Privacy Policy

1001689754 Ontario Inc. operating as PatchLead

PRIVACY POLICY 1001689754 Ontario Inc. Operating as PatchLead DOCUMENT INFORMATION Item Details Legal Entity 1001689754 Ontario Inc. Operating Name PatchLead Primary Platform PatchLead Lead Generation Platform Consumer Websites 2plumbers.ca, 2hvac.ca, hvaclines.ca and future consumer service websites Jurisdiction Ontario, Canada Applicable Privacy Framework PIPEDA and applicable Canadian privacy requirements TABLE OF CONTENTS

1. INTRODUCTION

1001689754 Ontario Inc., operating as PatchLead ("PatchLead," "Company," "we," "us," or "our"), respects the privacy of individuals whose personal information it collects, uses, or discloses. PatchLead operates a technology-based lead-generation and connection platform that facilitates connections between consumers seeking home services and independent service providers. PatchLead's services may be provided through:

patchlead.ca;
2plumbers.ca;
2hvac.ca;
hvaclines.ca;
future consumer-facing websites;
online service-request forms;
telephone systems;
AI-assisted voice systems;
automated callback systems; and
provider registration and account systems. This Privacy Policy explains how PatchLead handles personal information, including what information it collects, why it collects it, how it is used and disclosed, how it is protected, and what rights individuals may have.

2. ABOUT PATCHLEAD

PatchLead is operated by: 1001689754 Ontario Inc. Operating As PatchLead PatchLead is a technology and lead-generation platform. It connects consumers seeking home services with independent service providers that may be able to respond to their requests. PatchLead does not itself provide:

plumbing services;
HVAC services;
cleaning services;
repair services;
construction services; or
other home-service work. The independent service provider is responsible for the services it provides to a consumer, including its pricing, workmanship, licensing, insurance, warranties, and contractual obligations.

3. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy explains PatchLead's privacy practices and is intended to provide individuals with meaningful information about the Company's handling of personal information. It explains:

what personal information PatchLead collects;
how information is collected;
why information is collected;
how information is used;
when information is disclosed;
the categories of organizations that may receive information;
how information is protected;
how information is retained and destroyed;
how individuals may request access or correction;
how consent may be withdrawn;
how privacy complaints are handled; and
how to contact the person responsible for privacy matters. This Privacy Policy is a description of PatchLead's privacy practices. It is not, by itself, the consent mechanism for every collection, use, or disclosure of personal information. Where consent is required, PatchLead will obtain consent through the applicable point-of-collection notice, form, telephone disclosure, electronic mechanism, or other appropriate method.

4. DEFINITIONS

4.1 Personal Information

"Personal information" means information about an identifiable individual, as defined by applicable privacy legislation. Depending on the circumstances, this may include:

name;
telephone number;
email address;
service address;
postal code;
location information;
service-request information;
call records;
voice recordings;
communications;
account information;
consent records; and
other information capable of identifying an individual.

4.2 Consumer

"Consumer" means an individual who visits a PatchLead consumer website, submits a service request, communicates with PatchLead, or otherwise uses a consumer-facing PatchLead service.

4.3 Service Provider / Buyer

"Service Provider" or "Buyer" means an independent home-service business or contractor participating in the PatchLead platform.

4.4 Lead

"Lead" means information relating to a consumer's service request that may be used to facilitate a connection with a participating service provider.

4.5 Qualified Call

"Qualified Call" means a call or connection that satisfies the applicable qualification criteria established for the relevant service category, campaign, or Buyer.

4.6 AI Voice Agent

"AI Voice Agent" means an automated or AI-assisted voice system used by PatchLead to communicate with consumers, collect or confirm information, qualify service requests, or facilitate connections.

4.7 Privacy Officer

"Privacy Officer" means the individual designated by PatchLead to be accountable for the Company's privacy compliance and privacy management activities.

