Privacy Policy.

This Privacy Notice for 1001497538 ONTARIO INC. (doing business as Capped) ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at joincapped.com, or any website of ours that links to this Privacy Notice
• Use the Capped platform, recruiting systems, or brokerage websites we build and operate. Capped provides marketing services, software, and websites for real estate brokerages, including recruiting advertising, a brokerage management platform, and client websites.
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions, contact us at hello@joincapped.com.

Summary of key points

This summary provides key points from our Privacy Notice. You can find more detail in the full sections below.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the products and features you use.
• Do we process sensitive personal information? We do not process sensitive personal information.
• Do we collect information from third parties? We do not collect any information from third parties.
• How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.
• When and with whom do we share information? In specific situations and with specific third parties, described in section 3.
• How do we keep your information safe? We have organizational and technical processes in place to protect your personal information, though no system can be guaranteed 100% secure.
• What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information.
• How do you exercise your rights? The easiest way is to contact us at hello@joincapped.com. We will consider and act upon any request in accordance with applicable data protection laws.

Table of contents

1. 01What information do we collect?
2. 02How do we process your information?
3. 03When and with whom do we share your personal information?
4. 04Do we use cookies and other tracking technologies?
5. 05Do we offer artificial intelligence-based products?
6. 06How do we handle your social logins?
7. 07How long do we keep your information?
8. 08How do we keep your information safe?
9. 09Do we collect information from minors?
10. 10What are your privacy rights?
11. 11Controls for do-not-track features
12. 12Do United States residents have specific privacy rights?
13. 13Do we make updates to this notice?
14. 14How can you contact us about this notice?
15. 15How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us. The personal information we collect may include:

• Names
• Phone numbers
• Email addresses
• Job titles
• Business information (brokerage name, number of agents, services of interest)

Sensitive information

We do not process sensitive information.

Payment data

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the associated security code. All payment data is handled and stored by Stripe. You may review their privacy notice at stripe.com/privacy.

Social media login data

We may provide you with the option to register using your existing social media account details. If you choose to register in this way, we will collect certain profile information about you from that provider, as described in section 6 below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

• To deliver and facilitate delivery of services. We may process your information to provide you with the requested service.
• To respond to inquiries and offer support. We may process your information to respond to your inquiries and resolve any issues with the requested service.
• To send administrative information. Details about our products and services, changes to our terms and policies, and similar information.
• To deliver targeted advertising. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends so we can better understand how our Services are used and improve them.
• To determine the effectiveness of our marketing and promotional campaigns.
• To comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. When and with whom do we share your personal information?

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4. Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests. These third parties use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Services or on other websites.

You may adjust your browser settings to disable cookies if you prefer.

5. Do we offer artificial intelligence-based products?

We provide AI Products through third-party service providers ("AI Service Providers"), including Anthropic and OpenAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products are designed for the following functions:

• Image generation
• AI applications
• AI automation
• AI document generation
• AI search
• Text analysis

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

6. How do we handle your social logins?

Where you choose to register or log in using a third-party social media account, we will receive certain profile information from that provider. The information we receive may vary, but often includes your name, email address, friends list, and profile picture, as well as other information you choose to make public.

We use the information we receive only for the purposes described in this Privacy Notice or otherwise made clear to you on the relevant Services. We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend reviewing their privacy notice.

7. How long do we keep your information?

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because it is stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

8. How do we keep your information safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to the minor dependent's use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, please contact us at hello@joincapped.com.

10. What are your privacy rights?

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time by contacting us using the details in section 14 below. This will not affect the lawfulness of the processing before its withdrawal, nor, where applicable law allows, the processing of your personal information conducted in reliance on lawful grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send, replying STOP or UNSUBSCRIBE to the SMS messages we send, or by contacting us using the details in section 14 below. You will then be removed from the marketing lists. However, we may still communicate with you to send service-related messages necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

If you have questions or comments about your privacy rights, email us at hello@joincapped.com.

11. Controls for do-not-track features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted that we must follow in the future, we will inform you in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. It includes illustrative examples of each category.

We may also collect other personal information outside of these categories where you interact with us in person, online, by phone, or by mail in the context of receiving help through our customer support channels, participating in customer surveys or contests, and facilitating the delivery of our Services and responding to your inquiries.

We will use and retain the collected personal information as needed to provide the Services, or for:

• Category A — as long as the user has an account with us
• Category B — as long as the user has an account with us
• Category I — as long as the user has an account with us

How we use and share personal information

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your rights

You have rights under certain US state data protection laws. These rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (including under the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (including under the privacy laws in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (including under the privacy laws in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (including under the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (including under the privacy laws in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (including under the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (including under the privacy law in Florida)

How to exercise your rights

To exercise these rights, you can contact us by emailing hello@joincapped.com, or by referring to the contact details at the bottom of this page. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an agent who does not submit proof of valid authorization.

Request verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request additional information for verification, security, and fraud-prevention purposes.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@joincapped.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

13. Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last Updated" date at the top of this page. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at hello@joincapped.com or contact us by post at:

1001497538 ONTARIO INC. (operating as Capped)
432 Salem Road
Ajax, Ontario L1S 7S9
Canada

15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email us at hello@joincapped.com.