This Privacy Policy applies to you if you: (a) purchase or use our products and services; (b) access or use any of our websites that display or link to this Privacy Policy; (c) provide, or authorize another person or organization to provide, personal information to us; or (d) sign up to receive or respond to our promotional emails or other marketing activities.

This Privacy Policy describes our policies and practices with respect to our handling of personal information. This Privacy Policy also describes the rights and choices you have regarding your personal information. In some circumstances, at the time of collection of your personal information, we may provide you with additional information regarding our handling of your personal information.

In this Privacy Policy, reference to our “products and services” includes all products and services offered through our website, including the Toolkit, Astoria, and H2H Copywriting.

This Privacy Policy explains how and why we handle personal information in connection with our business activities, and our products and services, and is made available to you by appropriate means before or when we collect your personal information. By providing (or authorizing another person or organization to provide) your personal information to us, you consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy and as otherwise permitted by applicable law. We might also obtain your additional consent in certain circumstances, including when required by law, to collect, use, disclose or retain your personal information for other specific purposes.

You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us, but then you might not be able to proceed with your intended interactions or transactions with us or otherwise receive the full benefit of our products and services. Please refer to section 8 of this Privacy Policy to learn about withdrawing your consent.

In addition, where permitted by applicable law, we may collect, use, disclose and retain your personal information without your consent.

In this Privacy Policy, “personal information” means information about an identifiable individual (i.e., a natural person), but does not include (to the extent permitted by applicable law) information that is: (a) anonymized (including as a result of aggregation) so that the information cannot be directly or indirectly associated with an identifiable individual; (b) business contact information that enables an individual to be contacted at a place of business; or (c) not subject to regulation by Canadian personal information protection laws, including certain publicly available information (e.g., information in a telephone directory).

We may collect the following personal information about you depending on your interactions with us and your use of our products and services:

• Identifiers and contact information, such as your full name, email address, postal address, telephone numbers and other information you provide to us when you contact us.

• Transactional information, such as details about your purchase or use of our products and services and your payment information (including your credit or debit card details).

• Information, including narratives, testimonials, and other content, that you voluntarily provide to us in connection with our products and services. This includes content you agree to contribute as part of storytelling or testimonial initiatives involving our clients, where you interact with the client as an employee, customer, or other similar capacity.

• Internet or other electronic network activity information (i.e., technical information when you access or use our website), such as your IP address, device ID, browser type, operating system, device type, data about the pages you access on our website or the functionalities used on our website, language preferences, email bounce backs, click-throughs, general geographic information, and clickstream data.

• Communications that we exchange with you, including when you contact or correspond with us for customer support or otherwise interact with us by telephone, online, email, or in-person.

• Marketing information, such as your preferences for receiving promotional communications about our products and services and details about how you engage with our communications and advertisements.

• Professional and career-related information and other information you submit to us when applying for a career opportunity.

• Any other information that you or another person or organization on your behalf provide to us.

• Inferences drawn from your personal information, such as your preferences and interests.

We collect personal information in various ways and from various sources, including information we collect directly or indirectly from you; information we collect from other persons and organizations, including when you authorize them to provide us with your personal information; and information we collect automatically through our website, emails and advertisements.

In some circumstances, you may choose not to provide certain requested personal information or withdraw your previous consent to the collection of your personal information, but then you may not be able to purchase, receive, or use our products and services or otherwise receive the full benefit of our products and services.

(a)           Directly from you

We may collect your personal information directly from you. For example, when you:

• purchase or use our products and services, including when you interact with our products and services through SMS or provide information through fillable forms;

• subscribe to our newsletters or other commercial electronic communications;

• contact, correspond, or otherwise communicate with us, including when you request customer support, make an inquiry or complaint, or report an incident or problem with our products and services.

If you give us the personal information of another individual, then you must take all measures, including obtaining the individual’s valid consent, to ensure that you have the lawful right to collect and disclose the information to us and for us to collect, use, disclose, and retain the personal information as explained in this Privacy Policy.