5. SCOPE AND APPLICATION

This Privacy Policy applies to personal information collected, used, disclosed, or otherwise processed by PatchLead through its websites, platform, communications systems, and related services. It applies to information collected through:

patchlead.ca;
2plumbers.ca;
2hvac.ca;
hvaclines.ca;
future PatchLead consumer websites;
service-request forms;
telephone systems;
AI-assisted communications;
email and messaging;
provider registration systems;
customer support; and
cookies and similar technologies. Where an independent third party collects or processes personal information under its own responsibility, that third party's own privacy policy may also apply.

5.1 Québec Application

Where Québec privacy legislation applies to PatchLead's activities, PatchLead will comply with the applicable Québec requirements described in this Privacy Policy and implemented through its privacy procedures. PatchLead will maintain governance practices concerning:

protection of personal information;
retention and destruction;
employee responsibilities;
privacy complaints;
privacy impact assessments; and
other requirements applicable to its Québec activities. Québec's private-sector privacy legislation requires an enterprise to establish and implement governance policies and practices and to publish detailed information about those policies and practices in clear language.

6. PATCHLEAD'S ROLE AS A CONNECTION PLATFORM

PatchLead facilitates connections between consumers and independent home-service providers. PatchLead may: 1. receive a consumer service request; 2. collect information necessary to understand the request; 3. qualify the request; 4. identify potentially matching providers; 5. provide relevant information to those providers; 6. facilitate a telephone connection; and 7. maintain records necessary for billing, quality assurance, security, dispute resolution, and legal compliance. PatchLead does not itself perform the home-service work.

6.1 What Happens When a Consumer Submits a Request

When a consumer submits a service request, the consumer's relevant information may be shared with one or more independent service providers whose services match the request. A consumer should understand that a service provider who receives the request may contact the consumer by telephone or another permitted communication method regarding the requested service. The consumer is not required to hire a provider merely because the provider was introduced through PatchLead.

6.2 Compensation for Connections

Participating service providers may pay PatchLead for qualified calls or other qualifying service opportunities. PatchLead does not sell consumer information to unrelated data brokers or unaffiliated lead marketplaces and does not make consumer service-request information available for resale to such parties. Information may be shared with participating home-service providers where reasonably necessary to facilitate the consumer's requested service connection.

7. INFORMATION WE COLLECT

PatchLead collects information necessary for identified purposes and limits collection to information reasonably necessary for those purposes. Information may be collected:

directly from individuals;
automatically through websites and technology;
through telephone communications;
through service providers;
through third-party service providers acting on PatchLead's behalf; and
from other lawful sources. Categories may include:
identification and contact information;
service-request information;
location information;
communication information;
technical information;
account information;
transaction information;
consent and preference records;
call recordings and related metadata; and
information relating to privacy requests or complaints.

8. CONSUMER INFORMATION

When a consumer submits a service request, PatchLead may collect information necessary to process and facilitate that request. This may include:

name;
telephone number;
email address;
postal code;
service address;
requested service;
description of the issue;
urgency;
preferred timing;
information provided during qualification; and
information provided during telephone communications.

8.1 Consent and Preference Records

Where consent is required, PatchLead may record:

the individual giving consent;
the purpose of consent;
the date and time;
the communication channel;
the version of the applicable consent wording;
relevant telephone number or account identifier; and
withdrawal or opt-out information. Consent will be obtained through the applicable point-of-collection mechanism rather than treating this Privacy Policy itself as blanket consent.

9. SERVICE PROVIDER INFORMATION

PatchLead may collect information from businesses and representatives that register as Buyers. This may include: Business information

business name;
services offered;
service areas;
licensing information where applicable. Representative information
name;
business email;
telephone number;
business address. Account information
login credentials;
account settings;
user roles;
account activity. Billing information
wallet balance;
transactions;
charges;
credits;
refunds;
payment status;
payment-provider identifiers. PatchLead does not intentionally store complete payment-card numbers where payment information is entered directly into a third-party payment processor.

