Last updated: May 31, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your
information when You use the Service and tells You about Your privacy rights and how the law protects
You.

We use Your Personal data to provide and improve the Service. By using the Service,
You agree to the collection
and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the
following conditions. The
following definitions shall have the same meaning regardless of whether they appear in singular or in
plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our
Service or parts of our
Service.

Affiliate means an entity that controls, is controlled by or is
under common control with a
party, where “control” means ownership of 50% or more of the shares, equity interest or other securities
entitled to vote for election of directors or other managing authority.

Application means the software program provided by the Company
downloaded by You on any
electronic device, named Opia

Company (referred to as either “the Company”, “We”, “Us” or “Our”
in this Agreement) refers to
Opia Inc. , 308 Maplehurt Ave, Oakville, Ontario, Canada L6L4Y2.

Country refers to: Ontario, Canada

Device means any device that can access the Service such as a
computer, a cellphone or a
digital tablet.

Personal Data is any information that relates to an identified or
identifiable
individual.

Service refers to the Application.

Service Provider means any natural or legal person who processes
the data on behalf of the
Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to
provide the Service on behalf of the Company, to perform services related to the Service or to assist the
Company in analyzing how the Service is used.

Usage Data refers to data collected automatically, either
generated by the use of the Service
or from the Service infrastructure itself (for example, the duration of a page visit).

You means the individual accessing or using the Service, or the
company, or other legal entity
on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can
be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address

First name and last name

Phone number

Address, State, Province, ZIP/Postal code, City

Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address
(e.g. IP address), browser
type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain
information automatically,
including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address
of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device
identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our
Service or when You access the
Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may
collect, with Your prior
permission:

Information regarding your location

Pictures and other information from your Device’s camera and photo library

We use this information to provide features of Our Service, to improve and
customize Our Service. The
information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply
stored on Your device.

You can enable or disable access to this information at any time, through Your
Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage
of our Service.

To manage Your Account: to manage Your registration as a user of
the Service. The Personal Data
You provide can give You access to different functionalities of the Service that are available to You as a
registered user.

For the performance of a contract: the development, compliance and
undertaking of the purchase
contract for the products, items or services You have purchased or of any other contract with Us through the
Service.

To contact You: To contact You by email, telephone calls, SMS, or
other equivalent forms of
electronic communication, such as a mobile application’s push notifications regarding updates or informative
communications related to the functionalities, products or contracted services, including the security updates,
when necessary or reasonable for their implementation.

To provide You with news, special offers and general information
about other goods, services
and events which we offer that are similar to those that you have already purchased or enquired about unless You
have opted not to receive such information.

To manage Your requests: To attend and manage Your requests to Us.

For business transfers: We may use Your information to evaluate or
conduct a merger,
divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets,
whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data
held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes,
such as data analysis,
identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve
our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this
Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with applicable laws), resolve
disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data
is generally retained for a
shorter period of time, except when this data is used to strengthen the security or to improve the functionality
of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s
operating offices and in any other
places where the parties involved in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of Your state, province, country or other
governmental jurisdiction where the data protection laws may differ than those from Your
jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to
that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is
treated securely and in
accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization
or
a country unless there are adequate controls in place including the security of Your data and other personal
information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal
Data may be transferred. We
will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy
Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so
by
law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the
Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable
means
to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable
information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your
child
has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal
Data
from anyone under the age of 13 without verification of parental consent, We take steps to remove that
information from Our servers.

If We need to rely on consent as a legal basis for processing Your information
and Your country requires
consent
from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If
You click on a third party
link,
You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of
every
site You visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any
third
party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new
Privacy
Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming
effective
and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy
are
effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: