WEBSITE PRIVACY POLICY

LAST UPDATE: AUGUST 2024

Shop the LEWK Ltd. (“LEWK”, “we”, or “us”) respects your privacy and is committed to protecting the

personal information you may provide to us while using our website or by otherwise voluntarily

interacting with us.

The purpose of this privacy policy is to inform you about our privacy practices, including how we collect,

use and disclose your personal information (the “Policy”). This Policy applies to our website located at

https://www.shopthelewk.com/ (the “Website”).

Please review the Policy carefully. By submitting your personal information to us, by using our website,

or by voluntarily interacting with us, you consent to our collecting, using and disclosing your personal

information as set out in this Policy, as revised from time to time.

Your continued use of our website following the posting of any amendment to this Policy and, as

applicable following the dissemination of a notice to inform you of those changes, shall constitute your

acceptance of such amendment.

WHAT IS IN THIS PRIVACY POLICY?

▪ Meaning of Personal Information

▪ Your Consent to Collection, Use and Disclosure

▪ Personal Information We Collect

▪ Aggregated and Anonymized Information We Collect

▪ How We Use Your Personal Information

▪ How We Share Your Personal Information

▪ Retention of Personal Information

▪ Third Party Websites and Services

▪ International Transfer and Storage of Information

▪ Information Security

▪ Accessing and Updating Your Personal Information

▪ Opting Out of Communications

▪ Children’s Information

▪ Privacy Policy Updates

▪ Contact Us

MEANING OF PERSONAL INFORMATION

"Personal information" means recorded information that is reasonably capable of identifying an

individual. This information may include, but is not limited to, your name, date of birth, mailing address,

e-mail address, and telephone number. It may also include information that, when used in combination

with other information allows you to be identified, such as age, occupation, and location.

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Generally under Canadian privacy laws, personal information does not include any business contact

information that is solely used to communicate with you in relation to your employment, business or

profession, such as your name, position name or title, work address, work telephone number, work fax

number or work electronic address.

Personal information also does not include information that has been anonymized according to

generally accepted best practices and in such a way that it is, at all times, reasonably foreseeable in the

circumstances that it irreversibly no longer allows an individual to be identified, whether on its own or in

combination with other information.

YOUR CONSENT TO COLLECTION, USE, AND DISCLOSURE

Methods

 Where appropriate, we collect, use and disclose your personal information with your

consent, or as permitted or required by law.

 How we obtain your consent (i.e. the form we use) will depend on the circumstances, as

well as the sensitivity of the information collected.

 Subject to applicable laws, your consent may be express or implied, depending on the

circumstances and the sensitivity of the personal information in question.

 If you choose to provide us with your personal information after reviewing this Policy, we

will assume that you consent to the collection, use and disclosure of your personal

information. However, we will require your consent when necessary as required by

applicable privacy laws.

Purposes

 Typically, we will seek your consent at the time your personal information is collected.

 Where we want to use your personal information for a purpose not previously identified to

you at the time of collection, we will seek your consent prior to our use of such information

Withdrawing Consent

 To provide you with access to our website we may collect personal information. Without

such information, we may not be able to provide our services.

 You may withdraw your consent to our collection, use or disclosure of your personal

information at any time by contacting us using the contact information in the “Contact Us”

section below. However, note that:

o withdrawal of your consent may prevent us from providing website access to you, in

whole or in part, or prevent those from functioning as intended;

o before we implement the withdrawal of consent, we may require proof of your identity;

and

o even if you withdraw your consent, we may keep using, disclosing or retaining some of

your personal information to the extent required by applicable law.

Consent and Other Individuals

 If you provide personal information about another individual to us, it is your responsibility to

obtain the consent of that individual to enable us to collect from you, use and disclose their

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information as described in this Policy. By providing personal information about another

individual to us, you represent and warrant that you have obtained their prior consent to our

collection of his/her personal information from a third party and made them aware of this

Policy.

PERSONAL INFORMATION WE COLLECT

What Information We Collect

The information we may collect about you varies depending on the nature of our relationship with you.

Generally, the personal information we collect falls into the following categories (not all of which may

apply to you):

● Visitor Information: When users visit our Website and its associated sub-domains, we may

collect information they submit to us directly through the site, such as their email address if

they request information about LEWK. This includes contact forms which a Visitor may choose

to fill out on the Website.

● Log Information: To the extent permitted under applicable law, we automatically log

information about use of the Website, including the type of browser used, dates and times of

access, pages viewed, and IP address. We may also, subject to applicable law, collect or infer

your geographic location based on your IP address. Usage and personal information may be

logged as well for the purpose of tracking down technical issues.

● Device Information: We automatically collect information about the computer or mobile devices

used to access the website, including the hardware model, operating system and version,

unique device identifiers and mobile network information.