10. WEBSITE AND TECHNICAL INFORMATION

When an individual visits a PatchLead website, certain technical information may be collected automatically. This may include:

IP address;
browser type;
device type;
operating system;
pages visited;
date and time of access;
referral source;
website interactions;
general geographic information; and
cookie or similar technology identifiers. PatchLead may use this information to:
operate websites;
maintain security;
diagnose technical problems;
measure website performance;
understand website usage;
improve functionality; and
measure advertising and conversion activity. Non-essential analytics, advertising, or tracking technologies will be handled through the applicable consent mechanism where consent is required by law. The specific technologies used on each website may differ. Additional information is provided in PatchLead's Cookie Policy.

11. AI VOICE AGENT AND AUTOMATED COMMUNICATIONS

PatchLead may use an AI-assisted voice agent to communicate with consumers who have submitted a service request or otherwise requested contact through a PatchLead website. The AI Voice Agent may:

confirm information submitted by a consumer;
ask questions about the requested service;
collect additional service-request information;
determine whether the request meets applicable qualification criteria;
facilitate a connection with a participating service provider; and
maintain records of the interaction for the purposes described in this Privacy Policy. The AI Voice Agent may process information including:
name;
telephone number;
service address or postal code;
requested service;
responses to qualification questions;
voice and conversation content;
call date and time;
call-transfer information; and
qualification results.

11.1 AI Identification

When a consumer communicates with an AI Voice Agent, PatchLead will identify the interaction as being conducted with an AI-assisted or automated voice system at the beginning of the applicable call. The disclosure will also identify when the call is being recorded.

11.2 Purpose of AI Processing

PatchLead uses AI-assisted voice technology primarily to:

respond to requested callbacks;
qualify service requests;
confirm service information;
determine whether a request meets applicable connection criteria; and
facilitate connections with participating service providers. PatchLead does not use the AI Voice Agent to enter into a service contract between a consumer and a service provider.

11.3 Human Review

PatchLead may conduct human review of AI-assisted interactions for purposes including:

quality assurance;
dispute resolution;
fraud prevention;
security;
accuracy review;
system monitoring; and
legal or regulatory compliance. However, where a particular qualification or matching decision is made exclusively through automated processing, PatchLead will treat that process as automated decision-making where applicable law requires it to do so.

12. TELEPHONE CALL RECORDING

PatchLead records telephone calls involving its platform for legitimate operational purposes, including calls handled by its AI Voice Agent and calls transferred to participating service providers. Call recordings are personal information and are handled in accordance with applicable privacy requirements. The Office of the Privacy Commissioner of Canada recommends informing callers at the beginning of a recorded call, identifying the purposes of recording, and obtaining meaningful consent.

12.1 Recording Disclosure

At the beginning of a recorded call, PatchLead will provide a clear notice that: 1. the call is being recorded; 2. the recording is being made by or on behalf of PatchLead; and 3. the purposes of recording include the purposes described below. The applicable recording disclosure may be provided through an automated announcement or another appropriate method.

12.2 Purposes of Recording

PatchLead may use recordings for:

billing verification;
determining whether a call meets applicable Qualified Call criteria;
quality assurance;
dispute resolution;
fraud prevention;
security;
training or quality review where permitted by this Privacy Policy; and
legal or regulatory purposes. PatchLead will not describe one purpose to a caller while secretly using the recording for materially different purposes.

12.3 Consumer Objection to Recording

Where applicable law requires an individual to have a meaningful choice regarding recording, PatchLead will provide an appropriate mechanism for the individual to decline recording or use an available alternative method of communication. If recording is necessary for a particular service or transaction and no practical alternative is available, PatchLead will explain the relevant consequence to the individual.

12.4 Access to Recordings

Subject to applicable legal exceptions, an individual may request access to personal information contained in a call recording. PatchLead may verify the individual's identity before providing access and may provide the information in a transcript, recording, or other appropriate form.

