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For the purposes of applicable privacy laws, Portage Ventures GP Inc. and Portage Ventures II GP Inc. (collectively, with their subsidiaries and affiliates, “Portage”, “we”, “us”, “our”) are responsible for your personal information. Portage is committed to maintaining the confidentiality and security of your personal information. This Privacy Policy (the ‘Policy’) establishes guidelines with respect to our collection, use and disclosure of personal information that you may provide to us. In this Policy, the term “personal information” means information about an identifiable individual or that allows an individual to be identified, as more particularly defined or limited by applicable privacy laws.

Personal Information We Collect, Use and Disclose

We collect, use and disclose personal information from individuals for purposes permitted or required by applicable law, as described in this Policy or as we may indicate to you from time to time.

For example, we may collect personal information you provide when communicating with us, including by using our website, third party social media sites, or by subscribing to our e-mail notification service. Individuals who use our website or who subscribe to any of Portage’s e-mail notification services will find additional information regarding our online and e-mail personal information practices at: portagevc.com/terms-and-conditions/. The personal information we collect may include, without limitation, name, email address, telephone number and IP address.

If you apply for a position through the « Jobs » page of our Website, we will collect the personal information contained in your application package or generated in relation to your application and/or submit the same to the applicable portfolio company to which you are applying, for the purposes of evaluating your application and assessing whether to offer you a position. This may include information about your employment history and qualifications, as well as your name, residential address and contact details. If you are hired by us, the information will be retained, used and disclosed in accordance with our privacy policy applicable to the personal information of our employees (or the privacy policy applicable to the employees of the applicable portfolio company that hires you). If you are not offered or do not accept a position, we may retain this information for a reasonable period in the event that an appropriate position becomes available or that you re-apply.

We will use and disclose personal information for a number of reasons, including:

• to provide you with any email notification services you may request;
• to evaluate any job application you may submit and assess whether to offer you a position;
• where you have previously applied for a job, to keep in touch with you about available job positions which we think may be of interest to you;
• to ensure that our website runs smoothly and to improve the functionality of the website to better serve your requirements; or
• to meet legal, regulatory, industry, audit, security or ethical requirements.

Disclosure of your Personal Information

We may share your personal information with:

• third parties providing services on our behalf;
• our group portfolio companies and affiliates; or
• a regulator or law enforcement body.

We take reasonable contractual and other measures to require that the organizations with whom we share personal information maintain the confidentiality of personal information in accordance with applicable law and only use such information for the specific purpose for which we supply it to them.

International Transfers of Personal Information

In some circumstances, the sharing of personal information with third parties or other group or portfolio companies may involve the storage or processing of personal information outside Canada, including, without limitation, in the United States, Germany, France, the United Kingdom and Hong Kong. We will take reasonable steps to ensure that any international transfer of personal information is carried out in accordance with applicable privacy laws. The protection of such personal information will be subject to the legal requirements of the jurisdictions where the information is transferred, including lawful requirements to disclose information to government authorities in those countries. If you have any questions about the collection, use, disclosure or storage of personal information, please contact us as indicated below.

Consent

We collect, use and disclose your personal information internally or to third parties with your consent, or as may be permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. If you provide personal information to Portage, we assume that you consent to the collection, use and disclosure of your personal information as outlined to you at the time of collection or thereafter or as otherwise described in this Policy.

In some circumstances, you may refuse to consent to our collection, use and disclosure of your personal information, or you may withdraw your consent to further collection, use and disclosure of information about you, subject to contractual and legal restrictions and reasonable notice. Also, withdrawing your consent to certain uses of your personal information may mean that we may no longer be able to provide you with certain services.

Security

We take all reasonable precautions necessary to protect your personal information from misuse, interference and loss; unauthorized access, modification or disclosure.

Your Rights

The file containing your personal information will be kept at our offices or on our servers or those of our service providers and will be accessible to employees who require it for the purposes of their duties.

If you wish to request access to, or correction of, your personal information in our custody or control, or if you wish to withdraw your consent to the collection, use and disclosure of your personal information, please make your request in writing at 161 Bay Street, Toronto, Ontario, M5J 2S1, Canada, Attention: General Counsel. In some circumstances, we may not be able to provide you with access to your personal information or parts of it. We will advise you at the time of the request.

Inquiries or complaints about this Policy and our personal information practices may be directed to us at +1 (416) 607-2250, or at at 161 Bay Street, Toronto, Ontario, M5J 2S1, Canada, Attention: General Counsel.

Policy Changes

This Policy may be revised from time to time. You may contact us to obtain a current copy of this Policy. Your continued provision of personal information or use of our services following any changes to this Policy constitutes your acceptance of any such changes.

If you live within the European Union please see below for further information about your rights.

European Union Residents – Additional Privacy Information

Legal Bases for Using Personal Information

There are a number of different ways in which we are lawfully able to process your personal information. We have described these below.

1. Legitimate Interests
   We are allowed to use your personal information where it is in our legitimate interests to do so and it is not overridden by your interest. We believe that we have a legitimate interest in:
   • processing any job application that you might send us;
   • administering our website for internal operations, including troubleshooting, data analysis, testing, research, and statistical and survey purposes; and
   • keeping our systems secure and running smoothly.
2. Contractual Obligations
   We are allowed to use your personal information when it is necessary to do so for the performance of any contract we have with you.
3. Other Legal Obligations
   We are allowed to use your personal information when we need to in order to comply with legal obligations.
4. Consent
   We are also allowed to use your personal information where you have specifically consented. For example, we will obtain your consent to send you email notifications where you have requested them. You have the right to withdraw your consent at any time.

Your Rights

Applicable privacy laws in the European Union grant you the following rights in relation to your personal information:

• you can object to us processing your personal information in certain circumstances (for example, where we have done so on the assumption that it is in our legitimate interest to do so);
• you can ask what information we hold about you and be provided with a copy of such information and you can withdraw consent at any time;
• you can ask us to send you, or another organization, certain types of information about you in a format that can be read by computer;
• you may, in some cases, restrict our use of information about you (for example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy);
• if information is incorrect you can ask us to correct it;
• you have the right to ask us to assist you in transferring your personal information to a third party in certain circumstances; and
• you can complain to your local regulatory authority. The privacy regulatory authorities for each EU Member State are listed (along with contact details) on the following website: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Retention

We do not keep your personal information for longer than necessary for the purposes for which we collect it unless we believe that law or regulation requires us to preserve it.

When it is no longer necessary to retain your personal information, we will delete it from our systems, or put it beyond use.