PRIVACY POLICY Byrd Mobile Inc.

Last Updated: August 22, 2026

Byrd Mobile Inc. (“Byrd Mobile,” “we,” “us,” or “our”), a company registered in Canada with its principal business address at 1505 Barrington St Ste 100, Halifax, NS B3J 3K5, is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard personal information when you interact with our website(s), mobile applications, products, services, or otherwise engage with us (collectively, the “Services”).

This Policy is designed to help us meet obligations under:

Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and substantially similar provincial laws (including Quebec’s Law 25 where applicable);
The EU General Data Protection Regulation (GDPR) and UK GDPR (where we process personal data of individuals in the EU/EEA/UK);
The California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) (where applicable to California residents).

By using our Services, you acknowledge the practices described in this Policy. Where required by law (especially under GDPR or for sensitive data), we will obtain your consent.

1. Who We Are / Data Controller

Byrd Mobile Inc. 1505 Barrington St Ste 100 Halifax, NS B3J 3K5 Canada

For privacy-related inquiries or to exercise your rights, contact us at: Email: privacy@byrdmobile.com

If we appoint an EU/UK representative or Data Protection Officer as required, their details will be provided here or upon request.

2. Personal Information We Collect

We collect personal information (also called personal data) that identifies, relates to, describes, or could reasonably be linked to you. Categories may include:

Information you provide directly:

Identifiers (name, email address, phone number, postal address, account credentials)
Commercial information (purchase history, service requests, payment details processed via third-party providers)
Communications content (messages, support tickets, feedback)
Any other information you voluntarily submit

Information collected automatically:

Device and technical data (IP address, browser type, device identifiers, operating system, mobile advertising IDs)
Usage data (pages viewed, features used, time spent, referring URLs)
Location data (approximate location derived from IP or, with permission, precise location)
Cookies, pixels, SDKs, and similar technologies (see Cookies section)

Information from third parties:

Service providers, analytics partners, advertising networks, social media platforms, or publicly available sources (where permitted)

Sensitive personal information (if collected): We only collect sensitive categories (e.g., precise geolocation, financial account details, health data, biometric data, or information revealing racial/ethnic origin, etc.) where necessary and with appropriate legal basis/consent. We limit use of sensitive information as required under CPRA and other laws.

We do not knowingly collect personal information from children under 13 (or higher age of digital consent where applicable) without appropriate parental consent. If we learn we have done so, we will delete it promptly.

3. How We Collect Information

Directly from you (forms, account registration, purchases, communications)
Automatically via cookies, analytics tools, server logs, and device permissions

4. Purposes and Legal Bases for Processing

We process personal information for the following purposes and, where GDPR applies, on these legal bases:

Purpose

Examples

Legal Basis (GDPR where applicable)

CCPA/CPRA Business Purpose

Provide and operate Services

Account creation, order fulfillment, customer support

Contract performance; Legitimate interests

Performing services

Communicate with you

Service updates, responses to inquiries

Contract; Consent; Legitimate interests

Communicating

Marketing and promotions

Newsletters, offers (with opt-out)

Consent; Legitimate interests

Marketing

Analytics and improvement

Understand usage, debug, develop features

Legitimate interests; Consent (cookies)

Research & development; Quality control

Security and fraud prevention

Detect/prevent abuse, secure systems

Legitimate interests; Legal obligation

Security

Legal compliance

Respond to legal requests, tax, regulatory

Legal obligation

Legal compliance

Business transfers

Mergers, acquisitions

Legitimate interests

Business transfers

We will not use personal information for purposes incompatible with those disclosed without further notice or consent where required.

5. Cookies and Tracking Technologies

We and our partners use cookies and similar technologies for essential functionality, analytics, personalization, and (where consented) advertising. You can manage preferences via our cookie banner/consent tool, browser settings, or device settings. For California residents, we honor Global Privacy Control (GPC) signals as a valid opt-out of sale/sharing where applicable. Details of specific cookies and partners will be listed in a Cookie Policy or banner.