13. LEAD QUALIFICATION AND AUTOMATED DECISION-MAKING

PatchLead may use automated systems, including its AI Voice Agent, to determine whether a consumer service request satisfies predefined qualification criteria. Qualification criteria may include:

requested service;
geographic service area;
consumer responses;
service requirements;
call duration;
connection status;
applicable campaign requirements; and
participating service-provider requirements. The applicable criteria may vary by service category, campaign, geographic area, or Buyer.

13.1 Automated Qualification

Where the AI Voice Agent makes a qualification decision without human intervention, the process may constitute automated processing. PatchLead will not represent that a human reviewed every qualification decision where no such review occurred. Where Québec or other applicable privacy legislation provides specific rights concerning decisions based exclusively on automated processing, PatchLead will provide the applicable notice and rights.

13.2 Québec Automated Decision Rights

Where Québec legislation applies and a decision concerning an individual is based exclusively on automated processing of personal information, PatchLead will provide the information and mechanisms required by applicable law. Where applicable, an individual may request information concerning:

the personal information used to make the decision;
the principal factors and parameters involved in the decision; and
the means available to submit observations to a member of PatchLead personnel responsible for reviewing the decision. PatchLead will provide the applicable review mechanism required by law.

13.3 Qualification Does Not Guarantee Service

A qualification decision does not guarantee that:

a service provider will accept the request;
a consumer will hire a provider;
a service will be available;
a particular price will be offered; or
the requested work will be performed. PatchLead's role is to facilitate the connection.

14. HOW PATCHLEAD USES PERSONAL INFORMATION

PatchLead may use personal information for the following purposes:

14.1 Requested Service Connections

To:

process service requests;
understand consumer requirements;
qualify requests;
identify matching providers;
transfer calls;
facilitate communications.

14.2 Platform Operations

To:

operate websites;
manage accounts;
administer provider wallets;
process transactions;
maintain billing records;
provide support.

14.3 Quality and System Improvement

To:

evaluate call quality;
monitor platform performance;
identify technical problems;
improve qualification processes;
improve website functionality;
evaluate AI-assisted systems. PatchLead will use identifiable personal information for system improvement only where such use is permitted by applicable law and consistent with the purposes communicated to the individual.

14.4 Security and Fraud Prevention

To:

detect fraud;
prevent unauthorized access;
investigate suspicious activity;
prevent platform abuse;
resolve disputed transactions.

14.5 Legal Compliance

To:

comply with applicable laws;
respond to lawful requests;
establish or defend legal rights;
maintain legally required records;
investigate suspected unlawful activity.

15. DISCLOSURE TO MATCHING SERVICE PROVIDERS

When a consumer submits a service request, PatchLead may disclose relevant information to one or more independent service providers whose services reasonably match the request. Information may include:

name;
telephone number;
email address where appropriate;
service location;
requested service;
service-request details;
relevant qualification information. The purpose of the disclosure is to facilitate the connection requested by the consumer.

15.1 Consumer Understanding

By submitting a service request, the consumer should understand that the information necessary to facilitate the requested connection may be provided to matching service providers. The provider may then contact the consumer regarding the requested service. PatchLead does not control the independent provider's subsequent service relationship with the consumer.

16. THIRD-PARTY SERVICE PROVIDERS

PatchLead uses third-party vendors and technology providers to operate its platform. These may include providers for:

cloud hosting;
telecommunications;
AI voice technology;
analytics;
advertising and conversion tracking;
payment processing;
security;
email and messaging;
customer support;
data storage. PatchLead remains accountable for personal information under its control when it is processed by a third party on PatchLead's behalf. PatchLead will use contractual or other appropriate safeguards designed to require third-party processors to:
process information only for authorized purposes;
protect confidentiality;
implement appropriate security safeguards;
notify PatchLead of relevant privacy or security incidents;
assist with applicable privacy obligations; and
return, delete, or otherwise handle information appropriately when the processing relationship ends. Where a vendor's processing involves a new or materially different purpose, PatchLead will assess whether additional notice, consent, contractual protection, or other privacy measures are required.