(b)           Indirectly from you

We may collect your personal information from other persons or organizations you authorize to provide the information to us, including as follows:

·         Our Clients: We may collect your personal information, such as your name and contact information, from our clients, where you interact with the client as an employee, customer, or other similar capacity, for the purpose of providing our products and services to such client;

·         Payment Processors: We may collect your personal information, such as your name and transaction information, from a payment processor for the purposes of providing our products and services, including to process your payments or confirm your payment for our products and services; and

• Other persons and organizations that purchase our products and services on your behalf or for your use.

(c)           Collection through website, emails, and advertisements

Our website, email messages, and advertisements may use technologies (e.g., cookies, web beacons, tokens, pixels or tags, and analytics engines) to automatically collect information about your access to and use of our website and our products and services, and your actions regarding email messages and advertisements. Some of those technologies may be operated by independent organizations, such as Google and Meta.

Some of the information automatically collected by technological means is non-personal information (because the information does not identify an individual), and we will deal with that non-personal information as explained in section 13 of this Privacy Policy unless applicable law requires otherwise.

For more information about the technologies we use to collect information through our website, email messages, and advertisements, and how you can manage your choices, see section 8 of this Privacy Policy.

(d)           Combining personal information

We may combine your personal information collected by us or on our behalf through the various sources described in this section 5.

We may collect and use your personal information: (a) for our general business and legal compliance purposes relating to or arising from our relationship and dealings with you and your use of our products and services; (b) to improve our business, products, and services; (c) to provide you with personalized information about our products and services and other products and services we consider might be of interest to you; (d) for additional specific purposes we may communicate to you; and (e) as otherwise permitted by applicable law. We may use your personal information to create non-personal information. We may transfer your personal information to our service providers to assist us to use your personal information.

(a)           General business and legal compliance purposes

We may collect and use your personal information for our general business and legal compliance purposes relating to or arising from our relationship and dealings with you and to provide you with products and services, including:

• processing your transactions with us and providing our products and services to you;

• providing you with receipts, statements, and other documents and information regarding your purchase or use of our products and services and as otherwise required by contractual or legal obligations;

• contacting and corresponding with you regarding your transactions and your use of our products and services and to provide you with customer care services;

• processing and responding to your inquiries, requests, and other communications;

• providing you with information (including by email and other electronic messages) regarding our business, products and services, and other products and services that might be of interest to you;

• complying with, and assessing compliance with, applicable laws, contractual and legal obligations, and our internal policies and procedures;

• preventing, detecting, and investigating fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and

protecting and enforcing our rights, interests, and remedies (including the enforcement of releases and waivers) and the rights, interests, and remedies of our customers and other persons and organizations.

(b)          Improving our business, products, and services)

We may collect and use your personal information to understand and analyze your use of our products and services with a view to improving our products and services and developing new products and services. If required by applicable law, we will use de-identified information for those purposes, so the information does not identify you directly.

Examples of our research and data analytics include:

• analyzing customer or user demographics;

• using web analytics services to analyze the use of our website.

(c)           Advertising and marketing purposes

We may collect and use your personal information to provide you with customized information, offers, and promotions regarding our products and services and other products and services that might be of interest to you, through our website and other websites, social media, and online services.

We may engage third-party advertising and social media companies to display advertisements for our products and services on websites, social media, and other online services. Those companies may use cookies and similar technologies to collect information about you and your interaction over time on their websites and online services and other websites and online services, and use that information to display advertisements that might be of interest to you. We may also share information about our customers with those companies to facilitate interest-based advertising to our customers and similar users on other websites and online services. You can learn more about your choices for limiting interest-based advertising in section 8 of this Privacy Policy.

(d)           Non-personal information

We may collect and use your personal information to create non-personal information (i.e., information that does not identify you, directly or indirectly) in accordance with applicable laws, and we may then use, disclose and retain the non-personal information as explained in section 13 of this Privacy Policy.

(e)           Service providers

We may transfer your personal information to our service providers (i.e., organizations that provide services to us) to assist us to use your personal information as explained in this Privacy Policy and as otherwise permitted by applicable law, including to help us: (i) operate our business; (ii) provide our products and services to you; (iii) provide, operate and maintain our information technology systems and services; (iv) operate our website; (v) process payments and complete transactions; (vi) create, print, and deliver emails and documents; (vii) detect and deter fraud; (viii) provide customer and user care services; (ix) conduct promotions, sweepstakes, contests, surveys, and other advertising and marketing activities and events; and (x) collect and analyze data.

