PRIVACY POLICY

Stratosphere Technology Inc. (“Stratosphere”, “we”, “us”, “our” and terms of similar meaning) takes your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose (a) your personal or personally identifiable information (“Information”); and (b) data we obtain from your activity on the Services (as defined below) (“Data”) as part of providing our Website available at finchat.io (the “Website”) the license to the Software (as defined in the Terms) and the services provided to you subject to the Terms and/or an Order Form or any Schedule (collectively, the “Services”).

We encourage you to read and understand our License and Services Terms and Conditions (“Terms”) and this privacy policy (“Privacy Policy”) before using the Services. By accepting the Terms and/or Privacy Policy or by accessing the Services, you expressly consent to our collection, use and disclosure of your Information and Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms.

This Privacy Policy may change from time to time. Your continued use of the Services after we make changes indicates that you accept and consent to those changes, so please check the Privacy Policy periodically for updates. We will notify you in advance of any material changes to this Privacy Policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

All capitalized terms or terms that were otherwise defined in the Terms that are not otherwise defined herein obtain their meaning from the Terms, including, without limitation, the definition of “you” and “your” used in the Terms.

1. Scope of Application of this Privacy Policy

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

This Privacy Policy applies to personal information we collect, use, or disclose about you (“Personal Information”):

On the Services.

In email, text, and other electronic messages between you and Stratosphere.

The Services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the Privacy Policy of every website you visit.

2. What Information We Collect

We collect and use several types of information from and about you, including:

Personal information, that we can reasonably use to directly or indirectly identify you, including the following:

o Your Account Information. When registering for a User account or as you access or use the Services, from time to time, Clients and Users, as defined in the Terms, give us information including your name, email address, location and password (encrypted). Where possible, we indicate which information is required and which information is optional.

o User Content. As you use the Services, you can, or may be required, from time to time enter or send to us Information, which may include, without limitation, Information that you share on your account as a Client or a User, including any input, file uploads, or feedback you provide to the Services.

o Payment and Banking Information. When a Client provides a credit/debit card, payment method or banking information through the Client account or an Administrator, these payment details will be shared with our third-party payment processor(s). We do not store credit/debit card, payment method or banking information on our servers. If the Client modifies which Administrator account provides payment for the Services, we will require that Information to be updated for your continued access to the Services.

Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of Users accessing a specific feature or Services.

Non-personal details about your interactions with the Services, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Services (including date and time), page response times, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

3. How We Collect Information About You

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us via the Website, by email, or otherwise in the Services.

Automated technologies or interactions, as you navigate through our Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

A. Information You Provide to Us

When you use the Services, we may ask you to provide:

Information that you provide by filling in forms available through the Services. This includes information you provide when creating a User account, uploading User Content and/or otherwise using the Services.

Records and copies of your correspondence (including email addresses) if you contact us.

Your search queries on the Services.

B. Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with the Service, we and our third-party service providers may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Services.

Information about your computer, device, and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. However, if you select this setting you may be unable to access certain parts of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our App and Website.

Flash Cookies. Certain features of the Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Services. Flash cookies are not managed by the same browser settings that are used for browser cookies.

Web Beacons. Pages available through the Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

4. How We Use Your Information

We use Information and Data that we collect about you or that you provide to us, including any Personal Information in the following ways:

To determine your eligibility to be a Client, Administrator, or User, or to continue to have a Client account or User account on the Services.

To license the Software and provide our Services to you.

To provide you with information, products, or services that we offer or you request from us.

To fulfill the purposes for which you provided the Information or that were described when it was collected, or any other purpose for which you provide it.

To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.

To notify you about changes to our Services, either directly or through one of our partners, including for marketing and promotional purpose.

To improve, promote and develop our Services.

To provide you with user support, communicate with you and administer the Services, including troubleshooting.

To help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Services.

To allow you to participate in interactive features of the Services.

To enforce our terms, conditions and policies.

To facilitate payment transactions.

For any other purpose with your consent.

These uses improve the Services and better tailor it to meet your needs, so as to provide you with a secure, efficient and customized experience while using the Services.

5. Disclosure of Your Information

We may aggregate and anonymize your Data and use and disclose it for a variety of purposes, including analytics; however, in these situations, we do not disclose Personal Information. We may disclose Personal Information that we collect or you provide, as described in this Privacy Policy:

To our subsidiaries and affiliates.

In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Stratosphere’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Stratosphere about our customers and users is among the assets transferred.

To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Services improvement and optimization, cloud service providers, payment processors for the processing of payments) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Privacy Policy.

To fulfill the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

We may also disclose your Personal Information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

To enforce or apply our Terms and other agreements.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Stratosphere, our Users, or others.

6. Transferring Your Personal Information

We may transfer Personal Information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Privacy Policy.

We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada.

By submitting your Personal Information or engaging with the Services, you consent to this transfer, storage, or processing.

7. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. When accessing the Website or the Services, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may not be accessible or may not function properly.

Deleting your Content and Account. You can access and edit most of your profile information by signing into the Services. Should you choose to do so, you may delete your entire account. If your Client or User accounts are terminated, we will deactivate them, but we may retain your Information and Data for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy.

If you wish to delete your personal data, please reach out to us at [email protected] with a request to delete your account. We are committed to respecting your privacy choices and will process your request in a timely manner.

Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address or other contact information used by the us to promote products or services, you can opt-out by checking the relevant box located on the form on which we collect your Personal Information or by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.

8. Data Security

We strive to protect your Information and Data by putting in place a range of technical and organizational measures to safeguard and secure the Information and Data we receive from you, including without limitation, security technologies. We are continuously utilizing security measures to protect your Information and Data from unauthorized access or against loss, misuse or alteration. Despite our efforts, we cannot guarantee the security of your Information and Data. Unauthorized entry or use, hardware or application failure and other factors, may compromise the security of your Information and Data at any time. We reserve the right, without any limitation, to investigate any suspected breaches of the Services’ security or information technology or other systems or networks.

9. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

10. Accessing and Correcting Your Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at [email protected] to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your Personal Information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

● Information protected by solicitor-client privilege.

● Information that is part of a formal dispute resolution process.

● Information that is about another individual that would reveal their Personal Information or confidential commercial information.

● Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Team at [email protected].

11. Withdrawing Your Consent

Where we have asked for your consent to use and/or process your Information and Data, you can withdraw this consent at any time. We will do our best to accommodate your request, subject to applicable laws and the terms and conditions of this Privacy Policy. Please contact us at [email protected] if you would like to exercise any of the above rights

12. Changes To Our Privacy Policy

Stratosphere may amend this Privacy Policy from time to time. The use of Information and Data we collect is subject to the Privacy Policy in effect at the time the Information or Data is used. If we make any material changes in the way we use your Information or Data, we will notify you by (a) posting a notice on the Client or User account page of the Software or elsewhere on the Services; or (b) e-mailing you at your e-mail address associated with your Client or User account. Clients, and Users of the Services are bound by any changes to the Privacy Policy when they use the Services after such changes have been first posted.

13. Contact Information and Challenging Compliance

We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at [email protected].