17. PAYMENT PROCESSING

PatchLead uses third-party payment processors to process payments from participating service providers. Payment information may be entered directly into the payment processor's system rather than being stored by PatchLead. PatchLead may receive limited information such as:

payment confirmation;
transaction status;
payment-provider identifier;
billing history;
wallet balance;
refunds; and
credits. PatchLead does not intentionally store complete payment-card numbers entered directly into the applicable payment processor.

18. COOKIES AND TRACKING TECHNOLOGIES

PatchLead websites may use:

cookies;
pixels;
tags;
scripts;
analytics technologies;
advertising technologies; and
similar tracking technologies. These technologies may be used to:
operate essential website functions;
maintain security;
remember preferences;
analyze website usage;
measure advertising;
measure conversions;
improve website performance. Where applicable law requires consent for a non-essential technology, PatchLead will obtain the required consent before activating that technology. The specific technologies may differ between PatchLead websites. For details regarding individual technologies and cookie choices, individuals should consult the applicable Cookie Policy.

19. AI TRAINING AND SYSTEM IMPROVEMENT

PatchLead does not use identifiable consumer voice recordings to train or develop AI models. Voice recordings may be used for the purposes described in this Privacy Policy, including:

qualification;
billing verification;
dispute resolution;
quality assurance;
fraud prevention;
security; and
legal or regulatory purposes. Where PatchLead uses information to improve its systems, PatchLead will use de-identified transcripts, aggregated information, or other information that does not identify the individual where reasonably practicable. PatchLead will not authorize a vendor to use identifiable consumer voice recordings for unrelated AI-model training purposes unless such use is separately permitted by applicable law and supported by the required notice, consent, contractual arrangement, or other lawful basis. Vendor contracts and technical configurations must be reviewed to ensure they are consistent with this commitment.

20. MARKETING AND COMMERCIAL COMMUNICATIONS

PatchLead distinguishes between communications necessary to respond to a consumer's service request and promotional communications.

20.1 Service Communications

PatchLead may contact a consumer regarding:

a submitted service request;
a requested callback;
qualification;
a provider connection;
appointment coordination;
support; or
other communications reasonably necessary to fulfill the requested service connection.

20.2 Marketing Communications

Where a communication constitutes a commercial electronic message or telephone solicitation requiring consent under applicable law, PatchLead will obtain and maintain the appropriate consent. Marketing communications may include:

promotional emails;
promotional text messages;
special offers;
marketing announcements; and
similar promotional communications.

20.3 Withdrawal

Where consent is required for marketing communications, individuals may withdraw consent through:

the unsubscribe mechanism provided in an electronic message;
the applicable preference mechanism;
contacting PatchLead at privacy@patchlead.ca; or
another method made available by PatchLead. PatchLead will record applicable withdrawal or opt-out requests and will take reasonable steps to implement them. Withdrawal of marketing consent does not necessarily prevent service-related communications that are necessary to respond to an existing request or otherwise permitted by law.

21. SECURITY SAFEGUARDS

PatchLead implements reasonable administrative, technical, and physical safeguards appropriate to the nature and sensitivity of personal information under its control. Safeguards may include:

Access controls and role-based permissions;
Authentication procedures;
Encryption and secure transmission where appropriate;
Secure hosting and infrastructure;
Restricted access to personal information;
Confidentiality obligations;
Security monitoring;
Backup and recovery procedures;
Vendor security requirements;
Employee and contractor privacy procedures; and
Incident-response procedures. Access to personal information is limited to individuals who require it for authorized business purposes. No method of electronic storage or transmission can be guaranteed to be completely secure. PatchLead therefore cannot guarantee absolute security.

22. PRIVACY BREACHES AND INCIDENT RECORDS

PatchLead maintains procedures for identifying, containing, investigating, documenting, and responding to privacy and security incidents. A privacy incident may include:

Unauthorized access;
Unauthorized disclosure;
Loss or theft;
Accidental disclosure;
Unauthorized use;
Security compromise; or
Other circumstances involving unauthorized handling of personal information. PatchLead maintains an internal record of every breach of security safeguards as required by applicable law. Where applicable law requires notification to individuals, regulators, or other parties, PatchLead will assess the incident and provide the required notification within the applicable timeframe. PatchLead's incident-response procedures may include: 1. Containing the incident; 2. Identifying the information affected; 3. Assessing the risk of harm; 4. Taking corrective measures; 5. Documenting the incident; 6. Determining whether notification is required; and 7. Preventing or reducing the likelihood of recurrence.

23. RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

PatchLead retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, provide services, maintain appropriate business records, resolve disputes, protect the platform, and comply with applicable legal obligations. Retention periods may vary depending on:

The type of information;
The sensitivity of the information;
The purpose for which it was collected;
The nature of the relationship;
Billing and dispute requirements;
Security and fraud-prevention requirements;
Legal or regulatory obligations; and
Applicable limitation or recordkeeping requirements. PatchLead maintains an internal retention schedule identifying applicable retention periods for relevant categories of information.

23.1 Call Recordings

Call recordings may be retained for periods reasonably necessary for:

Quality assurance;
Qualified Call verification;
Billing;
Dispute resolution;
Fraud prevention;
Security;
Legal or regulatory purposes. PatchLead does not represent that every recording is automatically retained for one universal period.

23.2 Consent and Opt-Out Records

PatchLead may retain records of consent, withdrawal, and communication preferences for as long as reasonably necessary to administer those preferences, demonstrate compliance, resolve disputes, or satisfy applicable legal obligations.

23.3 Secure Destruction

When personal information is no longer required, PatchLead will take reasonable steps to:

Securely delete it;
Anonymize it; or
Otherwise dispose of it in accordance with applicable requirements. Information may be retained longer where required because of litigation, a legal hold, regulatory requirements, unresolved disputes, or another lawful purpose.

24. CROSS-BORDER PROCESSING

PatchLead may use service providers located in Canada, the United States, and other jurisdictions. Personal information may therefore be processed or stored outside the province or country in which it was collected. When personal information is processed outside Canada, it may be subject to the laws of the jurisdiction where it is processed, including lawful access by courts, regulators, or lawenforcement authorities. PatchLead takes reasonable steps to assess and manage risks associated with cross-border processing.

24.1 Québec Transfers

Where Québec privacy legislation applies, PatchLead will comply with applicable requirements before communicating personal information outside Québec. Where required, PatchLead will conduct the applicable assessment of the privacy protection available in the destination jurisdiction before the transfer. The assessment may consider:

Applicable legal framework;
Privacy principles;
Security safeguards;
Sensitivity of the information;
Purpose and duration of the transfer;
Contractual protections; and
Other relevant factors. Where required, PatchLead will implement appropriate contractual or other safeguards and will not proceed with a transfer where applicable legal requirements have not been satisfied.

25. ACCOUNTABILITY AND PRIVACY GOVERNANCE

PatchLead is accountable for personal information under its control and maintains privacy policies and practices appropriate to its operations. PatchLead will:

Establish privacy policies and procedures;
Identify responsibility for privacy compliance;
Limit collection to information reasonably necessary for identified purposes;
Implement appropriate safeguards;
Manage third-party processors;
Provide privacy training to personnel who handle personal information;
Maintain privacy incident procedures;
Respond to access and correction requests;
Respond to privacy complaints; and
Assess privacy risks associated with new technologies and processing activities.

25.1 Privacy Officer

PatchLead has designated a person responsible for privacy compliance. Privacy Officer / Person Responsible for the Protection of Personal Information: Privacy OfficerOrganization: 1001689754 Ontario Inc. operating as PatchLeadEmail: privacy@patchlead.ca The Privacy Officer is responsible for overseeing PatchLead's privacy practices and may be contacted regarding:

Privacy questions;
Access requests;
Correction requests;
Consent and withdrawal;
Call recording;
AI-assisted processing;
Cross-border processing;
Privacy complaints; and
Other privacy matters. PatchLead will publish updated contact information if the designated Privacy Officer changes.

