BEST BRAINS CANADA PRIVACY POLICY

1. Introduction

Best Brains Canada, operated by Best Brains of Canada INC. ("Best Brains," "we," "us," or "our"), respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, retain, safeguard, and otherwise process personal information when you:

• Visit https://bestbrains.com/ca-en/ or a webpage that links to this Privacy Policy
• Complete an inquiry, registration, contact, placement test, event, employment, or franchise application form
• Communicate with Best Brains Corporate Canada
• Use a corporate platform, portal, application, or online service that links to this Privacy Policy
• Participate in a corporate promotion, survey, contest, webinar, event, or program
• Otherwise interact with Best Brains Corporate Canada.

This Privacy Policy is intended to comply with applicable Canadian privacy laws, including:

• The federal Personal Information Protection and Electronic Documents Act (PIPEDA)
• Alberta's Personal Information Protection Act
• British Columbia's Personal Information Protection Act
• Quebec's Act respecting the protection of personal information in the private sector, as amended by Law 25
• Canada's Anti-Spam Legislation (CASL)
• Other applicable federal and provincial privacy, consumer-protection, employment, education, and electronic-commerce laws.

If a provincial law provides greater protection than this Privacy Policy, we will apply the requirement that provides greater protection.

2. Corporate and Independently Owned Franchise Locations

Best Brains Learning Centers are operated through a franchise system. Individual Best Brains Learning Centers may be independently owned and operated by franchisees.

This Privacy Policy applies to personal information handled by Best Brains Corporate Canada through its corporate website, corporate systems, and centralized services.

An independently owned Best Brains center may separately collect or manage personal information concerning its prospective and enrolled students, parents, employees, contractors, and local activities. In those circumstances, the franchisee may be separately responsible for its privacy practices and may provide an additional local privacy notice.

When you submit an inquiry for a particular Best Brains center, you authorize us to provide the inquiry and related contact information to the selected or nearest center so that it can respond to you. Best Brains Corporate Canada and the applicable franchisee may each be responsible for the personal information under their respective control.

Questions concerning information collected directly by a local center should first be directed to that center. Best Brains Corporate Canada may assist with escalating or addressing the matter where appropriate.

3. Accountability and Privacy Officer

Best Brains has designated a Privacy Officer who is responsible for overseeing our privacy-management program, responding to privacy inquiries and complaints, and supporting compliance with applicable privacy laws.

Privacy Email: info@bestbrains.com

Telephone: +1 (800) 817-1025

For Quebec residents, the Privacy Email and phone number remain the same until Best Brains publishes a written designation stating otherwise.

The Privacy Officer's title and contact information will be made available on our website.

4. What Is Personal Information?

"Personal information" generally means information about an identifiable individual. It may include information that identifies someone directly or information that could reasonably identify someone when combined with other information.

Personal information does not generally include anonymous or properly anonymized information that cannot reasonably be associated with an identifiable person. Business contact information may be treated differently under certain laws when used strictly to communicate with an individual in relation to their employment, business, or profession.

Some personal information may be considered sensitive because of its nature or the context in which it is collected or used. Sensitive information may include financial information, authentication credentials, government identification, information about a child, health or accommodation information, biometric information, or other information that creates a higher reasonable expectation of privacy.

5. Personal Information We Collect

The information we collect depends on your relationship with Best Brains and how you interact with us.

5.1 Parent and Guardian Information

We may collect:

• Name
• Email address
• Telephone number
• Mailing address and postal code
• Relationship to a student
• Preferred Best Brains center
• Preferred communication method
• Program interests
• Appointment and placement-test details
• Communications, inquiries, feedback, and complaints
• Marketing preferences
• Account and portal information
• Transaction or billing information.

5.2 Student and Child Information

Where necessary to respond to an inquiry, arrange an assessment, provide educational services, or administer a corporate platform, we may collect:

• Student name
• Date or year of birth
• Age
• Grade level
• School name, where provided
• Parent or guardian contact information
• Program and subject interests
• Placement-test results
• Academic level and learning goals
• Enrollment, scheduling, attendance, and program information
• Homework, assessment, progress, and teacher-support information
• Student account identifiers and login information
• Communications submitted through an educational platform
• Learning support, accessibility, health, allergies, emergency, or accommodation information voluntarily provided when reasonably necessary to serve the student safely.

We limit the collection of information about children to what is reasonably necessary for educational, safety, administrative, and legal purposes.

5.3 Website and Device Information

When you use our website or online services, we may automatically collect:

• Internet Protocol address
• Browser type and version
• Device type
• Operating system
• Language settings
• Approximate location derived from an IP address
• Referring website or advertisement
• Pages viewed and links selected
• Date, time, and duration of visits
• Website interactions and navigation patterns
• Cookie, pixel, device, or advertising identifiers
• Form activity and conversion information
• Error, diagnostic, and security logs
• Information concerning suspected fraud, abuse, or unauthorized access.