● Information Collected by Cookies and Other Tracking Technologies: To the extent permitted

under applicable law, we may use third-party analytics tools to better understand the user base

of our websites. To do so, we use various technologies to collect information, and this may

include sending cookies to user computers or mobile devices or enlisting third party services

which use cookies to track your activities on our website. Cookies are small data files transferred

to your computer’s hard-drive by a website, if your browser is enabled to accept cookies. They

keep a record of your preferences, making your subsequent visits to the site more efficient.

Cookies may store a variety of information, including the number of times that you access a site,

your registration information and the number of times that you view a particular page or other

item on the site. The use of cookies is a common practice adopted by most major sites to better

serve their users. Most internet browsers will allow you to erase cookies from your computer

hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You

should refer to your browser instructions or “Help” screen to learn more about how to manage

cookies. Please note, however, that if you block cookies, some portions of the website may not

function properly. For more information, please see our Cookies Policy.

B. Other Interactions

● For individuals who otherwise interact with us, whether in person, on the website, by phone or

email, through social media or otherwise, including individuals who request information about

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our products or services, or who enter a contest or respond to surveys and questionnaires, we

may collect information they provide to us during these interactions. This information may

include name, e-mail address and other contact information.

AGGREGATED AND ANONYMIZED INFORMATION WE COLLECT

General, aggregated, demographic, and non-personal information may be collected by us through our

websites or Services, but any such information will not be linked to any of your personal information.

This type of anonymous, aggregated profiling and session data may include information that you have

provided to us through surveys, polls, etc., and may also include aggregated anonymous information

about website usage and the customer base.

We will take reasonable measures to ensure the aggregated/anonymized information cannot be

associated with an individual, we will maintain and use such information only in an

aggregated/anonymized form, and we will not attempt to reidentify such information except as

permitted by law. We may disclose aggregated information about you, and information that does not

identify any individual, without restriction.

HOW WE USE YOUR PERSONAL INFORMATION

We use the information we collect from users in connection with our website to provide, maintain,

analyze, and improve our products and services, including to:

● Respond to your comments, questions, and requests, and otherwise facilitate or contact you

about your use of the Website.

● Communicate with you about marketing aspects such as products, services, offers, and events

offered by LEWK and others, and provide news and information we think will be of interest to

you.

● To the extent permitted under applicable law, monitor and analyze trends, usage and activities

in connection with our Website, and personalize and improve our website, products and

services.

● Notify you about important changes our services and applicable terms and policies.

● Collect, display and publish reviews and comments from our users and customers about our

products and services.

● Detect, investigate and prevent fraudulent transactions and other illegal activities and protect

the rights and property of LEWK and others.

● Enforce this Policy or our Terms of Service;

● Carry out any other purpose for which consent is obtained, or as otherwise permitted or

required by law.

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Whatever the purpose may be, we will collect and process your personal information to the extent you

have provided us with your consent, or alternatively as reasonably necessary to fulfill our contracts with

you, or as may be required by applicable law. We may use your personal information and other

information for purposes for which we have obtained your consent, and for such other purposes as may

be permitted or required by applicable law.

HOW WE SHARE YOUR PERSONAL INFORMATION

Personal information we collected may be shared as follows or as otherwise described in this Privacy

Policy:

● In response to a request for information if we believe disclosure is in accordance with any

applicable law, regulation or legal process, or as otherwise required by any applicable law, rule

or regulation;

● With vendors, consultants, and other service providers who need access to such information to

carry out work on our behalf in connection with our Services.

If we provide your information to third party service providers, we take reasonable measures to ensure

that this Policy and its principles are complied with and these third parties provide sufficient guarantees

to implement appropriate security measures. We also require that they only use your personal

information for the limited purposes for which it is provided. When our service providers no longer need

your personal information for those limited purposes, we require that they dispose of the personal

information. We do not authorize the service providers to disclose your personal information to

unauthorized parties or to use your personal information for their direct marketing purposes.

In some circumstances, we may permit our service providers to retain aggregated or statistical

information that does not identify you directly.

Additionally, we may use and disclose your information when we believe such use or disclosure is

permitted, necessary or appropriate:

(a) under applicable law, including laws outside your country of residence;

(b) to comply with legal process, including outside of your country of residence;

(c) to respond to requests from public and government authorities, or to cooperate with law

enforcement, including public and government authorities outside your country of residence;

(d) to enforce the terms of the agreements for our products and services;

(e) to protect our operations or those of any of our affiliates or subsidiaries;

(f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others;

(g) to allow us to pursue available remedies or limit the damages that we may sustain; and

(h) in connection with a sale or business transaction, we may transfer your personal information

to a third party to the extent necessary to conclude any reorganization, merger, sale, joint

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venture, assignment, transfer or other disposition of all or any portion of our business, brands,

affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, in a manner not identified

in this Policy, we will identify that third party and the purpose for the disclosure, and obtain your

consent.

