Valid as of September, 2023.

Freebees^TM Loyalty Program (the « Program ») is provided by Superstar Communications, Inc. («Superstar Communications », «us », « we » and/or « our »).

Freebees commitment to the protection of privacy

Protecting the privacy and confidentiality of your Personal Information has always been a fundamental principle in our relationship with you and our Partners. This Privacy Pledge tells you how we will ensure the confidentiality and privacy of the information that you entrust us with. When you use the Platform, you entrust us with your personal data. We are committed to maintaining your trust. We therefore suggest that you explore our privacy practices together. This policy describes how Superstar Communications Inc. (“we”) collects, processes, uses and shares personal information and personal data about Freebees Members and users of the website https://www.freebeespay.com(“ the platform "). This policy applies regardless of how you use or access the Platform, including through mobile devices and applications. In this policy, the term “personal data” means any information which concerns a natural person and allows them to be identified. Capitalized terms used in this Policy but not defined have the meaning assigned to them in the General Terms of Use available on our website.

Use of Personal Information

In order to enable you to use the Platform and the services offered through the Platform, we need to collect and process personal data about you. The treatment is mainly based on the following principles:

• We need to process certain personal data in order to be able to provide you with services and enable you to use the Platform.
• We process your personal data based on your consent expressed upon acceptance of our terms of use.
• We may process certain personal data because you have specifically consented to the processing. You can always withdraw your consent and we will then cease processing your personal data based on your consent.

Personal Information means any information, including Sensitive Data, that is about an identified or identifiable individual, received or derived by Freebees and recorded in any form. Personal Information remains personal, even if it is otherwise public. Personal Information does not include information that was modified or sanitized so that it can no longer be used to directly or indirectly identify an individual (anonymous personal information).

Freebees collects Personal Information for the following purposes

We use personal data that is collected through the Platform for the purposes that are described below.

Communicating with you
We use the personal data you provide to us to communicate with you by email about your use of the Platform, but only if you have provided this data to us and if you agree to receive communications from us. We comply with current regulations regarding unwanted electronic communications. If you no longer wish to receive electronic communications from us, you can notify us at any time by writing to us at the following address: .

Communication with Partners
We may disclose your personal information within our group of companies or to our Partners for the purposes described in this policy and in accordance with applicable law (for example, to enable you to take advantage of certain promotions). Under no circumstances will information about your individual transactions be transmitted from one Freebees Partner to another.

Administer the Platform
We use your personal data for a variety of reasons related to the Platform. First, we want to offer you our programs, products and services to help you get the most out of our promotions. Next, we use your personal data to manage our business activities, including billing member and partner accounts. We also want to improve your experience by understanding your needs and preferences, and to develop, improve, market and deliver products and services that meet those needs.

Additionally, we use your personal information to administer the Freebees program and affiliates, as well as to manage member accounts by recording and updating Freebees money balances. We also process Freebees money exchanges by members and allow our members to take advantage of our partners' promotions.

Finally, we want to communicate promotions and information that are of interest to you, using the personal data we have collected to understand and analyze your responses, needs and preferences. All this is done while respecting the laws and regulations in force.

Maintenance of the Platform
We use data collected through the Platform and data from analytics tools to monitor users' use of the Platform generally, to prevent misuse of the Platform, to identify problems or bugs in the Platform and to determine features to be improved.

Aggregated form
We use data collected through the Platform, in an aggregate form that does not allow data to be associated with a particular person, computer or mobile device, to provide information to our service providers. We share with our specialists Platform usage statistics which are segmented using certain personal characteristics, without these characteristics being associated with a particular person.

The data we collect

Information that comes from you
We collect the information that you communicate to us (for example by filling out a form) through the Platform interface or otherwise. This information may include, but is not limited to:

• Your first and last name;
• Your email address;
• Your phone number;
• Your residential address;
• Your birthday;
• Transaction information

Here are additional details about the requested personal information:

Birthday date: We ask for this information since merchants have an option to give their customers a gift for their birthday, so it's basically to make it happen on the right day. You must also be 18 years an older to enroll in the Program.

Email address: In order to notify you of any changes to the Program, it is necessary to be able to share this information with you by email. You may also receive Partner offers and notices when balances in your account are used (if you wish to receive them).

