Privacy Policy

Trybe (Storybankit Inc.)

Effective date: February 1, 2021

Welcome to Trybe

Trybe is a social media platform where users can support and engage with creators and each other through their stories and content. This updated Privacy Policy applies to creators, and all users of our platform, and is part of our Terms of Use.

Privacy Statement

This Privacy & Cookies Policy (“Privacy Policy”) applies to the personal information we collect, use, disclose and otherwise handle when you use the Trybe http://www.trybe.ly​ website (“Website”) and the mobile application Trybe (“App”) The Website and the App (collectively, the “Services”) are owned and operated by Storybankit Inc. (“Trybe”), which is the data controller in respect of your personal information. [Our representative in the European Economic Area (“EEA”) can be reached at ​privacy@trybe/ly]. We encourage you to review the age rating standard applicable for your country of residence. If you are under  14  years of age, or otherwise have not reached the minimum age set out in standards applicable to your country of residence, you may not use the Services in any way. Trybe does not knowingly or intentionally collect information from children under 14. If we learn that we have received information directly from a child who is under the age of 14, we will delete the information.

Consent

Personal information will only be collected, used, or disclosed with your consent, except in certain circumstances permitted or required by law. The way in which we seek consent may vary depending upon the sensitivity of the information. Typically, we will seek your consent for the use or disclosure of your personal information at the time of collection. Each time that our application asks you for personal information, you will have an opportunity to provide your consent or decline it. We won’t use any of your personal information except for the purposes you consent to. If the same information is required for a new purpose, we won’t use it for that new purpose unless and until we get a fresh consent from you. COLLECTION AND USE OF PERSONAL INFORMATION We collect and use your personal information (i) to enable us to perform the contract entered into between you and us when you signed up to use the Services, (ii) for the purposes of our legitimate business interests and/or (iii) where we have your consent to do so. Specifically, we may collect and use personal information on the Website or the Apps when you:

  • Connect a third-party account to the Apps and engage with us on social media;

  • Purchase Digital Currency;

  • Exchange Digital Goods in our in-App Marketplace;

  • Participate in our contests or competitions;

  • Contact us with a comment, question, or complaint;

  • Sign-up to receive promotional communications from us or ask to receive notifications; and

  • Submit a post, comment, leave a reply, or upload content to the Trybe platform This is information that you provide to us through text fields, such as your name, payment information and benefits. The information we collect differs depending on if you make an account & become a user, or become a creator.

  • First and Last Name

  • Email Address

  • Username

  • Password

  • State and Country of Residence

  • Gender

You also have the option to add more information to your public profile, such as a location, an about section, which we store along with any comments or messages you submit and any content you upload not limited to photos, audio, and video content.

Users

A user is someone who joins Trybe’s social media platform and may choose to reward other users or creators and may choose to subscribe to creators through subscriptions. As a user you do not have to provide your payment information to our payment processors unless you choose to purchase rewards or withdraw rewards earned. You can see the privacy policy for this payment processor on the​ ​Stripe​ site. At this time, Trybe does not receive your full card number. Payment processors provide us with a token that represents your account, your card’s expiration date, card type and the last four digits of your card number. If you are required to provide your name and email address to the payment processor, then they also provide us with that information. We may collect and process information about the creators you support, the level at which you support them, and how often you support them.

Creators

A creator is someone who creates and provides premium content for their users through Trybe’’s subscriptions and rewarding. To become a creator, you must create a page that describes what you are creating and any benefits you are offering. To receive payouts you have to create an account with one of our payment partner: Stripe. We may also require your bank account information to process payouts. You must also provide us with additional information for tax purposes. Depending on your location you may have to fill out a form with some combination of your:

  • First and Last Name
  • Address
  • Social Security Number or Employer Identification Number
  • Country of Citizenship
  • Foreign Tax Identification Number
  • Date of Birth
  • Your Nonprofit Registration Number, if you are a nonprofit business
  • Bank Account Information for Payouts
  • Phone Number

Additional Information We Collect

Automatically Collected Information

We collect information automatically as you navigate the platform or through our third party analytics providers. We may store usage information such as the type of device you use to access Trybe, your operating system, browser type, IP address, and device ID, the pages you visit or request, links clicked, referring sites, user interactions and your search terms. We also derive your location from your self-disclosed country, your IP address, and from your payment card.

Feed and Messaging

When you navigate and engage with the feed or posted content, we collect the comments you make as well as record how many times users visit, the activity on the site, where users have replied, with whom they’ve communicated, private messages, IP address, and from which location the user was last logged in.