5.4 Communications and Customer-Service Information

We may collect the content of emails, text messages, chat messages, online forms, telephone communications, support requests, survey responses, reviews, and other communications.

Calls, video meetings, or online sessions may be recorded only where appropriate notice and any required consent have been provided.

5.5 Payment and Transaction Information

Payments may be processed through third-party payment providers. Depending on the payment method, we or our provider may collect:

• Name and billing address
• Payment-card or bank-payment details
• Transaction amount
• Payment date and status
• Invoice and receipt information
• Limited card information, such as the last four digits
• Information needed to prevent fraud or process refunds.

Best Brains generally does not retain complete payment-card numbers when payments are processed by an authorized third-party payment provider.

5.6 Employment and Contractor Information

If you apply for employment or a contractor role, we may collect:

• Name and contact information
• Résumé, cover letter, and employment history
• Education, qualifications, certifications, and professional licenses
• References
• Interview notes and evaluation information
• Availability and compensation expectations
• Work-authorization information
• Background-check information where legally permitted and consented to
• Other information voluntarily provided during the recruitment process.

5.7 Franchise Candidate Information

If you inquire about or apply for a Best Brains franchise, we may collect:

• Name and contact information
• Business and professional history
• Preferred territory
• Ownership and partnership information
• Financial qualifications and available investment information
• Corporate or business-entity information
• Information required for franchise-development due diligence
• Communications with our franchise-development team
• Other information voluntarily included in an application.

Additional notices and authorizations may be provided during the formal franchise application and due-diligence process.

5.8 Photographs, Video, Testimonials, and Event Information

We may collect photographs, video recordings, testimonials, contest entries, event registrations, or promotional content when appropriate consent has been obtained.

For children, we will obtain authorization from a parent or legal guardian before using an identifiable image, recording, testimonial, or student work for promotional purposes, except where another lawful basis clearly applies.

5.9 Information from Other Sources

We may receive information from:

• A Best Brains franchisee or learning center
• A parent, guardian, family member, or authorized representative
• Service providers and corporate affiliates
• Advertising and social-media platforms
• Referral partners
• Event and community partners
• Schools or educators, where authorized
• Publicly available sources
• Government, law enforcement, regulatory, or legal sources where permitted or required.

6. Children's Privacy

Best Brains provides educational services for children, but our corporate website is primarily intended for parents, guardians, educators, prospective franchisees, job applicants, and other adults.

Children should not submit personal information through our corporate website without the knowledge and involvement of a parent or legal guardian.

We generally require a parent or guardian to provide or authorize the collection of information needed to register for a child, schedule a placement test, create an educational account, or enroll in a Best Brains program.

For children under 13, we generally obtain consent from a parent or guardian before collecting, using, or disclosing the child's personal information, except in an emergency or another exceptional circumstance permitted by law.

For Quebec residents:

• Personal information may not generally be collected directly from a child under 14 without consent from the person having parental authority or the child's tutor, unless the collection is clearly for the child's benefit.
• Consent concerning a child under 14 must generally be provided by the person having parental authority or the tutor.
• Consent concerning a minor who is 14 or older may be provided by the minor, the person having parental authority, or the tutor, as permitted by Quebec law.

We do not knowingly sell children's personal information or knowingly use children's personal information for third-party behavioural advertising.

If we learn that personal information was submitted by a child without appropriate authorization, we will take reasonable steps to delete, restrict, or otherwise appropriately handle the information.

7. Why We Collect and Use Personal Information

We may collect, use, or disclose personal information for the following purposes:

• Responding to questions and information requests
• Identifying an appropriate Best Brains center
• Referring inquiries to independently owned franchise locations
• Scheduling placement tests, consultations, orientations, or other appointments
• Assessing program suitability and recommended starting levels
• Registering and enrolling students
• Providing educational programs, materials, platforms, and support
• Creating and administering student, parent, teacher, employee, or franchisee accounts
• Tracking attendance, assessments, progress, homework, and educational support
• Communicating with parents, guardians, students, employees, applicants, or franchisees
• Processing transactions, invoices, refunds, and account adjustments
• Providing customer service and technical support
• Managing events, promotions, surveys, contests, and community programs
• Delivering requested newsletters, announcements, or promotional information
• Personalizing website content and user experiences
• Measuring website performance and campaign effectiveness
• Improving our curriculum, services, platforms, and corporate support
• Conducting quality-assurance, franchise-support, compliance, and brand-standard activities
• Preventing fraud, misuse, security incidents, and unauthorized access
• Protecting the safety, rights, and property of students, families, personnel, franchisees, Best Brains, and others
• Recruiting and evaluating employees, contractors, or franchise candidates
• Administering legal, regulatory, tax, accounting, insurance, and contractual requirements
• Establishing, exercising, or defending legal claims
• Completing a proposed or actual business transaction
• Creating aggregated, de-identified, or anonymized statistics
• Fulfilling another purpose disclosed at or before the time of collection.