6. How We Share Personal Information

We do not sell personal information for monetary consideration in the traditional sense. Under CCPA/CPRA, “sale” or “sharing” can include certain disclosures for cross-context behavioral advertising.

We may disclose personal information to:

Service providers / processors (hosting, payment processors, analytics, email, customer support) under contracts that limit their use of the data
Advertising and analytics partners (where consented or as permitted)
Affiliates or in connection with a business transaction (merger, sale of assets)
Legal authorities when required by law or to protect rights, safety, or property
Other parties with your consent

We require service providers to protect the information and use it only for the specified purposes. We do not allow them to sell or use the data for their own purposes beyond the contracted services.

California Notice of Collection / Categories Disclosed: In the past 12 months we may have collected and disclosed the categories listed in Section 2 for the business purposes above. We [do / do not] sell or share personal information for cross-context behavioral advertising. [Update accurately.] Sensitive personal information is used only for permitted limited purposes and is not sold/shared for additional purposes without the right to limit.

7. International Data Transfers

As a Canadian company, personal information may be processed or stored in Canada, the United States, the EU/EEA, or other countries. When transferring personal data from the EU/EEA/UK, we use appropriate safeguards such as Standard Contractual Clauses (SCCs), adequacy decisions, or other lawful mechanisms. For transfers from Canada, we ensure comparable protection through contractual means and due diligence, consistent with PIPEDA.

8. Data Retention

We retain personal information only as long as necessary for the purposes described, to comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary by data type and purpose (e.g., account data while active + [X] years; transaction records per tax laws; analytics logs for shorter periods). When no longer needed, we securely delete or anonymize the data.

9. Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, loss, misuse, or alteration. These include encryption in transit and at rest where appropriate, access controls, employee training, and regular reviews. No method of transmission or storage is 100% secure; we cannot guarantee absolute security.

10. Your Rights

Depending on your location, you may have the following rights (subject to legal exceptions and verification):

Under PIPEDA / Canadian law:

Access your personal information
Request correction of inaccurate information
Withdraw consent (where processing is based on consent)
Challenge our compliance

Under GDPR (EU/EEA/UK residents):

Access, rectification, erasure (“right to be forgotten”)
Restriction of processing
Data portability
Object to processing (including for direct marketing or legitimate interests)
Withdraw consent at any time
Lodge a complaint with a supervisory authority (e.g., your local DPA)

Under CCPA/CPRA (California residents):

Right to Know / Access (categories and specific pieces of personal information collected, sources, purposes, third parties)
Right to Delete
Right to Correct inaccurate personal information
Right to Opt-Out of Sale or Sharing of personal information
Right to Limit Use and Disclosure of Sensitive Personal Information
Right to Non-Discrimination for exercising rights
Right to data portability (in some cases)

How to exercise rights: Email us at privacy@byrdmobile.com or use any designated form/link on our website (“Do Not Sell or Share My Personal Information,” “Limit the Use of My Sensitive Personal Information,” or privacy request form). We will verify your identity and respond within the timeframes required by applicable law (generally 30–45 days, extendable where permitted). Authorized agents may submit requests with proper authorization.

You may also opt out of marketing emails via the unsubscribe link in those communications.

11. Children’s Privacy

Our Services are not directed to children under 13 (or the applicable age of consent). We do not knowingly collect their personal information. Parents/guardians who believe we have collected such information should contact us for deletion.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date will reflect changes. Material changes will be notified via the Services, email, or other appropriate means. Continued use after changes constitutes acceptance where permitted by law.

13. Contact Us / Complaints

For questions, concerns, or to exercise rights: Byrd Mobile Inc. 1505 Barrington St Ste 100 Halifax, NS B3J 3K5 Canada Email: privacy@byrdmobile.com

Canadian residents may also contact the Office of the Privacy Commissioner of Canada. EU/EEA/UK residents may lodge a complaint with their local supervisory authority. California residents may contact the California Privacy Protection Agency or the California Attorney General.