Canada Privacy Policy

1. INTRODUCTION

Overchain’s privacy policy. Overchain (Canada) Limited (“Overchain or the Firm”) is registered with the Fintrac with registration address at 100 University Ave, Toronto, ON M5J 1V6, Canada. The Firm is the controller and is responsible for your personal data (collectively referred to as the “Company”, “Overchain”, “The Firm”, “we”, “us” or “our” in this policy).

Overchain respects your privacy and is committed to protecting your personal data. This privacy policy (together with our Terms and Conditions, and any additional terms of use incorporated by reference into the Terms of Service applies to your use of:

• Overchain mobile application software (App) available on the Apple Appstore and Google Play Store, once you have downloaded our App onto your mobile telephone or handheld device (“Device”);
• Overchain.io (our “Website”) once you access our Website from your computer, mobile telephone or handheld device (Device);
• Any of the services accessible through our App and Website. all together (the “Platform”)

We will inform you as to how we process your personal data when you visit our Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Terms used within this Policy and Terms and Conditions shall have the meaning(s) given in the Regulation ‘Personal Information Protection and Electronic Documents Act (PIPEDA)’, as applicable.

Unless otherwise required by law and other applicable guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you or applicable legislation requires us to (e.g. PIPEDA), and we will give it back to you at any time (if possible).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

2. IMPORTANT INFORMATION

2.1 Purpose of this privacy policy

This privacy policy aims to give you information on how Overchain collects and processes your personal data through your use of our Platform, including any personal data you may provide through the Platform when you register as a user on our Platform.

Our Platform is not intended for children, and we do not knowingly collect personal data relating to children. The use of our Platform is not intended for persons under the age of 18. If you are not at
least 18 years old, you may not use our Platform at any time or in any manner. We do not knowingly collect or solicit any personal data from anyone under the age of 18 or knowingly allow such persons to create an account or our Platform. In the event that we become aware that we have collected personal data from a child under 18, we will delete that personal data as quickly as possible. If you believe that we have unlawfully collected personal data from a child under the age of 18 on the Platform, contact us at info@overchain.io.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

2.2 Controller

Overchain is the controller and responsible for your personal data. We have appointed a Data Protection Officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

2.3 Contact details

▪ If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer in the following ways;Email address: privacy@overchain.io;
▪ Postal address: C/O DPO, 100 University Ave, Toronto, ON M5J 1V6, Canada

You have the right to make a complaint at any time to us or the Office of the Privacy Commissioner of Canada.
Website: https://www.priv.gc.ca
Phone (Toll-free): 1-800-282-1376
Email: via secure online form at priv.gc.ca/en/contact-the-opc

We would, however, appreciate the chance to deal with your concerns before you approach the relevant authorities, so please contact us in the first instance.

2.4 Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. Updated privacy policy will be published on our website. We will inform you of such changes 30 (thirty) calendar days in advance by sending an email to the email address provided on your account. You will be entitled to notify us by email if you are not willing to be subject to the updated privacy policy before the updated privacy policy come into effect. In such a case, our relationship with you will be terminated. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.5 Third-party links

Our Platform may include links to and from third-party websites, plug-ins, links, partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username, title, date of birth and gender or similar identifier.

Contact Data includes billing address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.

Device Data: includes information about your hardware, for example the model of the Device you use, your Device’s operating system version, your battery capacity, your carrier, your time zone within which your Device is located (country/city), the CPU architecture of your Device, your connection type, your network type, your disk capacity, your screen resolution.

Content Data includes information stored on your Device, including login information, any content that is captured, recorded, filmed, posted, transmitted or otherwise made available and/or provided by you through the Platform ) that is captured, recorded, transmitted or otherwise made available and/or provided by you through the Platform.

Financial Data includes bank account and payment card details processed through our External Third Party providers.

Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

Profile Data includes your username and password, your Overchain account data, history of account settings, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our Platform and services, the resources that you access on our App, whether this is required by us to improve our App and/or user experience, fix usability issues, dimension our infrastructure or otherwise.