We will not use personal information for a materially different purpose unless we obtain any additional consent required by law or the new use is otherwise authorized by law.

8. Consent

We collect, use, and disclose personal information with knowledge and consent except where applicable law permits or requires otherwise.

Consent may be:

• Express
• Implied, where appropriate under applicable law
• Provided electronically
• Provided in writing
• Provided verbally where appropriate.

The form of consent depends on the sensitivity of the information, the individual's reasonable expectations, and applicable legal requirements.

You may withdraw consent at any time, subject to legal, contractual, educational, security, or operational restrictions and reasonable notice. Withdrawal of consent may affect our ability to provide requested services.

Where required by law, we will obtain separate consent for secondary uses of sensitive personal information.

9. Cookies and Similar Technologies

We use cookies, pixels, tags, local storage, software development kits, and similar technologies to operate and improve our website.

These technologies may be used for:

• Website functionality
• Authentication
• Security
• Fraud prevention
• Remembering preferences
• Analytics
• Performance measurement
• Advertising measurement
• Social-media functionality.

Where required by law, non-essential cookies will only be activated after the user has provided the required consent.

You may change cookie preferences through our cookie-management tool or browser settings.

10. Marketing Communications

Where permitted by law, we may send information regarding:

• Educational programs
• Learning-center openings
• Events
• Placement-testing opportunities
• Newsletters
• Promotions
• Franchise opportunities
• Corporate announcements.

Commercial electronic messages are sent in accordance with Canada's Anti-Spam Legislation (CASL).

You may withdraw your consent to receive commercial electronic messages by:

• Selecting the unsubscribe link included in an email
• Updating your communication preferences
• Contacting us using the information provided in this Privacy Policy.

Transactional, educational, billing, security, safety, or legal communications are not marketing communications and may continue where necessary.

11. Disclosure of Personal Information

We disclose personal information only where reasonably necessary for the purposes described in this Privacy Policy or where otherwise required or permitted by law.

11.1 Best Brains Corporate Entities

We may disclose personal information to Best Brains corporate affiliates for:

• Technology and platform support
• Curriculum development
• Administrative services
• Marketing administration
• Customer support
• Legal compliance
• Franchise administration.

11.2 Independently Owned Learning Centers

Where you request information from or enroll with a Best Brains Learning Center, we may disclose relevant personal information to that center.

The learning center may independently collect, use, disclose, retain, and otherwise process personal information under its own privacy practices and legal obligations.

11.3 Service Providers

We may disclose personal information to carefully selected service providers that assist us with:

• Cloud hosting
• Website operation
• Learning-management systems
• Customer relationship management
• Payment processing
• Email and messaging
• Analytics
• Cybersecurity
• Accounting
• Professional consulting
• Marketing support
• Technical support.

Service providers may process personal information only for authorized purposes and are contractually required to protect the information.

11.4 Professional Advisers

We may disclose personal information to lawyers, accountants, auditors, insurers, financial institutions, consultants, and other professional advisers where reasonably necessary.

11.5 Legal and Regulatory Authorities

We may disclose personal information where required or permitted by law, including to:

• Courts and tribunals
• Law-enforcement agencies
• Privacy commissioners
• Tax authorities
• Child-protection authorities
• Consumer-protection agencies
• Other competent public authorities.

We may also disclose information where reasonably necessary to establish, exercise, or defend legal claims or protect individuals, property, systems, or the public.

11.6 Business Transactions

Personal information may be disclosed in connection with:

• A merger
• Acquisition
• Investment
• Business restructuring
• Sale of assets
• Transfer of operations
• Financing
• Bankruptcy or insolvency proceedings.

Recipients will be required to protect personal information in accordance with applicable legal obligations.

12. Cross-Border Transfers

Personal information may be processed in Canada, the United States, or another country where Best Brains or its service providers operate.

When personal information is transferred outside the province or country in which it was originally collected, it may become subject to the laws of the receiving jurisdiction.

We take reasonable contractual, technical, and organizational measures to protect personal information during cross-border transfers.

Where required by applicable law, including Quebec's Law 25, we will complete any required privacy impact assessment or implement additional safeguards before transferring personal information outside Quebec.

13. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to satisfy legal, accounting, tax, educational, contractual, regulatory, and operational requirements.

