Privacy Policy

At Xplore, an important part of our commitment to provide you with service excellence is our respect for your right to privacy.

Keeping our customers' personal information and affairs in strict confidence is a cornerstone of Xplore's business.

In the following pages we describe these policies and procedures and how we put them into practice so that you have control over how we collect, use, and disclose your personal information.

Protecting your Privacy Means:

• we keep your personal information and the business you do with us in strict confidence;
• your personal information is not sold;
• you have control over how we obtain, use, and give out personal information about you;
• you have access to and can correct the personal information we have about you; and
• we respect your privacy when we market our products and services.

What Information is Covered By This Policy:

Our Privacy Policy protects your personal information. Personal information is identifiable information about a person (including customers and employees) that is protected by law. This can include a person’s name, email, address, network, billing information, and other identifiable information.

Personal information is not:

• Information relating to a business, including a person’s business contact information;
• Information that has been anonymized, de-identified, or aggregated such that it cannot reasonably be associated with a person; or
• Information about you that is already publicly available.

Sensitive Personal Information is personal information that, due to its nature, commands a high level of reasonable expectation of privacy. Sensitive personal information can include but is not limited to medical, financial, and biometric information. Personal information’s sensitivity can depend on its context as well. For example, personal information used as verification questions can be considered sensitive due to its role in protecting a person’s private information.

Why we collect your personal information:

Upon becoming a Xplore customer and upon acquiring new products and services, in addition to your name, address and phone number, you agree to provide us with all information needed to:

1. Provide our customers with our products and services.
2. Establish and maintain a responsible commercial relationship with our customers and provide ongoing services.
3. Understand customer needs and preferences.
4. Develop, enhance, market, or provide products and services.
5. Manage and develop business operations.
6. To meet our legal and regulatory requirements.

We use market leading data analytics technologies to help us inform and improve the uses described above.

Certain information, such as a driver's license, although convenient for identification, is voluntary. It is up to you whether you want to provide this, or some other suitable identification, subject to any legal requirements.

We collect, use and disclose personal information only for the purposes for which it was collected, for purposes consistent with the reason it was collected, or in ways that will clearly benefit you.

How we collect your personal information:

We mainly collect your personal information from you directly. This happens when you sign-up for new products or services with us, or when you reach out to us by phone, email, chat, or when you visit a retail store offering our products and services. We also receive information about you when you fill out a survey or participate in a contest.

Sometimes, we may collect personal information from you in the following ways:

• Automatically: Some information is gathered when you use a product or service, we provide you.
• Through digital channels: When using our website or mobile site, we may collect your personal information through means like cookies. You can review our policy on cookies here.

Your consent can be express or implied.

Your Implied Consent.

You imply consent when we can reasonably conclude that you've given consent by some action you've taken, or when you decide not to take action. For example, when you sign up for our internet service, we will use the address you provide to send you bills or other important notices. If we rent to you a piece of equipment, we can conclude that you have consented to the conditions. If we give you an opportunity to tell us you don't want direct marketing material and you don't tell us that you don't want us to send it, we can conclude that you have no objection.

We will rely on your implied consent to use and disclose personal information about you in a manner consistent with the purposes we collected it for.

Your Express Consent.

How we obtain your consent depends on the circumstances, including the nature of the personal information collected, used, or disclosed. For more sensitive personal information, we will always seek your express consent when using it for new purposes or to disclose it to third parties.

We also obtain your express consent before we:

• obtain a credit report
• use your personal information in any way we didn't tell you about previously

You give us your express consent by explicitly letting us know you agree with us collecting, using, or disclosing your information. You can do this verbally or in writing, including in a letter, e-mail, or by ticking a box in an online form.

You Can Withdraw Your Consent After You've Given It

You can withdraw your consent any time after you've given it to us, provided there are no legal requirements to prevent this. However, in order to maintain the integrity of the credit reporting system, we do have to update your credit information with the credit bureau as long as you have credit with us. Your consent for this purpose cannot be withdrawn during this time.

If you don't consent to certain uses of information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we'll explain the situation to you to help you with your decision.

We Get Your Consent Before Sharing Personal Information With Other People

We don't share information about you with any of our affiliates, or release it to anyone outside of Xplore without your express or implied consent. We will never share sensitive personal information without your express consent, unless required by law. For example, we give information to a credit bureau only with your express consent.

There are some exceptions to this rule. For example, we may collect, use or disclose personal information without your express or implied consent if:

1. We use an outside company to process information or to deliver services. At times we may use the expertise of an outside company to do work for us involving some of your personal information. We may disclose your personal information to the following types of third parties when needed:

1. Dealer and retail sales agents;
2. Installation crews and third-party contractors;

1. 1. Shipping companies;
   2. IT and Network vendors;
   3. Direct Mail vendors;
   4. Advertising companies;
   5. Customer Relationship Management Cloud Software;
   6. Analytics companies;
   7. Digital and Web agencies; and,
   8. Collection agencies.
2. We must disclose information for legal reasons. We may be compelled to release information by a court of law, or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to.
3. We have to protect the interests of Xplore. In certain circumstances, Xplore may have to collect, use or release information for its protection. For example, we may do so when returning a cheque for the reason "Not Sufficient Funds", when collecting an overdue account, when realizing on security pledged for a loan, or to detect or prevent fraud.

Only authorized employees have access to your personal information.

Our employees who have access to your personal information are made aware of how to keep it confidential. Each employee is subject to obligations to protect the confidentiality of personal information in accordance with company policy, and satisfying such obligations is a condition of employment with Xplore.

This protects your information at all times, when it is stored in data files or handled by our employees.

For Québec residents, the personal information that we collect from you is stored securely with that of the rest of our customer data outside of Québec. Your personal information is safeguarded in a manner consistent with applicable privacy laws.

You can check your information to verify, update and correct it, and to have any obsolete information removed. We may ask you to put your request in writing.

There's no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records, which we have already given you. We will let you know in advance if there is a charge.

If you have a sensory disability, we will give you access to your personal information in any alternative format you request if we already have it in that format, or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.

It may not be appropriate for us to release certain information directly to you.

You can check much of your information routinely – for example, by examining documents that we send to you, such as any statements of account.

If we have obtained information about you from other people, upon your request, we will let you know the person we got it from.

If you ask, we will let you know the names of outside companies or organizations we've given information to. This won't include information given to outside companies we've used to do work for us, such as direct mail marketing companies. It won't include particulars of cheques returned for the reason "Not Sufficient Funds" or otherwise, or regular updates of credit information to credit bureaux.

We'll deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we'll tell you why, subject to any legal restrictions and we'll notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.

Whenever possible, we'll correct any information which we may have given to an outside organization. If a third party, such as a credit bureau, has given us information which you tell us is wrong, we'll give you the name and address of that party so that you can correct the information.

There may be files that include information about you and other customers, or that have information confidential to Xplore, or are the property of Xplore. Because we must protect everyone's confidentiality and legal rights, we cannot make these files available to persons outside of Xplore. However, we will make available to you any factual information about you contained in such files.

We have procedures in place to assist our employees in the practice of this Privacy Policy. Senior management of the company oversees the practice of these policies on a regular basis.

If you have any questions or complaints about our Privacy Policy, or about how we are living up to them, let us know right away. You can contact our Chief Privacy Officer at [email protected].

Xplore is committed to treating you with the greatest respect and consideration, and providing the highest level of service. Even so, from time to time something may go wrong. There may be a misunderstanding, or you may feel you have been dealt with unjustly. Whatever the circumstances, resolving the problem for you is our primary concern.