26. ACCESS TO PERSONAL INFORMATION

Subject to applicable legal exceptions, individuals may request access to personal information held by PatchLead about them. An access request may seek:

Confirmation that PatchLead holds personal information;
Access to the information;
Information about how the information is used;
Information about disclosures, where applicable; and
Other information required by applicable law. PatchLead may require reasonable identity verification before responding to an access request.

26.1 Response Time

PatchLead will respond to access requests within the timeframe required by applicable privacy legislation. Where PIPEDA applies, PatchLead generally responds within 30 days, subject to any lawful extension available under that legislation. Where Québec legislation applies, PatchLead will follow the applicable statutory timeframe for access requests. If an extension is legally permitted and required, PatchLead will provide the applicable notice.

27. CORRECTION OF PERSONAL INFORMATION

Individuals may request correction of personal information that they believe is:

Inaccurate;
Incomplete;
Outdated; or
Misleading. PatchLead will review correction requests and, where appropriate, correct the information or take reasonable steps to address the issue.

27.1 Québec Correction Requests

Where Québec privacy legislation applies, PatchLead will respond to correction requests within the applicable statutory timeframe. Where required, PatchLead will also take reasonable steps concerning organizations to which the incorrect information was previously communicated.

28. QUÉBEC PRIVACY RIGHTS

Where Québec privacy legislation applies, individuals have the rights provided by that legislation. Depending on the circumstances, these rights may include:

Access to personal information;
Correction of personal information;
Withdrawal of consent where applicable;
Data portability;
Rights relating to the dissemination or indexing of personal information in applicable circumstances;
Information concerning automated decision-making;
The ability to submit observations concerning an automated decision;
Privacy complaint rights; and
Other rights provided by applicable Québec law. PatchLead will provide the applicable procedures for exercising these rights.

29. WITHDRAWAL OF CONSENT

Where PatchLead relies on consent for a particular collection, use, or disclosure, an individual may withdraw consent subject to applicable legal limitations. A withdrawal request may be submitted by:

Emailing privacy@patchlead.ca;
Using an applicable online preference or consent mechanism;
Using an unsubscribe mechanism provided with a marketing communication;
Requesting withdrawal during a communication where the applicable process permits it; or
Using another method made available by PatchLead. PatchLead will maintain appropriate records of withdrawal requests and will take reasonable steps to implement them. Withdrawal of consent may affect PatchLead's ability to provide certain services. For example, withdrawing consent necessary to process a service request may prevent PatchLead from facilitating the requested connection. Withdrawal does not invalidate processing that occurred before withdrawal and does not prevent continued processing where permitted or required by law.

30. PRIVACY COMPLAINTS

Individuals may contact PatchLead's Privacy Officer with concerns regarding:

Collection;
Use;
Disclosure;
Security;
Consent;
Access;
Correction;
Call recording;
AI-assisted processing;
Cross-border processing; or
Any other privacy matter. Complaints may be submitted to: privacy@patchlead.ca PatchLead will: 1. Acknowledge the complaint; 2. Review relevant information; 3. Investigate the concern; 4. Take corrective action where appropriate; and 5. Provide a response. PatchLead will handle complaints in accordance with applicable privacy requirements. Individuals may also have the right to complain to the applicable privacy regulator.

31. LEGAL AND REGULATORY DISCLOSURE

PatchLead may use or disclose personal information where reasonably necessary to:

Comply with applicable law;
Respond to lawful requests;
Comply with court orders or legal processes;
Establish, exercise, or defend legal rights;
Prevent or investigate fraud;
Protect the security of the platform;
Protect the rights, safety, or property of PatchLead or others. Where disclosure is required by law, PatchLead will comply with the applicable legal requirements.

32. FRAUD PREVENTION AND PLATFORM SECURITY

PatchLead may use personal information to detect, investigate, and prevent:

Fraud;
Unauthorized account access;
False service requests;
False disputes;
Payment abuse;
Platform misuse;
Security threats; and
Other unlawful or unauthorized activity. This may involve reviewing:
Account activity;
Transaction records;
Communication records;
Call information;
Device or technical information;
Platform usage patterns. PatchLead will use such information for legitimate security, fraud-prevention, operational, or legal purposes consistent with applicable law.