User Surveys

From time to time, we may solicit your participation in user surveys. We may ask you demographic information, including information related to your gender, ethnicity, race, age, sexual orientation, earnings, and accessibility to better understand and serve our user base which you may elect to share or not. We collect such information to ensure we provide fair and equal access to our services, and to

showcase creators to Trybe for greater discoverability. To the extent that you participate, we will store your survey responses. Purchasing Digital Currency: Using the App is completely free. We make in-App purchases available to our users who may choose to purchase virtual currency (“Digital Currency”) to reward other users or creators. Purchases of Digital Currency are paid for with real money and may also be withdrawn in the form of real money. If you choose to purchase Digital Currency, we may collect certain personal information including your name, email address, billing address, and payment card information. We use this information to process your transaction. We may also collect this information when your transaction is processed by another party, such as your Sign-in Partner or Stripe. The purchases you make through a Sign-in Partner account may be subject to additional policies and terms and we encourage you to review such policies and terms carefully before making an in-App purchase. Email and Push Notifications: You can sign up on the Website to receive our newsletter and other emails about promotions and information about Storybankit Inc. products and services. We collect your name and email address for the purposes of sending you these communications. You can opt out of receiving these emails from Trybe at any time by following the unsubscribe instructions included in our emails, or by contacting us at the contact information set out below. Please note that you may continue to receive certain transactional and account-related emails from us. If you access the App, we may also send push notifications to your mobile device to provide you with game updates, offers, and other game-related information, with your consent. You can manage these notifications in the “Settings” of your mobile device. SHARING OF PERSONAL INFORMATION We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law. Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. For example, we may use service providers for certain functions such as hosting of the Website and the

Apps. Our service providers are given the information they need to perform their designated functions, and are not authorized to use or disclose personal information for their own marketing or other purposes. We also use third party service providers to collect certain analytical information, such as the Apps features used and time spent on the Apps, to help us improve the quality of our Services, serve advertisements, and manage and analyze data about our users and our advertising effectiveness. These data are collected by our third-party service providers in an aggregate form that does not personally identify any individual Apps user. Your personal information may be maintained and processed by us, our affiliates, and other third-party service providers in Canada, the U.S., or other jurisdictions. Such jurisdictions may not have the same data protection laws as the jurisdiction in which you provided the information. When we transfer your information to other jurisdictions, including to jurisdictions outside of Canada or the European Economic Area, we will protect the information as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of information. By submitting your information to us, you agree to this transfer, storing, and processing. Legal and Compliance: We and our service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing, or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S., or other law or legal process. Your personal information may also be disclosed where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property. Sale of Business: Personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of LBC or the Hempire & Tasty Buds brand, or as part of a corporate reorganization, stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship. SAFEGUARDING AND RETENTION OF PERSONAL INFORMATION

We have implemented administrative, technical, and physical measures designed to safeguard personal information in our custody and control against theft, loss and unauthorized access, use, modification, and disclosure. We restrict access to information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements. We have information retention processes designed to retain information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal information are available by contacting us using the details provided at the end of this Privacy Policy. COOKIES, ADS, AND ADDITIONAL INFORMATION ABOUT THE WEBSITE AND THE APP We use this information to help us understand the activity on our Services, to monitor and improve our Services, and to tailor your in-game experience.

We process your information to:

  • verify your identity to comply with Canadian and international laws
  • allow you to sign in to your account
  • allow you to support a creator’s membership program on Trybe
  • process membership payments and payouts
  • Allow you to purchase rewards and earn rewards
  • send you emails relevant to your usage, as controlled by your email preferences
  • reply to your questions
  • provide to you existing and enhanced services related to your Trybe account
  • promote your Trybe account for greater discoverability
  • spotlight and celebrate creators
  • Market Trybe products and services to you or to audiences similar to you based on your networks and common factors that others have with you, unless you opt out, as controlled by your email preferences
  • understand how you use the service, and create better tools for creators to serve users
  • conduct research and development to improve Trybe and develop future products
  • prevent fraud and abuse on Trybe

Information We Share with Creators

By becoming a subscriber of a creator, you agree to have the following information shared with that creator:

  • your name and email address, and other profile information you’ve provided
  • any messages you send creators through Trybe
  • your physical address, city, state, and country
  • all information about your subscription, including amount and start date, but not your full payment card information
  • some aggregated and anonymized data about how you use Trybe that cannot be linked back to you or to any individual user

Information We Share with the Public

The following information is publicly accessible:

  • By default your Trybe profile unless you make it private
  • by default the creators you subscribe to. If you flag your account as private, we will not display the creators you subscribe to
  • any posts, likes, or comments you make
  • your aggregated or anonymized usage data in blog posts, press releases, or in other ways to share information about Trybe’s usage. Aggregated or anonymized data cannot be linked back to any individual Trybe user
  • number of users and creators

Cookies, Tracer Tags, and Beacons: We and our third-party providers, including Google Analytics, collect, process, store, and analyze information obtained from your browser or mobile device through the use of “cookies” or other tools such as “tracer tags” and “web beacons”. A cookie is a tiny element of data that the Website or Apps can send to your browser, which may then be stored on your computer or mobile device so that we can recognize you when you return. “Tracer tags” and “web beacons” allow us to understand your activity when you visit the Website or use the App. For more information on cookies and how they can be managed and deleted please visit ​http://www.allaboutcookies.org/​or ​http://www.networkadvertising.org/choices/​. We use the following cookies and other tools on the Website or the App, as applicable:

  • Strictly necessary cookies: these are essential in order to enable you to use the Website and its features as well as maintaining site security. Without these cookies, you would not be able to access the Services securely or at all.
  • Functionality cookies: these cookies are necessary for the Website to operate and allow us to remember what choices you make and provide enhanced, more personal features. The information these cookies collect do not track your browsing activity on other websites.
  • Analytical cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Website. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated. These tools help us track, measure, and analyze the behaviours and usage patterns of visitors to the Website and users of the Apps. We use this information to help us understand how

visitors engage with the Website and the Apps, and to improve and tailor our visitors’ and users’ experience.

