RIFO REALTY GROUP INC.

PRIVACY POLICY

Last Revised: August 23, 2021

INTRODUCTION

RIFO REALTY GROUP INC. (“RIFO”) respects your (“Your”) privacy and is committed to protecting it through RIFO’s compliance with this privacy policy (the “Privacy Policy”). This means RIFO does not transfer, distribute, disclose, rent or sell any of Your personal information to third parties except as provided for in this Privacy Policy or as specifically consented by You.

RIFO has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.

By using (the word “use” in this Privacy Policy will mean “access or use”) RIFO’s Services, including RIFO’s Website (currently located at https://www.rifo.co, https://www.rifo.ca, You expressly consent to RIFO’s collection, use and disclosure of Your personal information in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and subject to RIFO’s Terms of Service available at https://policy.rifo.ca/terms_of_service.html. Undefined capitalized terms used in this Privacy Policy have the meanings given to them in RIFO’s Terms of Services available at https://policy.rifo.ca/terms_of_service.html.

SCOPE

This Privacy Policy applies to all Personal Information collected, used or disclosed by RIFO from endusers of RIFO’s Services (“Users”), including You. “Personal Information” is any information in any form that identifies or can identify an individual or could be combined other information to identify You.

This Privacy Policy also applies to information that is about You, but individually does not identify You, as described below

ACCOUNTABILITY

RIFO is responsible for the Personal Information under its possession and control. RIFO has designated a Privacy Officer to be responsible for its compliance with this Privacy Policy and privacy legislation.

INFORMATION RIFO COLLECTS

Personal Information

Personal Information that RIFO collects includes, but is not limited to:

• Registration information, such as name, e-mail address, address, date of birth, usernames, passwords, phone numbers, mailing address, profession and job title;
• Billing and payment information, including credit card information and bank account details;
• Any other Personal Information that You may provide when You use the Services, or when you contact RIFO with questions and/or inquiries;
• Technical support records;
• Service requests and inquiries; and
• Any information that RIFO collects from You that is intended to improve and personalize RIFO’s Services.

b. Non-Personal Information

RIFO collects non-specific Personal Information (“NPI”) about Users when they interact with the Services. For instance, NPI may include, but is not limited to, device information, IP address, geolocation information, browser name, type of computer or device, and technical information about a User’s means of connecting to the Services, such as operating system, Internet service provider utilized, and mobile network information. See the section below entitled “How does RIFO collect, use and share NPI?” for more information.

Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any other User. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.

HOW DOES RIFO USE PERSONAL INFORMATION?

RIFO collects Personal Information for the following usage purposes:

• to provide Services to You and other Users;
• to facilitate transactions between You, other Users and RIFO;
• to establish and maintain responsible commercial relations with You;
• to communicate with You in order to provide the Service;
• to permit RIFO’s third party payment provider(s) to provide payment services;
• to respond to any correspondence You may direct to RIFO;
• to understand RIFO’s Users’ needs and preferences;
• to enforce RIFO’s Terms of Service;
• to provide You with Service or administrative messages
• to meet legal and regulatory requirements;
• to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
• to improve the Services; and
• for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.

In addition, RIFO may use Personal Information, on an aggregated de-identified basis, for research purposes to improve the Services. This aggregated de-identified information does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

HOW DOES RIFO COLLECT, USE AND SHARE NPI?

RIFO uses NPI in an ongoing effort to better understand and serve the Users of RIFO’s Services, including to provide the Services and to improve the content and functionality of the Services

For instance, RIFO uses NPI to monitor traffic and to collect statistical data.

RIFO also conducts research on RIFO’s User behaviour and demographics based on Personal Information and the NPI that RIFO has collected. This research will be compiled and analyzed on an aggregated basis and this aggregated data does not identify any individual and therefore is considered and treated as NPI under this Privacy Policy.

No NPI by itself, or together with aggregated Personal Information (which, as explained below, is treated as NPI under this Privacy Policy), can be tracked to a specific individual's Personal Information.