Our service providers may be located outside Canada, as explained in section 9 of this Privacy Policy. Service providers are prohibited from using your personal information outside of the contracted purposes. If you have questions about our use of service providers or wish to obtain more information about our policies and practices relating to service providers, please contact our Privacy Officer using the information in section 15.

We may disclose your personal information to other persons and organizations: (a) for purposes relating to or arising from our relationship and dealings with you or to provide you with products and services; (b) in accordance with your additional specific consents; (c) as required or authorized by applicable law; and (d) in connection with a business transaction. We do not sell your personal information. The collection, use, disclosure, or retention of your disclosed personal information by those persons and organizations is not subject to this Privacy Policy.

(a)           General

We disclose your personal information for purposes relating to or arising from our relationship and dealings with you or to provide you with products and services (including transactions with you or on your behalf) and as otherwise explained in this Privacy Policy or permitted by applicable law.

(b)           Additional consents

We may disclose your personal information in accordance with additional consents (express or implied) that you give during your interactions and transactions with us or other persons and organizations, including to process your payments for our products and services.

(c)           Law enforcement/legal disclosures

We may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant, or court or arbitral order or litigation disclosure obligation. We may also disclose your personal information to law enforcement agencies or other independent organizations if we reasonably believe the disclosure is necessary or appropriate in connection with national security, law enforcement, or other issues of public importance (including tax and regulatory compliance), or if we reasonably believe the disclosure is necessary or appropriate to protect and enforce our rights, interests, and remedies or to protect and enforce the rights, interests, and remedies of our customers or other persons and organizations, including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service, or other agreements that govern access to or use of any of our products and services.

(d)           Business transactions

We may disclose your personal information in connection with a proposed or actual business transaction in which we are involved (e.g., a corporate amalgamation, reorganization, merger, or acquisition, or the sale or transfer of some or all of our business or assets). However, we will only disclose your personal information to the extent reasonably necessary for each transaction.

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You have choices about the way we handle your personal information.

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(a)           Opt out of marketing communications

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You can choose not to receive our marketing or promotional messages by email or text message by clicking on “unsubscribe” in an email or text message you receive from us. It may take up to ten (10) business days to register a change to your communication preferences.

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Please note that even if you indicate your choice not to receive marketing or promotional messages from us, we may still communicate with you by email or text message regarding your use of our products and services (e.g., to send you payment receipts and customer service messages) and as otherwise permitted by applicable law.

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(b)           Cookies

‍ Cookies are small text files stored on your computer that allow us to remember information about you. We use cookies to enhance your experience on our website so the next time you return to our site you do not have to select your preferred options again. We use cookies for the following purposes:

• ‍ Strictly necessary cookies: These cookies are necessary for the website to function and cannot be switched off through the Cookie Preference Center. You can set your browser to block or alert you about these cookies, but some parts of the website will not then work.

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• Analytics cookies: These cookies allow our website to collect information about how you interact with the website, including which pages you visit most often and if certain pages send you error messages. These cookies help us improve our services. If these cookies are blocked or disabled, our website may become less functional, including the potential that some of our services may no longer be available to you.

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• Functional cookies: Functional cookies allow our website to remember information, such as your preferred language, that can be used to customize your experience on our website. These cookies also can be used to provide you with information specific to your region, and may assist you in customizing our website’s appearance. If these cookies are blocked or disabled, our website may become less functional, including the potential that some of our services may no longer be available to you.

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• Targeting cookies: Targeting cookies are used by parties that are involved in serving other companies’ advertising on our website, or that are involved in determining which of our advertisements (or other parties’ advertisements) to show you on third-party websites. These cookies collect information about your online activities, such as the advertisements you have seen or the websites or pages you have visited, in order to draw inferences about what advertising might be relevant to you. This information is then used to show you targeted advertising (sometimes referred to as “interest-based advertising” or “online behavioral advertising”) that may be most relevant to you, including when you visit other websites not belonging to us. If these cookies are blocked or disabled, our website may become less functional, including the potential that some of our services may no longer be available to you.

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You can manage your preferences regarding cookies and similar technologies (including for cookies relating to advertising) using the cookie banner in the footer of our website.

Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change the settings. If you do not accept cookies, however, you may not be able to use all functionalities of our website or our website might not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

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We use Google Analytics to help us understand the use of our website. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

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Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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(c)           Advertising Choices

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You can limit the use of your personal information for interest-based advertising by:

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• Cookie Manager: using our cookie preference manager accessible through the cookie banner on our website to opt out of advertising cookies.

• ‍ Browser settings: blocking third party cookies in your browser settings.

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• Privacy browsers/plug-ins: using privacy browsers or ad-blocking browser plug-ins that block tracking technologies.

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• Platform settings: using platform/service provider settings to opt-out of use of your information for interest-based advertising:

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• Google: https://adssettings.google.com/

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• Facebook: https://www.facebook.com/about/ads

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• Instagram: https://accountscenter.instragram.com/ad_preferences/

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• Ad Industry Tools: opting out of interest-based advertisements from companies participating in the following industry opt-out programs:

• ‍ Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp

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• Digital Advertising Alliance: optout.aboutads.info.

• ‍ ‍ AppChoices mobile app, available at https://youradchoices.ca/en/tools.

• ‍ ‍Mobile device settings: using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

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(d)           Your mobile device settings

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Your mobile device settings may allow you to choose the way that we collect and use some of your personal information (e.g., your location) or communicate with you. Please refer to your device settings or user manual to learn about those settings.

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(e)           Withdrawing consent

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You may withdraw your consent to our collection, use, and disclosure of your personal information as explained in this Privacy Policy at any time on reasonable written notice to us, subject to legal or contractual restrictions. To withdraw your consent, you may contact us in writing using the contact information in section 20 of this Privacy Policy.

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If you withdraw your consent to our collection, use, and disclosure of your personal information for purposes that are integral to our relationship and dealings with you or your access to or use of our products and services, then you might not be able to proceed with your intended dealings with us or otherwise access, use, or receive the full benefit of our products and services.

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If you withdraw your consent to our collection, use, and disclosure of your personal information for purposes that are not integral to our relationship and dealings with you or your access to or use of our products and services, then withdrawing your consent for those purposes will not affect your access to or use of our products and services.

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If you withdraw your consent to our collection, use, and disclosure of your personal information, we may retain and use your personal information to comply with applicable law, to establish, enforce and exercise our rights and remedies, and for other purposes permitted by applicable law.

We are based in Canada. We and our service providers may use, process, and store your personal information at facilities in Canada and numerous other countries.

We and our service providers may use, process, and store your personal information outside of the province, territory or country where you live, including in Canada and the United States. The personal information protection laws of other jurisdictions might be different from the laws of the jurisdiction in which you reside, and might permit the government, government agencies, courts, law enforcement agencies, and national security authorities in those jurisdictions to access your personal information without notice. By providing your personal information to us, you consent to the transfer of your personal information to facilities located in other countries and the use, processing, and storage of your personal information at those facilities.

We retain your personal information for as long as necessary to achieve the purposes for which the information was collected as set out or referenced in this Privacy Policy, to comply with our legal obligations, and to enforce or protect our legal rights, or a longer period required or permitted by applicable law. We will then delete or destroy records of your personal information, or anonymize the information to use it for serious and legitimate purposes, in accordance with applicable law.

We use reasonable safeguards appropriate to the sensitivity and amount of personal information under our legal control to help protect the personal information from unauthorized access, collection, use, disclosure, deletion, or similar risks. Nevertheless, security risks cannot be eliminated, and we cannot guarantee that your personal information will not be accessed, used, disclosed, or deleted in ways not described in this Privacy Policy.

Depending on the sensitivity and amount of personal information under our legal control, the purposes for which it is used, and the format in which it is stored, we use a combination of measures – including administrative, physical, and technical security and safeguarding measures – to help protect the security of the personal information, including:

• A privacy framework governing the protection of personal information through its lifecycle.

• Technical safeguards, such as encryption, firewalls, passwords, and antivirus software, to protect personal information collected, used, or stored in electronic format.

• A designated individual accountable for our compliance with applicable privacy laws.

• Procedures for receiving, investigating, and responding to complaints or inquiries regarding our information handling practices.

• Contractual provisions and other measures to require our service providers to whom we transfer personal information to maintain adequate privacy protections and standards.