Location Data includes your current location disclosed by GPS technology and other similar technology.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the Terms of Service you have agreed with, and you fail to provide that personal data when requested, we may not be able to provide you with the services. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect personal data from and about you include through:

Information you provide to us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you provide to us by giving answers to questions asked on our Platform, or by corresponding with us (for example, by email or chat). It includes information you provide when you use or register to use our Platform, download or register our Platform, subscribe to any of our services, search for an App or service, make an in-App purchase, or other activities commonly carried out in connection with our Platform and when you report a problem with our Platform, our services. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit our Platform we will automatically collect personal data including Device, Content and Usage Data. For example, when you report a problem with our App or our Website, we log information in respect of your Device such as the version of the operating system you are using, the App version you are using and the time zone within which your Device is located. We also log when you are using and have last used our App, and what videos and other content you view on our App. We collect this personal data using cookies and other similar technologies. For more information on used cookies, please see our Cookie Policy.

Location Data. We also use GPS technology and other similar technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work.

Direct interactions. You may give us your Identity and Contact Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
▪ Apply to use our services;
▪ Visit our Website;
▪ Create an account on our App;
▪ Subscribe to our mailing list;
▪ Use our Platform;
▪ Request marketing to be sent to you; or
▪ Give us feedback or contact us.

Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookie and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below which include:
▪ Device Data from analytics providers such as Google, advertising networks such as HubSpot and verification providers such as SumSub.
▪ Technical Data from External Third Party for marketing or newsletters. Our transactional & newsletter emails are sent via HubSpot. In some of our email messages, we use a “clickthrough URL” linked to content on the Site. We track this click-through data to help us measure the effectiveness of our customer communications.
▪ Contact, Financial and Transaction Data from providers of technical and payment services such as SumSub.
▪ Identity and Contact Data from SumSub. Our support queries are managed via the HubSpot platform.
▪ Identity and Contact Data from publicly available sources.

5. COOKIES

You can adjust the preferences on our Platform to refuse all or some cookies. This helps us to provide you with a good experience when you use our Platform, remember your preferences and also allows us to improve our Platform. If you disable or refuse cookies, please note that some parts of our Platform may become inaccessible or not function properly. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our Cookie Policy .

6. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when we have a lawful legal basis.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Most commonly, we will use your personal data in the following circumstances:

• Where you have consented before the processing;
• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with legal obligations.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw consent to direct marketing at any time by contacting us.

6.1 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To use or install our Platform and register you as a new Platform user.	▪ Identity; ▪ Contact; ▪ Financial; ▪ Device.	▪ Performance of a contract with you.
To process purchases on our Platform and deliver services including managing payments and collecting money owed to us.	▪ Identity; ▪ Contact; ▪ Financial; ▪ Transaction; ▪ Device; ▪ Marketing and Communications; ▪ Location.	▪ Performance of a contract with you; ▪ Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship, communications with you including notifying you of changes to our Platform or any services.	▪ Identity; ▪ Contact; ▪ Financial; ▪ Profile; ▪ Marketing and Communications.	▪ Your consent; ▪ Performance of a contract with you; ▪ Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services); ▪ Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions.
To administer and protect our business and Platform (including troubleshooting, diagnostics, monitoring servers, data analysis, testing, system maintenance, support, reporting and hosting of data).	▪ Identity; ▪ Contact; ▪ Technical; ▪ Location.	▪ Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); ▪ Necessary to comply with a legal obligation.
To deliver content and advertisements to you. To make recommendations to you about goods or services which may interest you. To measure and analyse the effectiveness of the advertising we serve you. To monitor trends so we can improve our Platform.	▪ Identity; ▪ Contact; ▪ Device; ▪ Content; ▪ Profile; ▪ Usage; ▪ Marketing and Communications; ▪ Location.	▪ Your Consent; ▪ Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our Platform, products/services, marketing, customer relationships and experiences.	▪ Technical; ▪ Usage; ▪ Marketing and Communications.	▪ Consent ▪ Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.	▪ Identity; ▪ Contact; ▪ Technical; ▪ Usage; ▪ Profile; ▪ Marketing and Communications.	▪ Necessary for our legitimate interests (to develop our products/services and grow our business).
To establish, exercise, or defend of legal claims, legal proceedings, or regulatory investigations.	▪ Identity; ▪ Contact; ▪ Technical; ▪ Usage; ▪ Profile; ▪ Marketing and Communications.	▪ Necessary to comply with legal obligations; ▪ Necessary for our legitimate interests.

6.2 Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

6.3 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into our Platform and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase product/service experience or other transactions.

6.4 Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to process your personal data for a purpose that is not compatible with the original purpose for which it was collected, we will inform you in advance, explaining the applicable legal basis. Where required, we will seek your consent before proceeding. You also have the right to object to any new processing activities in accordance with your rights under applicable data protection laws.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by the applicable laws.

7. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table (Purposes for which we will use your personal data) above.

• Cloud Storage Provider which hosts our cloud storage system where we store our document management system and backups, ensuring your personal details are kept in a secure environment;
• Identity Verification Provider which manages the verification of information supplied to us, ensuring compliance with regulatory requirements and fraud prevention;
• Customer Relationship Management (CRM) which manages our support queries, facilitates email communications, and processes requests for removal from our mailing list;
• Automation and Workflow Integration Provider which enables automation and integration of various business processes, improving efficiency and operational workflows;
• Other service providers such as Google, and service providers who perform services and functionalities of the Platform on our behalf, including cloud storage and cloud computing, data analytics, or advertising;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
• Authorities. We may process and disclose your personal data when required to comply with legal obligations, court orders, or requests from regulatory authorities, law enforcement agencies, or other governmental institutions.

We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their
own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS

Sometimes we will need to store and process your personal data outside of Canada. Whenever we transfer your personal data outside of Canada, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide
  an adequate level of protection for personal data;
• Where we use certain service providers, we may use specific contracts approved by
  Canada which give personal data the same protection it has in the Canada;
• We will implement other appropriate security measures to ensure the protection of your
  personal data when transferred outside the Canada, in compliance with applicable data
  protection laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Canada.

9. DATA SECURITY

Overchain takes security seriously and cares about the integrity of your personal data.

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us, or our chosen third-party provider of payment processing services will be encrypted using appropriate encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a contractual need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

If you have any urgent security concerns, please email privacy@overchain.io.

10. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see (your legal rights) below for further information. However, please note that there may also be residual personal data that will remain within our databases and other records, which cannot be removed. For example, it is not technically feasible to remove deleted data from backups. We store anonymised records of all deletion activity in order to scrub any deleted data before using this residual/backup data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use our App for a period of 12 months then we will treat the account as expired and your personal data may be deleted, except personal data required to maintain by applicable laws.

11. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to yourpersonal data.

1. Request information about whether we hold personal data about you, and, if so, what that personal data is and why we are holding/using it.
2. Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. As part of our response to any data subject access request, we are also required to provide you with certain information about our processing of personal data.
3. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
4. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
5. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing of personal data on this legal basis. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
6. Object to automated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal data or profiling of you.
7. Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data, for example if you want us to establish its accuracy or the reason for processing it.
8. Request transfer of your personal data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your personal data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
9. Withdrawal of consent: Where we rely on consent as our legal basis for processing you have the right to withdraw consent to processing at any time by contacting us. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11.1 No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. In any case, we shall provide you with detailed reasoning of such decision.

11.2 What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If a representative wishes to exercise data subject rights on behalf of a data subject, they must provide a valid authorization document (e.g. Power of Attorney) as proof of authorization.

11.3 Time limit to respond

We try to respond to all legitimate requests without undue delay, but no later than within one month.

Our response period can be extended by up to two additional months, considering the complexity and number of requests. You will be informed of the extension within one month of making the request, along with the reasons for the delay.

If you wish to exercise any of the rights set out above, please contact us at, info@overchain.io.

11.4 Data protection of using digital assets and blockchains

Your use of digital assets may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of Personal Data, especially when blockchain data is combined with other data.

As blockchains are decentralized or third-party networks which are not controlled or operated by the Company, we are not able to erase, modify, or alter Personal Data on such networks.

11.5 How to Contact Us

If you have questions or concerns regarding this Policy or if you have a complaint, please contact us by our appointed Data Protection Officer (DPO) at privacy@overchain.io. If we are unable to satisfactorily address your concerns, you have the right to communicate with a relevant supervisory authority. We can direct you to the relevant supervisory authority in your jurisdiction.

11.6 Updates to the Privacy Policy

We reserve the right to alter, amend or modify this Policy from time to time, in our sole discretion. We will provide you with notice of such changes by sending you an email, providing notice on the homepage of the Platform and/or by posting the amended Policy on the Platform and updating the “Last Updated” date at the bottom of the Policy. The amended Policy will be deemed effective immediately upon posting on the Platform. Your continued use of the Platform and/or our Services constitutes your agreement to be bound by any such changes to this Policy. If you do not agree with this Policy or any amendment to it, you should discontinue access and use of the Platform and our Services.

Last updated 13 October 2025.