  • Advertising cookies: these cookies are used to send you advertising and marketing-related material tailored to you and your interest, including where you log into the Website via a Sign-in Partner such as Facebook. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers. If you have connected a Sign-in Partner account to the Website and/or Apps, cookies may let us know who you are and provide us and our service providers with information that we will use to personalize your experience (for example by loading your Facebook profile image and name to the display in the game). You may set your Web browser to notify you when you receive a cookie or not to accept certain cookies. However, if you decide not to accept cookies from the Website or Apps, you may not be able to take advantage of all of the features of our Services. You can opt-out from being tracked by Google Analytics in the future by clicking on the following link: ​https://tools.google.com/dlpage/gaoptout​. For more information about Google analytics, see ​www.google.com/policies/privacy/partners/​. We do not use cookies in our App. However, we use other tracking tools to collect and process details of your user activity within the Apps in order to send you push notifications with game updates, offers, and other game-related information, or to serve tailored ads about our products and services to you on third-party social media platforms (which you may opt out of at any time). YOUR RIGHTS Subject to applicable law, you may have certain rights with respect to our processing of your personal information. You may have the right to request access to the information we hold about you, obtain confirmation as to whether or not information concerning you exists, be informed of the content and source of such

information, and check its accuracy. You may also have the right to correct, update, delete, block, cancel, or object to the use of your information held by us. If you are located within the EEA, you are afforded specific rights in respect of the personal information we hold about you. These are set out under a separate section below. If you change your mind and no longer wish to receive marketing e-mails from us, or if you wish to stop seeing tailored ads and other electronic messages on social media, you can request that we cease sending such e-mails or serving such ads. You may exercise your rights or the choices described above by contacting us at the contact information set out below, or by clicking the unsubscribe link displayed in any of our marketing e-mails. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. If you wish to stop receiving push notifications from us to your mobile device, you can turn off push notifications for the App in the settings of your mobile device.

Deleting Your Account

You may self-initiate a deletion of your account directly inside the Trybe App. Please be aware that this is a final act and cannot be reversed. Any rewards in your account will be deleted as well unless withdrawn prior to deletion. Any accounts with less than 5000 awards cannot be withdrawn prior to deletion. CALIFORNIA PRIVACY RIGHTS California law permits customers in California to request certain details about how their “personal information” (as defined by California Civil Code Section 1798.83) is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information upon request or permit California customers to opt in to, or opt out of, this type of sharing. California customers may request information about our compliance with this law by contacting us at [support@trybe.ly] or by postal mail at  3163  256th Street Langley BC V4W 1Y Canada.. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

EEA PRIVACY RIGHTS

If you are located in the EEA, you have a number of rights in relation to how we process your personal information. These include:

  • the right access the personal information that we may hold about you;
  • the right to rectify any inaccurate personal information that we may hold about you;
  • the right to have your personal information erased in certain circumstances, for example, where it is no longer necessary for us to process your personal information to fulfil our processing purposes; or where you have exercised your right to object to the processing;
  • the right to restrict the processing of your personal information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
  • the right to object to the processing of your personal information which may be exercised in certain circumstances, for example, where we are processing your personal information for direct marketing purposes, or where your own legitimate interests outweigh ours; and
  • the right to have your data ported to a new service provider if you no longer wish to use the Services. You may contact us using the contact details provided at the end of this Privacy Policy. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. Should you have cause to complain about how we handle your personal information, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the national data protection authority in the country in which you are located. UPDATES TO THE PRIVACY POLICY We may update this Privacy Policy periodically to reflect changes to our privacy and data practices. We encourage you to periodically review this policy. We will indicate at the top of this Privacy Policy when it was most recently updated. CONTACT US Please contact us if:
  • you have any questions or comments about this Privacy Policy;
  • you wish to update information we have about you or your preferences; or if you would like to exercise your rights of access, rectification, blocking, or deletion or to object to the processing of your information;
  • you are a parent or guardian and wish to review information collected from your child or have that information deleted. You may contact us by email at privacy@trybe.ly or write to us at: 3163 256th Street Langley BC V4W 1Y4 Canada. Governing Law and Dispute Resolution: This privacy statement, and all related matters, are governed solely by the laws of the province of Ontario, Canada and applicable federal laws of Canada, excluding all rules of private international law or the conflict of laws which would lead to the application of any other laws.