, 2024