STARBEM INC.

PRIVACY POLICY

Privacy is of utmost importance for STARBEM INC. This Privacy Policy describes how STARBEM (“us”, “our” or “we”) may collect, use, and share your Personal Information.

“Personal Information” refers to any information that can be used, either alone or in combination with other information, to identify you.

Scope of this Privacy Policy

This Privacy Policy only applies to the collection, use and sharing of Personal Information by STARBEM on https://starbem.ca/ and https://marketing.starbem.ca/ (the “Websites”), on the Starbem platform (the “Platform”), and when you interact with us. STARBEM is a technology company, which provides an online marketplace for wellness services that allows those seeking such services to easily find and connect with those providing such services. It does not apply to the collection, use, retention, disposal, destruction or protection of the Personal Information by Providers (as defined in our Terms of Use) through the Platform. Providers providing services on the Platform are responsible for the Personal Information they collect, use, share, store, retain and process. As such, you may contact the Providers you consult directly in order to obtain information on how they will manage your Personal Information.

For any other information about this Privacy Policy or our privacy practices, please contact us at contactus@starbem.app.

WHAT PERSONAL INFORMATION DO WE COLLECT?

• I. When visiting or using the Websites

When visiting our Websites, we may collect the following Personal Information:

• * Your name and contact information (email and phone number) and the contents of your message, when you contact us via our online form or by email in order to respond to your message;

• II. When using the Platform as a customer

In order to create an account to use the services on the Platform, we collect the following Personal Information:

• * Full name;
• * Email;
• * Phone number;
• * Gender;
• * Date of birth;
• * Payment Information;

We may also collect and de-identify information about how our Services are used, such as usage data, product interaction, device ID, diagnostics, performance and crash data, in order to improve our services.

From time to time, we may request other Personal Information. For example, after your use our Platform, you may be asked to complete a survey regarding your use of the services on the Platform, which we collect and use to improve our services.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

submitting any Personal Information. However, our Websites use technology called “cookies” as well as other similar tracking tools. The tools are elements of data that our Websites can send to your browser, which may then be stored on your hard drive so we can recognize you when you return.

We use the information, in aggregate form which we cannot use to identify you, to help us understand activity on our Websites including traffic, to personalize the Websites according to your preferences, and to monitor and improve our products and services and our Websites for customer needs and interests. We may also use this information for statistical analysis purposes. We may also use this information to promote our services through marketing and advertising. STARBEM uses cookies and similar technologies, such as pixels and tags, to ensure that the services provided are in accordance with the best standard expected by the user.

STARBEM uses specialized companies for advertising, both within and outside the Platform, such as Google and Facebook. Please visit these third-party advertisers’ websites to review their privacy policies and how they manage their cookies, beacons and/or pixels, and for information on how to opt-out of some of these practices:

• * Google Analytics is a web analytics service that provides statistics and analytical tools for tracking and marketing purposes. We use Google Analytics on our Websites to analyze how users use the Websites, and to serve relevant advertisements to you on other websites. Google Analytics may collect information such as user location as inferred from IP address, the amount of time a visitor spends on our Websites, which pages are more frequently accessed, how the Websites are accessed (either directly, a search engine, or from a link), what sort of software is used (e.g. operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/ .

For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/ .

• * We also work with Meta (Facebook) to collect data that helps us track conversions from Facebook or Instagram ads, optimize ads, build targeted audiences and remarket users. Meta provides us with aggregate and/or de-identified data that cannot identify you (which may include general demographics and interests) about ads and commercial content these individuals engage with, when they engage with these ads and content, where such ads and content are posted. We then obtain some information on conversion (when someone views ads and content and takes a certain action, e.g. conversions). For more information on Facebook’s and Instagram’s advertising tools and your options to opt-out, please visit Facebook: https://www.facebook.com/policies/cookies .

You can withdraw your consent to our use of cookies or prevent third-party websites from accessing our cookies through the privacy settings on your browser. However, opting-out of our cookies may disable some of our Websites’ and Platform’s features and functionalities, and may prevent us from providing you with the information and services you have requested.

HOW WE MAY USE YOUR PERSONAL INFORMATION We will use your Personal Information for the following purposes, including to:

• * Create and manage your account;
• * Personalize and improve user experience on our Websites and on the Platform;
• * Respond to inquiries;
• * Process payment for services and to issue invoices;
• * Send communications concerning your account, our operations and with your prior consent, some promotions we may offer;
• * Provide access to our services, our Websites and our Platform;
• * In de-identified and/or aggregate form, develop, improve, and maintain our services and our Websites and Platform through research and development;
• * In de-identified and/or aggregate form, create analytics and business intelligence;
• * Manage our operations;
• * Comply with our obligations under applicable law;
• * Manage claims with and between customers, Providers, STARBEM, individuals and/or third-parties;
• * Prevent and remediate breaches of our agreements and our General Terms and Conditions of Use;
• * Prevent fraud;
• * With prior express consent, publish testimonials from our Customers;
• * Conduct internal audits or investigations.

HOW IS THE PERSONAL INFORMATION STORED AND PROTECTED?

We consider the security of all Personal Information to be our priority.

We use reasonable and appropriate security measures to protect Personal Information against unauthorized use, loss, access, modification, destruction or disclosure while it is in our custody or under our control. These measures include physical, organizational and technological measures that are proportionate to the quantity and sensitivity of the Personal Information.

Although any protection system is subject to flaws and possible breaches that may lead to data leaks, we always seek to prevent this from happening by adopting a high level of protection, certified by companies specialized in security.

The information and Personal Information are stored in STARBEM's database and will only be accessed by duly authorized companies and professionals.