Telephone number: This is a way to reach customers, for example, if their card has been lost and found. At no time otherwise you will be contacted by telephone and merchants do not have access to this information.

Address: As Members receive amounts of money as gifts when registering, this data makes it possible to ensure that the most appropriate amounts are given according to the proximity of the businesses with the Member. It is possible to simply enter the postal code in the first address line and select your city from the choices that will be offered.

From time to time, you may be asked to provide additional Personal Information. If you choose not to provide this information, it will not affect your ability to accumulate or spend Freebees money.

The Freebees Program will use this information from time to time to promote additional products, services and special offers from the Freebees Program and/or its Partners.

Data collected automatically
We collect certain information automatically during your use of the Platform. This information is recorded each time you interact with the Platform. The data collected includes certain information specific to your mobile device or your computer and data on your interaction with the Platform, in particular:

• The operating system and identification number of your computer or mobile device;
• The make and model of your computer or mobile device;
• The language of your computer or mobile device;
• The IP address from which your computer or mobile device accesses the Platform;
• The country, state, city and zip code where your computer or mobile device is located;
• Screens viewed, actions taken, number of connections to the Platform, date of connections to the Platform.
• The number of users, the number of visits to our website or to our Partners, demographic data or data on your consumption habits.

Data from analytics tools
When you access the Platform, we collect certain data from analysis tools such as Google Analytics. This data may include, for example, gender, age, interests. This data is not associated with you personally and is transmitted to us in aggregate form.

When you use a Freebees loyalty card, we also receive information that does not identify you. These data allow us to generate statistical reports on the number of users of the program, the number of visits to our website or our partners, demographics or consumer habits of Members, etc.

How are your personal data protected ?
Your personal data is hosted by our service provider, Microsoft Azure, which commits to us to use industry standard security measures to preserve the integrity and confidentiality of personal data.

Our employees and suppliers are informed of the confidential nature of the personal data that is collected through the Platform and are made aware of appropriate security measures to avoid unauthorized access to personal data.

Our Use of Your Personal Data and Other Information

We only share your personal data as described in this policy and when we have your consent. Your personal data may be communicated to the categories of people described below for the purposes mentioned.

Employees
The personal data collected is only accessible to our duly authorized managers, employees and subcontractors who must access it for the use provided for in this policy.

Partners
The personal data collected is not accessible to our partners, with the exception of the email address in certain cases, but may communicate with you for the use provided for in this policy.

We communicate personal data, in an aggregated form which does not allow the individuals concerned to be identified, with service providers responsible for advertising as well as the processing and management of Member transactions, studies, analyzes and communications. This data includes, in particular, statistics about our users, their usage habits of the Platform, the most popular offers and the effectiveness of electronic communications.

Legal obligations
We may also disclose collected personal data to third parties if expressly authorized or required by law, or if we are required to do so by a competent authority. We may disclose personal data in legal proceedings if necessary to protect our rights or those of our users.

Freebees Members can opt out of receiving marketing and promotional communications in electronic, printed or verbal format, other than Member Summaries, by writing to us at:

Freebees Customer Care
73 rue du Chinook
Gatineau, Québec, J9A 0A8

by email to ,
or by calling us at 1-888-509-0388.

The decision to opt out of additional communications does not affect the Member's ability to accumulate or spend Freebees money in the Freebees Program.

Privacy and Cookies. The Website uses several different types of "cookies"

Cookies are small files that websites put on your computer hard disk drive when you first visit.

Think of a cookie as an identification card that's uniquely yours. Its job is to notify the site when you've returned. While it is possible to misuse a cookie in cases where there is personal data in it, cookies by themselves are not malicious.

Many websites use cookies. Cookies tell us how often you visit pages, which helps us learn what information interests you. In this way, we can give you more of the content you like and less of the content you don't.

A "session cookie", which resides in memory and persists only as long as the browser is open. This cookie holds only the information that is uniquely generated when you log on to the site and persists only as long as your browser is open. This cookie makes your Freebees Member Account information available as you browse the Website. Upon your departure from the Website and closure of your browser, the information in the session cookie is removed from memory. In order for the Website's online Account Balance and Statements, Order Cards and Order Rewards features to function, you must enable the session cookies setting on your browser.

The Website will also set a cookie to remember your preferences to enhance your experience each time you visit the Website.