Typical retention periods include:

• General inquiries: Normally up to 24 months after the last meaningful interaction.
• Student and educational records: During the educational relationship and for an appropriate period afterwards, subject to applicable legal and operational requirements.
• Marketing records: Until consent is withdrawn or the information is no longer required, together with limited suppression records.
• Recruitment records: Normally up to 24 months after completion of the recruitment process unless another lawful basis applies.
• Franchise inquiries: For the duration of the application process and an appropriate business-retention period.
• Financial and accounting records: For the period required under applicable Canadian tax, accounting, and corporate laws.
• Security logs: For a limited period necessary for operational, fraud-prevention, and cybersecurity purposes.
• Legal matters: Until applicable limitation periods and related proceedings have concluded.

When personal information is no longer required, we will securely destroy, delete, anonymize, or otherwise dispose of it using appropriate methods.

14. Safeguarding Personal Information

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction.

Safeguards may include:

• Role-based access controls
• Authentication and password management
• Encryption where appropriate
• Secure hosting environments
• Network monitoring
• Security logging
• Regular backups
• Incident-response procedures
• Employee confidentiality obligations
• Vendor security assessments
• Data-minimization practices
• Physical security measures.

Although we implement appropriate safeguards, no method of electronic transmission or storage can be guaranteed to be completely secure.

15. Privacy Breaches

We maintain procedures for identifying, investigating, containing, documenting, and responding to suspected privacy and security incidents.

Where required by applicable law, including PIPEDA or provincial privacy legislation, we will notify affected individuals and the appropriate privacy regulator if a breach creates a real risk of significant harm or another applicable notification threshold.

We will also maintain records of reportable privacy breaches as required by law.

16. Automated Decision-Making

We may use automated systems to support:

• Spam filtering
• Cybersecurity monitoring
• Website analytics
• Lead routing
• Appointment scheduling
• Educational recommendations
• Customer-service workflows
• Administrative reporting.

We do not intend to make decisions based solely on automated processing that produce significant legal or similar effects unless permitted by applicable law and accompanied by appropriate safeguards.

17. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Know how your personal information is collected, used, and disclosed
• Request access to your personal information
• Request correction of inaccurate or incomplete information
• Withdraw consent, where processing is based on consent
• Request deletion where permitted by law
• Request information regarding cross-border disclosures
• File a complaint with the appropriate privacy regulator
• Exercise additional rights available under applicable provincial legislation.

These rights are subject to applicable legal limitations and exceptions.

17.1 Access Requests

You may request confirmation regarding whether we hold your personal information and request access to that information, subject to applicable legal exceptions.

17.2 Correction

You may request correction of inaccurate, incomplete, or outdated personal information.

Please notify us whenever your contact information or other relevant details change.

17.3 Withdrawal of Consent

Where processing is based on consent, you may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent does not affect processing completed before the withdrawal became effective.

18. How to Exercise Your Rights

Privacy requests may be submitted to:

Email: info@bestbrains.com

Telephone: +1 (800) 817-1025

Please include sufficient information to help us identify the relevant records and verify your identity.

We will respond within the period required by applicable law. Where permitted, the response period may be extended for complex or numerous requests.

Requests are generally handled without charge unless a fee is permitted by applicable law.

19. Complaints

If you have questions or concerns about our handling of personal information, we encourage you to contact us first so that we can investigate and attempt to resolve the matter.

If you remain dissatisfied, you may have the right to submit a complaint to the appropriate privacy regulator, including:

• The Office of the Privacy Commissioner of Canada
• The Commission d'accès à l'information du Québec
• The Office of the Information and Privacy Commissioner of Alberta
• The Office of the Information and Privacy Commissioner for British Columbia
• Another competent provincial privacy authority where applicable.

20. Third-Party Websites

Our website may contain links to:

• Best Brains Learning Center websites
• Payment-service providers
• Educational partners
• Government websites
• Social-media platforms
• Recruitment services
• Other third-party websites.

These websites operate independently and have their own privacy policies. We encourage you to review those privacy policies before providing personal information.

21. Social Media

If you interact with Best Brains through Facebook, Instagram, LinkedIn, YouTube, X, or another social-media platform, that platform may independently collect and process your personal information in accordance with its own privacy policy.

We may receive information that you choose to make available through your privacy settings or interactions with our official pages.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in Canadian privacy law
• Regulatory guidance
• Technology developments
• Educational services
• Business operations
• Security practices
• Processing activities.

The latest version will be published on our website together with the revised effective or last-updated date.

Where required by applicable law, we will provide additional notice or obtain renewed consent before material changes become effective.

23. Contact Us

Questions, requests, complaints, or privacy inquiries may be directed to:

Best Brains Canada

Email: info@bestbrains.com

Telephone: +1 (800) 817-1025

Privacy requests should include sufficient information to enable us to identify the relevant records, verify your identity where appropriate, and respond to your request as efficiently as possible.