Furthermore, all Personal Information is stored in an encrypted form. The information is protected with SSL (Secure Socket Layer) technology so that the Personal Information remains confidential. Additionally, this technology aims to prevent information from being transmitted or accessed by unauthorized third parties.

FOR HOW LONG DO WE KEEP STORED PERSONAL INFORMATION?

Except as required by law, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, or meeting any legal or regulatory requirements.

For instance, STARBEM will retain your Personal Information as long as you maintain an active registration on the Platform, as the Personal Information is necessary for the execution of the services offered.

In case of an eventual deletion request made by the USER or after deactivation of the registration with STARBEM, their identifiable Personal Data will be eliminated. However, it is worth noting that STARBEM may keep the USER'S Personal Information, even after a deletion request, to comply with a legal obligation that requires the storage and maintenance of such information. Additionally, the Personal Information may be kept in anonymized form for the purpose of study and implementation of improvements on the Platform.

WITH WHOM DO WE SHARE YOUR PERSONAL Information?

In the course of our activities and for the same purposes as those listed in this Privacy Policy, your Personal Information can be accessed by, shared with, or transferred to the following categories of recipients on a need-to-know basis to achieve such purposes:

• * Service Providers

STARBEM may share Personal Information with third-party service providers to the extent that such information is necessary for the provision of the services we offer, which is done under the guidance and on behalf of STARBEM. These third-party service providers may have been retained, for example, to provide support, assist in resolving technical issues, perform information verification and fraud prevention, assess and manage risks, among others, to the users.

• * In the event of a business transaction

Your Personal Information may be transferred in the event of a business transaction (e.g. merger, acquisition) to the buyer, assignee or transferee. Your Personal Information will remained protected in accordance with this Privacy Policy, or, should any change be made to the processing of your Personal Information, you will be notified through this Website.

• * To comply with our legal obligations

Finally, we may also disclose your Personal Information to a third-party if we are required to do so to comply with any court order, law (e.g. in the case of significant adverse events), or legal process, including responding to any government or regulatory request, in accordance with applicable law, or when we believe disclosure is necessary or appropriate to protect our rights, property, or safety or the rights, property or safety of our customers, or others.

• * With your prior express consent

We may share your Personal Information with a third-party if we have your prior express consent.

When required by law, prior to any transfer of Personal Information, we ensure to have agreements in place that third-parties only use Personal Information as necessary and for the agreed upon purpose, to protect the Personal Information with security safeguards appropriate to the sensitivity of the information, and not to disclose it except as may be permitted by us, as required by law, or as stated in this Privacy Policy.

LINKS TO THIRD-PARTY SITES FOUND ON OUR WEBSITES OR PLATFORM

Our Websites or our Platform may include links to third-party websites as well as content and applications hosted and served by third-parties. Clicking on those links may allow the third-party to collect or share Personal Information about you. If you follow a link to a third-party website, please refer to the third-party’s privacy notice for information on the type of Personal Information it collects, and how it uses or discloses it. We do not endorse and are not responsible for the information or privacy practices of websites or services owned by third parties.

YOUR CHOICES

At any time, you may make the following choices related to the Personal Information we hold about you:

• 1. Access, Correct or Update Personal Information:
• * At any time, you may request access to any of your Personal Information that we hold, subject to limited exceptions prescribed by law, such as any Personal Information about another individual that cannot be separated from yours, any information subject to solicitor-client privilege, commercially confidential information, information that may threaten life or security of an individual, or information collected for purposes related to an investigation of a breach of an agreement or contravention of law. You may request information on the types of Personal Information we hold about you, what it is being used for, and with whom it has been shared. You may also request the correction of any inaccurate, outdated or incomplete information related to you.

• 2. Withdraw consent to the processing of Personal Information:
• * You may “opt-out” or withdraw your consent at any time to the collection, use, disclosure or any other form of processing of your Personal Information.

• 3. Marketing communications:
• * If you have consented to receive promotional emails from us, you may withdraw your consent to receive such communications at any time by using the unsubscribe link we include in marketing emails. You may also opt-out of our use of your Personal Information for marketing purposes by contacting us using the contact information provided below. Please note that, even if you unsubscribe to such communications, we may contact you for other service-related purpose and update permitted by law.

Please note that in some cases, if you contact us to exercise any of your rights regarding your Personal Information, we may not be able to fulfill your request, in part or completely, as these rights are subject to specific requirements or limitations under applicable law.

If we cannot accommodate a request, we will provide you with a justification. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service.

In order to assist with your request, we may ask you for sufficient information to allow us to confirm your identity, that you have authority to make the request, and to confirm the details of the request.

As stated above, Providers providing services on the Platform are responsible for the Personal Information they collect, use, share, store, retain and process. As such, if you would like to access your personal health information, you may contact the Providers you consult directly.

LOCATION OF YOUR PERSONAL INFORMATION

The Personal Information we collect may be stored and processed in jurisdictions outside of your province of residence and outside of Canada, by STARBEM or its service providers. Please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is stored, including lawful access. If your Personal Information is transferred outside of your jurisdiction, we will take steps to ensure your information is adequately protected in accordance with applicable privacy and data protection laws.

CONTACT US

You may contact our Privacy Officer if you have any questions or complaints regarding our privacy practices or this Privacy Policy, or if you would like to exercise any of your choices regarding the Personal Information we hold about you. You may contact our Privacy Officer at the contact information below:

dpo@starbem.app.

UPDATES TO THE PRIVACY POLICY

We may make changes to this Privacy Policy at any time by posting a new version to our Websites and on our Platform. If required by law, we will notify you in another manner that is likely to come to your attention.

The effective date of this Privacy Policy is indicated at the top of this page.