The Program collects anonymous information about Freebees Members to allow The Freebees Program and/or its Partners to personalize advertising that appears:

• On our website
• On other sites across the Internet
• On your Mobile phone via our App
• On your email address

Manage your notifications and cookies

If you want to block (disable) the notifications generated by the Partners, you can disable notifications in your mobile application or simply add Partners you do not want to receive notifications from to your "blacklist".

You can apply the same options for e-mailing via your Member account on our website or by choosing disabling options displayed at the bottom of messages.

If you do, please note that this will limit your experience on some websites, including the site freebeespay.com.

You can delete your cookies using your browser's controls after browsing the Website.

Business Transfers

In the event that the sale or restructuring of all or part of our company is considered, we may transmit the personal data collected to the people or organizations involved before and after the transaction, whether or not it takes place. In such a case, these people or organizations undertake to us to preserve the confidentiality of the personal data collected and to use them exclusively to evaluate the feasibility or advisability of the transaction as well as in accordance with this policy.

Your Rights

Subject to certain exemptions, you have the following rights in relation to the personal information we collect about you:

(A) Your right of access
Upon your written request, subject to certain exceptions, Freebees will inform you of the existence, use, and disclosure of your personal information and will provide you with a copy of that personal information within the timescales provided for by law. You have a right to access and rectify the information held about you. Please send any access requests to us using the contact information below.

(B) Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified.

(C) Your right to be delisted
You have the right to control the dissemination of your personal information. As such, you may request that we de-index (i.e., delist from search results) any hyperlinks associated with your name and that provide access to your Personal Information if the underlying dissemination of your Personal Information contravenes the law or a court order, or if it otherwise causes serious injury to your reputation or privacy. This also includes your right to re-index (i.e., list in search results) any hyperlinks associated with your name where doing so can prevent the perpetuation of a serious injury to your reputation or privacy.

You can contact us for assistance in changing, updating, or deleting personal information previously provided to Freebees.

(D) Your right to request information about data processing
You may contact us to request information about our data processing activities, namely what Personal Information was collected from you and how it is being processed by Freebees. You may ask us to clarify the categories of persons that have access to your Personal Information at Freebees and the applicable retention period for that information.

(E) Your right to withdraw consent, deactivate your account, or unsubscribe
If we rely on your consent (or explicit consent) as our legal basis for processing your Personal Information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you want to deactivate your account, please submit a request electronically or contact us at 1-888-509-0388.

If you do not want to continue to receive emails from Freebees, please follow the steps outlined below. Please note that every time we send you an email, we will give you the option to unsubscribe from our email list, so you'll be able to stop receiving our emails at any time.

Unsubscribe from our communications:

• Log in at freebeespay.com by entering your email address and password.
• In the “My Account” window, click on “Options”.
• Select or remove the notifications that you would like to receive or unsubscribe from newsletters.

(F) Your right to lodge a complaint with a privacy regulator
You have the right to make a complaint at any time to the relevant privacy regulator. In Canada, you can contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy commissioner for your province of residence. We would, however, appreciate the chance to deal with your concerns before you approach the relevant privacy regulator, so please contact us first.

Security

We take reasonable steps to protect the personal data provided via our Program and related services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

All collected Information may be shared with our agents or contractors, and we ensure that all shared Information can only be used in accordance with this Policy. If you access third-party Internet websites, this Policy does not apply since such Internet websites may independently solicit and collect your Information. We strongly encourage you to consult the privacy policy of all third-party Internet websites you visit.

As stated above, we collect and store your Information and strive to ensure that such collected Information is well safeguarded against unauthorized access, use, modification, theft or loss. However, we specifically and expressly disclaim and make no warranties as to any security breaches.

Changes to Our Privacy Policy

We may modify this policy from time to time to reflect changes in our personal data management practices. In the event that a modification is made, the new policy will be available through the Platform.

We will notify you of any material changes to our privacy policy by email within a reasonable time of the new policy coming into effect. Any notice will be sent to the email address you provided to us.

Other Terms and Conditions

Your access to and use of this Services is subject to our Terms & Conditions located at our website.

For any questions regarding the protection of personal data, please contact Mr. Hassen Khalifa by email at .

Superstar Communications Inc.
73 rue du Chinook
Gatineau (Québec) J9A 0A8