Specific Uses of NPI by RIFO:

• To monitor traffic, provide the Services, and conduct internal research on RIFO’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors.
• The NPI collected by RIFO will not be shared with third parties, except as expressly indicated in this Privacy Policy, or with RIFO’s Affiliates (as defined below), business partners and other third parties to describe RIFO’s Services and for other lawful purposes.

Specific NPI Collected by RIFO:

• The Services may automatically receive and store certain types of information about Users’ use of the Services via web browser, including IP address, browser type, browser version, web pages viewed, date and time, time spent on Services, unique device identifier, , and other diagnostic information, as well as how users interact with RIFO.
• When you access the Services with a mobile device, the Services may collect information such as the type of mobile device you use, your mobile device unique identifies, the IP address of your mobile device, your mobile operating system, your mobile network, device phone number, the type of mobile Internet browser you use, and other diagnostic information
• The Services also may access metadata and other information associated with other files stored on Your device. This may include, for example, audio and video clips, personal contacts, and address book information, and Your device’s camera application to assist with real estate listings.

Technology Used to Collect NPI:

• RIFO uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.

GEO-LOCATION INFORMATION

RIFO may use and store information about Your location if You give RIFO permission to do so. RIFO uses this data to provide features of the Service, to improve the Service and customise the Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

COLLECTION AND TRANSMISSION OF SOCIAL ACCOUNT INFORMATION

In order to provide you with one-click sharing service, RIFO’s apps have integrated Umeng+ U-Share SDK, which will collect social account information from your device in order to facilitate the sharing of such information on your social media accounts. For example, you can utilize the foregoing one-click sharing service to announce and post on Facebook that you have bought a new house. For your information security, we have made data security confidentiality agreements with Umeng+ who will strictly abide by our data privacy and security requirements. We will not share the foregoing Personal Information unless authorized by you. For more information please see https://www.umeng.com/policy to review Umeng+’s privacy policy.

COOKIES & OPT-OUT

RIFO uses cookies to enhance Users’ experiences. Users’ web browsers place cookies on their computers for record-keeping purposes and sometimes to track information about them. Cookies help RIFO accurately understand how many consumers are visiting RIFO’s Website, how often Users visit the Website, what Content Users are most interested in, and how they prefer to interact with Content on the Website. For example, a cookie will allow RIFO to remember certain things like Your Internet Protocol (IP) address (IP addresses are strings of numbers that identify senders and receivers of information sent across the Internet), Your login information, the time and duration of Your visits, how You navigated through RIFO’s content and where You exited the Website. To save You the time of re-entering Your login information every time You come back to RIFO’s Website, RIFO may link information contained in a cookie to Your email address. RIFO does not use cookies to retrieve information from Your device that RIFO did not originally send in a cookie.

Examples of Cookies we use include:

• Session Cookies, which are used to operate the Services
• Preference Cookies, which are used to remember Your preferences and various settings.
• Security Cookies, which are used for security purposes

RIFO uses Google Analytics, which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor use of the Services. The data is shared with other Google services. Google Analytics uses cookies to track information about traffic and visitors and sends such information (i) to Google servers in the United States and (ii) to RIFO. Google Analytics does not identify any individual users or associate Your IP address with any other data held by Google. RIFO uses such information in the aggregate to compile statistical reports about the activity on the Services as well as to benchmark the Services to other third parties who also use Google Analytics. In addition, Google may use the collected data to contextualise and personalise the ads of its own advertising network. This information is used by RIFO to improve the Services and their functionality. Google’s privacy policy can be found here: policies.google.com/privacy.

You may disable cookies using Your browser's settings. Please consult Your browser's help function for information on how to disable cookies.

You may opt-out of Google Analytics by clicking here: tools.google.com/dlpage/gaoptout?hl=en.

Note that if You disable cookies, certain features of RIFO’s Services may not function to their fullest potential

CONSENT

RIFO respects Your privacy and, unless otherwise required by law, RIFO will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing RIFO Personal Information to register for RIFO’s Services is implied consent to use such information to provide You the associated Services.

