Website privacy policy

Last updated: [date]

Draft. This policy is awaiting legal review. Remove this notice once it is approved.

1. Who we are

This website is operated by Harper Labs Inc. [a company being incorporated in British Columbia] (“Harper Labs”, “we”, “us” or “our”), a construction technology company. Our office is at [address], Burnaby, British Columbia.

We are responsible for the personal information we collect through this website. We handle it in accordance with British Columbia’s Personal Information Protection Act (PIPA) and, where it applies, Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

2. What this policy covers

This policy covers personal information collected through the public pages of harperlabs.ca and through messages you send us about the website. It does not cover:

• The private board and investor portal, which is covered by a separate Portal Privacy Policy shown to authorized users.

• Our software products. Information handled inside our software is governed by the agreement between us and the customer or tester using them.

• Other websites we link to, which have their own privacy practices.

3. Information we collect

Information you give us. When you use our contact form or email us, we collect your name, email address, and your company, role and phone number if you choose to provide them, together with the content of your message.

Information collected automatically. When you visit the site, some technical information is processed so that the site can be delivered and protected:

• Delivery and security. Our website is delivered through a third-party hosting, content delivery and security provider, which processes your IP address, browser and device information, and the pages you request, in order to route traffic, block attacks and prevent abuse. The provider may set a small number of strictly necessary security cookies for this purpose.

• Server logs. Our web server records basic access logs (IP address, date and time, page requested, browser type) for security and troubleshooting.

• Analytics. We use a privacy-focused analytics service provided by our hosting and security provider to understand, in aggregate, how many people visit and which pages are viewed. It does not use cookies, does not track you across other websites, and does not build a profile of you.

We do not use advertising cookies, tracking pixels or third-party advertising networks, and we do not sell personal information.

4. Why we use it

We use personal information only to:

• respond to your enquiry and follow up on it, including about our products, testing, partnerships, careers or investment;

• operate, secure and maintain the website, and detect and prevent fraud, abuse and attacks;

• understand overall website use so we can improve it; and

• meet our legal obligations and protect our legal rights.

We will not use your information for a new purpose without telling you and, where required, getting your consent. We do not send marketing emails or newsletters from this website. If we offer a mailing list in future, we will ask for your express consent and every message will include a way to unsubscribe, as required by Canada’s Anti-Spam Legislation.

5. Consent

By submitting the contact form or emailing us, you consent to our collecting and using your information to respond to you as described in this policy. Technical information needed to deliver and secure the website is processed as a condition of using it. You may withdraw your consent to our further use of your contact information at any time by writing to [email protected], subject to legal or contractual restrictions; we will explain any consequences of withdrawing.

6. Who we share it with

We share personal information only with service providers who help us run the website and our business, and only as needed for the purposes above. You may ask our Privacy Officer for the names of our current service providers.

Our service providers are required to protect personal information and to use it only to provide services to us. We may also disclose personal information where required or permitted by law (for example, in response to a valid court order), to protect our rights or safety or those of others, or to a prospective buyer, investor or successor in connection with a financing, sale or reorganization of our business, under confidentiality obligations.

7. Information stored outside Canada

Some of our service providers store or process information outside Canada, including in the United States. While there, it is subject to the laws of that country and may be accessible to its courts, law enforcement and national security authorities. You can ask us about our practices for service providers outside Canada by contacting our Privacy Officer.

8. How long we keep it

If we use your information to make a decision that directly affects you, we keep it for at least one year after that decision so you have a reasonable opportunity to request access to it. When information is no longer needed, we securely delete or anonymize it.

9. How we protect it

We use reasonable security safeguards appropriate to the sensitivity of the information, including encrypted connections (HTTPS), access controls and multi-factor authentication on our accounts, firewall and network protections, keeping systems updated, and limiting access to people who need it. No method of transmission or storage is completely secure, so please do not send us sensitive personal information (such as identification or banking numbers) through the contact form.

If a privacy breach creates a real risk of significant harm to you, we will notify you and the appropriate regulator as required by applicable law.

10. Your rights

Subject to limited exceptions in the law, you may:

• ask whether we hold personal information about you, and request access to it;

• ask how your information has been used and to whom it has been disclosed;

• ask us to correct information that is inaccurate or incomplete; and

• withdraw your consent, as described in section 5.

Send your request in writing to our Privacy Officer. We may need to verify your identity. We will respond within 30 days, or tell you if we need more time as permitted by law. We do not charge for access requests except, where permitted, a minimal fee we will estimate for you in advance.

11. Children

This website is intended for businesses and adults. We do not knowingly collect personal information from children. If you believe a child has sent us personal information, please contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. The “Last updated” date at the top shows when it last changed. If we make a significant change to how we use personal information, we will post a notice on the website.

13. Contact us and complaints

Questions, requests and complaints about privacy should go to our Privacy Officer:

Privacy Officer: Jamie Kossowan

Email: [email protected]

Mail: Harper Labs Inc., Attn: Privacy Officer, [address], Burnaby, BC [postal code]

We will investigate every complaint and, if it is justified, take appropriate steps to address it. If you are not satisfied with our response, you may contact:

• Office of the Information and Privacy Commissioner for British Columbia — www.oipc.bc.ca

• Office of the Privacy Commissioner of Canada — www.priv.gc.ca