Effective Date: January 25, 2024

1. Introduction

This Privacy Policy outlines the procedure followed by Cooler AI, (“CoolerAI,” “we,” “our,” or “us”) in collection, utilization and disclosure of consumer information. It includes consumer rights and choices about such use and sharing, and applies to any consumer interaction

with any online service location and any digital cooler door in any retail location that posts a link to this Privacy Policy including our website at and our cooler display technologies (collectively, the “Service”). This Privacy Policy does not apply to our information

collection activities outside of the Service (unless otherwise stated below or at the time of collection).

2. About this policy

This policy is designed to help the consumer understand our information collection practises depending on their relationship with us. This policy should be read with any other applicable policies, terms and conditions in place between the consumers and us. Any term or

provision contained in this Policy shall not apply to the extent that it is incompatible with relevant applicable statutory laws and regulations in the country or jurisdiction that applies to your personal information.

3. How is information collected

A. Through our Digital Cooler doors.

We work with retailers to deploy Digital Cooler doors in their stores. Our Digital Cooler doors use sensors and software to recognize the consumer demographic, their reaction to offers and products. No videos or images are taken or stored. The software develops statistics in

an encrypted code concerning the reaction of the consumers at the location of the Digital Cooler door. We use those statistics/encrypted code for purposes of understanding consumer trends and purchase behaviour.

CoolerAI does not collect or retain any information that individually identifies consumers.

B. Through the Website.

We collect information you provide when you use the Website. The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information you provide include the following:

Contact Data, including your first and last name, email address, postal address, and phone number.

Company Data, including your company’s name and postal address and no of licenses.

Content, including content within any messages you send to us (such as feedback and questions to customer support).

You may choose to voluntarily submit other information to us through the Website that we do not request, and, in such instances, you are solely responsible for such information.

C. Information Collected Automatically through the Website.

We automatically collect information in connection with your use of the Website. Some examples of information we automatically collect include the following:

Website Use Data, including data about the features you use, the pages you visit, any associated emails and advertisements you view, the time of day you browse, and your referring and exiting pages.

Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser.

Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Website. Persistent cookies may remain on your device for extended

periods of time, and generally may be controlled through your browser settings.

Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels

(which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a

particular device. We may incorporate pixels from third parties that allow us track our conversions, bring you advertising both on and off the Website, and provide you with additional functionality. For further information on Tracking Technologies and your rights and choices regarding them,

see the “Third Parties” and “Your Rights and Choices” sections below.

4. How we use the information collected.

We use information we collect in accordance with the practices described in this Privacy Policy,

including to:

Manage our Service.

Perform services requested by you.

Respond to your comments, questions, and requests, and provide customer service.

Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.

Prevent and address fraud, breach of policies or terms, and threats or harm.

Monitor and analyze trends, usage, and activities.

Conduct research, including focus groups and surveys.

Fulfill any other purpose disclosed to you or with your consent.

Not withstanding the foregoing, we will not attempt to identify individually any individuals from the information collected through the Digital Cooler doors, unless required by law or legal obligation. However, we may use information that does not identify you (including information that has

been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

5. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:

Service Providers. We share information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as camera technology, data analytics, marketing and advertising,

website hosting, and technical support. Service Providers are prohibited from using information about you for any purpose other than to provide this assistance, although we may permit them to use information that does not identify you (including information that has been aggregated or deidentified)

for any purpose except as prohibited by applicable law.

Investors. We share information with our investors. For example, we share information with our affiliates for customer support and technical operations.

Retailers. We share information with our retailer customers in connection with us providing Digital Cooler doors in their stores. For example, we share information for purposes of understanding how consumers interact with their products and helping them with product placement. We will not share

information that identifies you personally, unless required by law or legal obligations.

Media Buyers. We share information, such as headcount, with media buyers to help them manage and optimize their digital marketing campaigns.

Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights,

property, life, health, security and safety of the Service, any third party or us.

Consent. We may share information to fulfil any other purpose disclosed to you or with your consent. Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law.

For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below

6. Your Rights and Choices.

A. Tracking Technology Choices.

Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.

B. Communications.

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email.

7. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

8. International Transfer.

We are based in Canada and Canadian law governs the information we collect. If you are accessing the Service from outside of the Canada, please be aware that information collected through the Service may be transferred to, processed, stored, and used in Canada and other jurisdictions. Data protection laws in Canada and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in Canada and other jurisdictions as set out in this Privacy Policy.

9. Children.

We do not knowingly collect or use personal data from children under 16 years years of age. If we learn that we have collected any such data, it will be deleted immediately. If a child under 16 years has provided us with personal data, their parents or guardian may contact our officer from the contact information section.

10. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted.

11. Complaints.

If you have any complaints about how we process your data, please contact us through the contact method listed in the Contact Information section so that we can, where possible, resolve the issue.

12. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us. All privacy concerns will be directed to CoolerAI.