Where appropriate, RIFO will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when RIFO wants to use information for a purpose other than those identified above). In obtaining consent, RIFO will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.

The form of consent sought by RIFO may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, RIFO shall take into account the sensitivity of the Personal Information and the reasonable expectations of RIFO’s Users. RIFO will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to RIFO in writing.

LIMITING USE, DISCLOSURE AND RETENTION

As noted above, RIFO does not disclose Your Personal Information to third parties, except as provided for in this Privacy Policy.

When You sell or buy services via the Services, the Vendor or Agent (as applicable) may receive Your Personal Information for service provision purposes.

Your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by RIFO to assist it in providing and developing products, services and/or the Services. Such Affiliates will only use Your Personal Information for the purposes identified in this Privacy Policy.

At present, RIFO uses Moneris for payment services. Moneris’s privacy policy is available at moneris.com/en/Privacy-Policy .

As explained above, RIFO uses Google Analytics. Google’s privacy policy can be found here: policies.google.com/privacy

In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, RIFO will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.

Subject to the foregoing, only RIFO’s and RIFO’s Affiliates’ employees and contractors with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about RIFO’s Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of RIFO’s Users’ Personal Information.

RIFO will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by RIFO.

RIFO will disclose Personal Information without Your knowledge or consent if RIFO receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If RIFO receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, RIFO’s policy is to provide the requested information.

LINKS TO OTHER SERVICES

You may be able to access third-party websites and services through links available on RIFO’s Services or the Website. Any links are provided for Your convenience. RIFO does not have any control over those third-party websites or services and RIFO does not provide any guarantee that the privacy practices of the hosts of those websites or services meet RIFO’s standards. Your use of such third-party websites or services is at Your own risk and will be governed by the privacy policies of those websites or services and not by this Privacy Policy. Do not transmit Personal Information using those websites or services without reading the privacy policies governing those websites and services.

You may change the way social media services and RIFO’s Services interact by modifying Your privacy settings in Your social media account. You can also log-out of Your social media account before using RIFO’s Services. For more information, please refer to Your social media services’ privacy policy, which governs Your use of these features.

STORAGE OUTSIDE OF CANADA

We may store and process the Your Personal Information on servers in Canada and/or in the United States. RIFO requires that RIFO's service providers safeguard Your Personal Information.

CHILDREN AND MINORS

RIFO’s Services are not directed to children under the age of 18 years. RIFO will not knowingly collect Personal Information about a child under the age of 18. RIFO does not allow minors (persons who are under the age of majority in their place of residence) to make purchases.

HOW CAN I ACCESS MY PERSONAL INFORMATION?

Upon request, RIFO will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. RIFO will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate

NOTE: In certain circumstances, RIFO may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. RIFO will provide the reasons for denying access upon request.

SAFEGUARDS

RIFO protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. RIFO will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

RIFO’s methods of protection include:

• Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to RIFO's place of business in general and to internal offices as well;
• Organization measures, such as security clearances and limited access on a need to know basis; and
• Technological measures, such as the use of passwords, firewalls and encryption.

INQUIRIES; CHALLENGING COMPLIANCE

An individual will be able to make inquiries and/or address a challenge concerning compliance with this Privacy Policy to RIFO's Privacy Officer.

RIFO will maintain procedures for addressing and responding to all inquiries or complaints from RIFO’s Users about RIFO's handling of Personal Information. RIFO shall investigate all complaints. All inquiries or complaints involving RIFO's handling of Personal Information or compliance with this Privacy Policy or with PIPEDA shall be directed to RIFO's Privacy Officer.

The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If RIFO finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.

For more information, please contact RIFO’s Privacy Office as follows:

GENERAL

RIFO reserves the right to modify and amend this Privacy Policy from time to time in its sole discretion without prior notice. Any such amendment(s) will be posted on RIFO’s Services and will be effective as of the date of posting.