We will rely on you to ensure that your personal information held by us is as accurate, complete and up to date as necessary for the purposes for which we use the personal information. You must promptly notify is of any changes to your personal information using the functionalities available through our website, by contacting our customer service representatives, or by contacting our Privacy Officer using the contact information in section 20 of this Privacy Policy.

You may reasonably request access to your personal information under our legal control and information about our use, disclosure, and retention of your personal information by submitting a written request to our Privacy Officer using the contact information in section 20 of this Privacy Policy. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and have the information corrected as appropriate. You might be required to pay a reasonable fee for access to your personal information. We may decline to process an access request that is unreasonably repetitive, frivolous, vexatious, or impracticable, or if we reasonably believe the requested access would infringe or jeopardize the privacy of other persons, violate any applicable law or legal requirement, or for other reasons permitted by applicable law.

Depending on the jurisdiction where you reside, you may also be entitled to request the rectification or deletion of your personal information under our legal control if our collection, disclosure or retention of the information is not authorized by law.

We may use your personal information to create and collect aggregated or anonymized data, so that the information no longer relates to an identifiable individual. We may use, disclose, transfer, and retain non-personal information in accordance with applicable law.

If non-personal information is combined with personal information, then we will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with the personal information.

We have no responsibility or liability for, or control over, any independent business that is advertised by our products and services or correspondence, or their collection, use, disclosure, or retention of your personal information.

Our products and services and our correspondence (including emails) may include advertisements for independent businesses and their products and services or links to their websites. We have no responsibility or liability for, or control over, those independent businesses, their websites, products and services, or their collection, use, disclosure, or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure, and retention of your personal information by independent businesses or through independent websites or online services. If you have questions about how those independent businesses or their websites or online services collect, use, disclose, or retain personal information, please contact the owner or operator of the independent businesses, websites, and services.

We have no control over, or responsibility or liability for, the collection, use, disclosure, or retention of the personal information that you post to or share in connection with social media sites.

If you use certain aspects of our website or other services to post information to social media sites, the personal information that you post or share in connection with the social media sites is visible to other persons and can be read, collected, used, and disclosed by other persons. Any information provided to social media sites and other sites is governed by their own privacy policies. You are solely responsible for the personal information that you choose to post or share in those situations. We have no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations, and the use, disclosure, and retention of the disclosed information is not subject to this Privacy Policy.

We do not knowingly collect personal information from children under 14 years of age without the consent of their legal guardian.

If we learn that we have inadvertently collected or received personal information from a child without required parental or guardian consent, then we will delete the information unless the parent or guardian provides the required consent or we are required by law to retain the information. If you reasonably believe we might have any information from or about a child where parental or guardian consent was required, then please contact us using the contact information in section 20 of this Privacy Policy.

We in our sole discretion may change this Privacy Policy from time to time. We will post each revised Privacy Policy on our website at www.h2hcontent.com, and will provide additional notice of changes to this Privacy Policy as required by applicable law. All changes to this Privacy Policy will be effective when we post the revised Privacy Policy on our website, unless the revised Privacy Policy states otherwise. Our collection, use, disclosure, and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time.

By using any of our products and services after any change to this Privacy Policy is effective, you confirm your acceptance of the change and consent to our collection, use, disclosure, and retention of your personal information as explained in the revised Privacy Policy, except as may be expressly specified in the revised Privacy Policy. It is your responsibility to ensure that you read and understand the latest version of this Privacy Policy. The “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) is the date this Privacy Policy was last revised.

You consent to our sending you emails (to the email addresses you provide to us) regarding this Privacy Policy and related matters and as otherwise permitted by applicable law.

The agreements (e.g., including website terms of use and terms of service) that you accept (or are deemed to accept) when you use our website or purchase or use our products and services contain important provisions, including provisions disclaiming, limiting, or excluding our liability and the liability of other persons and organizations (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or our collection, use, disclosure, and retention of your personal information. Nothing in this Privacy Policy amends any of those other agreements.

If you have any questions or complaints about how we handle your personal information, or if you wish to withdraw your consent to our handling of your personal information, please contact our Chief Technology Officer by email (vanessa@h2hcontent.com) or phone (647-295-5114).