RETENTION OF PERSONAL INFORMATION

We will use, disclose or retain your personal information only for as long as necessary to fulfill the

purposes for which that personal information was collected and as permitted or required by law. These

times vary depending on the purpose for which the information was collected and the need for the

information. We will destroy records containing personal information or in some cases, anonymize all

personal information in the records, when we no longer need the information for the purpose for which

it was collected, or for other business or legal purposes, or its retention is no longer required by law.

THIRD PARTY WEBSITES AND SERVICES

This Policy applies only to our website, products, and services. It does not extend to any websites,

products, social media platforms or services provided by third parties.

There may be times where a third party may ask to collect your personal information themselves. These

third parties can include advertisers and third party service providers and payment processors. When

you provide your personal information to such third parties, they will use your personal information in

accordance with their own privacy policies and not this Policy. Therefore, you should read their privacy

policies carefully before providing them with your personal information. We are not responsible for the

privacy practices of such third parties, and we encourage you to review all third party privacy policies

prior to using third party websites or products or services.

The third party service providers we use in relation to the Website, include but are not limited to, the

following:

● Google Analytics. We use Google Analytics to help us understand how our users interact with

certain features on our website. For more information, please visit

https://analytics.google.com/analytics/web

● Hubspot. We use Hubspot for lead and client information for employers. Hubspot is a CRM and

marketing system that allows us to track and take action on our relationships with consumers.

For more information, please visit https://hubspot.com

If you would like more information about our service providers, please contact us using the contact

information in the “Contact Us” section below.

INTERNATIONAL TRANSFER AND STORAGE

LEWK is based in Canada and we process and store information in Canada. Your personal information

may also be stored and processed in any country where we have facilities or in which we engage third

party service providers. As a result, to the extent permitted under applicable law, your personal

information may be transferred to countries outside your country of residence, which may have

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different data protection rules than in your home country. While such information is outside of your

country, it is subject to the laws of the country in which it is located, and may be subject to disclosure to

the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to

the laws of such country.

INFORMATION SECURITY

We have implemented reasonable physical, organizational, contractual and technological security

measures with a view to protecting your personal information and other information from loss or theft,

unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the

only personnel who are granted access to your personal information are those with a business ‘need-to-

know’ or whose duties reasonably require such information.

While we take precautions against possible breaches in our web sites and customer databases, no web

site or Internet transmission is completely secure, so unfortunately, we cannot guarantee that

unauthorized access, hacking, data loss, or other breaches will never occur. Your use of our website and

the Services are at your own risk. We assume no liability for disclosure of your personal information due

to transmission errors, unauthorized access, or causes beyond our control, including security failures on

the part of our partners and third party service providers and processors.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel

that the security of any information that you provided to us has been compromised), please contact us

immediately using the contact information in the “Contact Us” section below.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

We make reasonable efforts to ensure that your personal information is kept as accurate, complete and

up to date as reasonably necessary. We will not routinely update your personal information, unless

such a process is necessary. We expect you, from time to time, to supply us with updates to your

personal information, when required.

You may make a written request to review any personal information about you that we have collected,

used or disclosed, and we will provide you with any such personal information to the extent required

and/or permitted by law. You may also challenge the accuracy or completeness of your personal

information in our records and request corrections. If you successfully demonstrate that your personal

information in our records is inaccurate or incomplete, we will amend the personal information as

required. To exercise these rights, please contact us by using the contact information in the “Contact

Us” section below.

We may require that you provide sufficient identification to fulfill your request to access or correct your

personal information. Any such identifying information will be used only for this purpose.

OPTING OUT OF COMMUNICATIONS

If you no longer want to receive marketing-related emails from us, you may opt-out of receiving

marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from

us. You may also opt-out by contacting us directly using the contact information in the “Contact Us”

section below.

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We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a

reasonable time to process your request. Please note that if you opt-out from receiving marketing-

related emails, we may still need to send you communications about your use of our products or other

matters.

CHILDREN’S INFORMATION

Our Website is not intended for children under the age of 16. Children under the age of 16 should not

use our website and should not supply us with any personal information.

If we learn we have collected or received personal information from a child under 16 without

verification of parental consent, we will delete that information. If you believe we might have any

information from or about a child under 16 without the consent of their parent or legal guardian, please

contact us using the information in the “Contact Us” section below.

PRIVACY POLICY UPDATES

This Policy is current as of the “updated” date which appears at the top of this page. It may be modified

or updated from time to time. When changes are made to this Policy, they will become immediately

effective when published in a revised Policy posted on our website unless otherwise noted.

CONTACT US

All comments, questions, concerns or complaints regarding your personal information or our privacy

practices should be sent to our Privacy Officer as follows:

Attention: Privacy Officer

By e-mail: sheena@shopthelewk.com