33. BUSINESS TRANSFERS

PatchLead may participate in a corporate transaction, including:

Merger;
Acquisition;
Sale of assets;
Corporate restructuring;
Financing;
Transfer of a business division; or
Change in ownership or control. Personal information may be transferred as part of such a transaction where permitted by applicable law and subject to appropriate privacy safeguards. Where a transaction results in a materially different use of personal information and applicable law requires additional notice or consent, PatchLead will take the required steps.

34. CHILDREN AND AGE RESTRICTIONS

PatchLead's consumer services are intended for adults who are legally capable of requesting or arranging home services. PatchLead does not intentionally design its consumer lead-generation services to target children. PatchLead will not knowingly collect personal information from children for purposes that are not permitted by applicable law. If PatchLead becomes aware that personal information has been collected from a child in circumstances where the collection was not appropriate or permitted, PatchLead will take reasonable steps to address the situation in accordance with applicable law. A parent or guardian who has a concern regarding a child's personal information may contact: privacy@patchlead.ca

35. PRIVACY IMPACT ASSESSMENTS AND NEW TECHNOLOGIES

PatchLead assesses privacy risks when introducing new technologies, systems, services, or processing activities that may create material privacy risks. Where required by applicable law, PatchLead will conduct the applicable Privacy Impact Assessment before implementing the relevant system or transferring personal information. This may include assessment of:

AI voice technology;
Automated qualification systems;
Analytics and tracking technologies;
New categories of personal information;
Cross-border processing;
New service providers;
Significant changes to existing processing. For Québec activities, PatchLead will comply with applicable Québec requirements relating to Privacy Impact Assessments and transfers of personal information outside Québec.

36. THIRD-PARTY WEBSITES AND SERVICES

PatchLead websites may contain links to or integrations with third-party websites and services. These may include:

Independent home-service providers;
Payment processors;
AI technology providers;
Analytics providers;
Advertising platforms;
Social-media platforms; and
Other service providers. Once an individual interacts directly with a third-party website or service, that third party's own privacy practices may apply. PatchLead does not control the privacy practices of independent third parties and encourages individuals to review the applicable privacy policies before providing personal information.

37. CHANGES TO THIS PRIVACY POLICY

PatchLead may update this Privacy Policy to reflect:

Changes to its services;
Changes in technology;
Changes in privacy practices;
Changes in applicable law;
Changes in service providers; or
Regulatory developments. The Last Updated date and version number will be updated when material changes are made. Where applicable law requires notice or consent for a material change, PatchLead will provide the required notice or obtain the required consent. The current version will be made available through the relevant PatchLead websites.

38. CONTACT INFORMATION

For privacy questions, requests, or complaints: 1001689754 Ontario Inc. Operating As PatchLead Privacy Email: privacy@patchlead.ca When submitting a privacy request, individuals should provide enough information for PatchLead to identify the relevant request, account, communication, or information. PatchLead may require reasonable identity verification before responding to an access or correction request.

39. REGULATORY AUTHORITIES

If an individual is not satisfied with PatchLead's response to a privacy concern, the individual may have the right to contact the applicable privacy regulator. Office of the Privacy Commissioner of Canada For matters governed by federal private-sector privacy legislation, individuals may contact the Office of the Privacy Commissioner of Canada (OPC). Commission d'accès à l'information du Québec For matters governed by Québec private-sector privacy legislation, individuals may contact the Commission d'accès à l'information du Québec (CAI). PatchLead encourages individuals to contact its Privacy Officer first so that the Company has an opportunity to review and address the concern.

40. DOCUMENT CONTROL

Legal Entity: 1001689754 Ontario Inc.Operating Name: PatchLead Document: Privacy Policy Version: 3.0Privacy Contact: privacy@patchlead.ca