BUTTERFLYMX PRIVACY POLICY – CANADA

Effective Date: March 23rd, 2025

ButterflyMX, Inc. (“ButterflyMX,” “we,” “us,” “our”) is committed to protecting your personal information. This Privacy Policy describes the Personal Information that we collect about you, how we use and disclose personal information, and the steps we take to protect personal information.

For purposes of this Privacy Policy, “Personal Information” means any information that relates to you as an individual and could reasonably be used to identify you. This Privacy Policy applies to our collection and use of Personal Information through this website and any related websites, our mobile application, products, services, tools, or platforms (the “Services”), as well as through any other means where a link or reference to this Privacy Policy is provided at the time of collection.

This Privacy Policy describes our practices with respect to the collection, use, and disclosure of the Personal Information:

of our business customers (including their employees and representatives), who may be property owners, managers, and other business partners
of the tenants and residents of our business customers’ properties (“Tenants”)
of the visitors that enter partner properties and utilize our Services (generally limited to Property Access Information: https://butterflymx.com/privacy-policy-canada/#collect

Please note that we operate as a service provider/processor under applicable privacy laws when providing the Services to our business customers (i.e. property owners, managers, and other business partners). We only process tenant and visitor Personal Information as a service provider/processor in order to provide the Services to our business customers.

Our business customers have represented that they have obtained all necessary consents to provide us with your personal information, or to have us collect, use and disclose such Personal Information on their behalf. Users that install our app are also required to consent to the terms of this Privacy Policy.

In addition, by using the Services, or otherwise submitting your Personal Information to us, you consent to the processing of your Personal Information in accordance with the terms of this Privacy Policy.

Personal Information We Collect

When you access or use the Services, or otherwise interact with us, we may collect certain Personal Information about you from a variety of sources.

Categories of Personal Information that we may collect directly include:

Basic Personal Information. We may collect tenants’ names so that they can appear in the intercom directory. We may also collect the names of individuals who fill out a “Contact Us” form or otherwise contact us.
Contact information. We collect phone numbers and email addresses from tenants who sign up for an account with us and download our mobile app in order to enable their visitors to call them through the intercom system. In addition, users of our intercom can choose to sync the contacts on their mobile device with our app in order to easily send their contacts a virtual key to their unit (this is an optional feature that users can enable; we never collect contacts from your phone without your express permission).
Property Access Information. We collect Personal Information when you enter one of our partner properties using one of our intercoms, keypads, access readers or other access control devices. This information may include your name or device/card/pin identification number, point of entry and date and time of entry. For property entries made through a video intercom, our system records a photograph and/or video of the person entering. Property Access Information is tied to an individual unit, and is viewable only by the tenant of the relevant unit and by the property management.
Account information. We collect email addresses and passwords from individuals who sign up for an account.
Communications. We collect the contents of communications that you share with us in connection with customer support requests, questions submitted through our Services, and requests for product information.
Identity verification information. When you schedule a self-guided tour at a partner property, our service provider may collect a scan of your driver’s license in order to verify your identity.

Categories of Personal Information that we may collect automatically from users of our Services include:

Technical information (for example, browser and device type, IP address, and operating system version)
Usage information (for example, pages visited, search terms entered, and frequency of visits)

We may also collect Personal Information from other sources including:

The names, addresses, and phone numbers of tenants (either directly or through APIs) from building owners, building managers, and property management service companies when they onboard ButterflyMX;
The names and contact information of potential business clients from third party lead generators and partners to support our sales efforts.

Finally, we may collect Personal Information as may be required or permitted by law.

How We Use Personal Information

We may use the Personal Information we collect for the following purposes:

Provide the Services. We use your Personal Information to enable you to interact with the Services (i.e. to allow visitors to contact you through the intercom).
Risk mitigation and security. We use Property Access Information to protect residents in the building, as well as the property itself, both by allowing a resident to view and verify visitors requesting building access from that resident, and by creating access logs that can be audited in the case of a building security incident. In connection with self-guided tours, our service provider may use your driver’s license to verify your identity for risk mitigation purposes.
Communication and marketing. We may use your Personal Information to communicate with you about the Services, respond to your questions, or, with your consent or as otherwise permitted by law, offer you additional products or services. We may also use your Personal Information for personalization and advertising, and to track the effectiveness of our advertising activity.
Service development. We may use your Personal Information to help us design, develop and improve our Services and processes, including user support and customer experience.
Comply with the law and exercise our rights. We may use your Personal Information as reasonably necessary to assess and ensure compliance with applicable laws, legal requirements, and company policies; to protect our assets or to investigate or defend against any claims of illegality or wrongdoing (including to obtain legal advice or to establish, exercise or defend legal rights); or to respond to a court order or judicial or other government subpoena or warrant.
Corporate transaction. We may use your Personal Information in the event we undertake or are involved in or contemplating any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event.
Manage our Services. We may use Personal Information to analyze how people use our Services and to improve our Service offerings.

We may also aggregate, anonymize, or otherwise de-identify your Personal Information and use it for any purpose permitted by applicable law. When we collect, use, or disclose aggregated or deidentified information, we commit not to reidentify the information.

Cookies and Other Tracking Technologies

We and our vendors may use a variety of tracking technologies, including cookies, beacons, pixels, SDKs, and APIs that collect certain information when you interact with the Services. Depending on your device and browser settings, these tracking technologies may collect your IP address, device identifiers, user preferences, approximate geolocation, the pages you click on, and the website you visited immediately beforehand. Additionally, these technologies may collect details about how you interact with the Services.

We may use these technologies for various purposes, including to provide functionality to the Services, help us route traffic between servers, understand how the Services are performing and used, improve features and content on the Services, and for advertising purposes. We may combine certain information collected through tracking technologies with other information we obtain about you, which may include information we obtain from our vendors. We or other parties may collect Personal Information about your online activities over time when you use the Services.

You can opt out of being tracked online for interest-based advertising purposes by going to https://optout.aboutads.info or https://optout.networkadvertising.org, or by disabling advertising cookies by clicking the “Your Privacy Choices” link in the footer of this webpage. You can opt out of being tracked for interest-based advertising purposes on mobile apps by going to https://youradchoices.com/appchoices.

The choices you make are device-specific and browser-specific. If you use different browsers on your computer, or multiple computers and devices, you will need to opt out of interest-based advertising from each browser on each of the computers and devices that you use. Please note that even if you opt out of interest-based advertising, you may still receive advertisements from us; they just won’t be customized based on your web browsing activities on third-party websites. Please also note that if you opt out of interest-based advertising, we may still track your visits to the Services for our own analytics, operations, and security purposes.

Some browsers may have a “Do Not Track” setting. Please note that our websites are not designed to respond to “Do Not Track” settings. Please note that we do not control how other parties manage their opt-out processes.

Google Analytics

Our Services may use Google Analytics, a service that uses the IP address of users of our websites and app to tracks and provides us with aggregated reports on the way those users interact with out websites and app. Information about Google Analytics’ current opt-outs for web is available on-line.

We may integrate Google Analytics with the following Google advertising features:

Remarketing with Google Analytics, which allows us to target advertising to IP addresses that have interacted with our websites and app.
Google Analytics Demographics and Interest Reporting, which provides aggregated reports on the demographics and interests of the users of our websites and app.

Google Display Network Impression Reporting, which provides us with aggregated reports about the effectiveness of our Internet advertising campaigns.
Google Ads, which allows us to advertise our Services on Google’s online properties, including its search engine and Google-owned sites like YouTube.

Youtube

To deliver content to our users, we also use YouTube API Services, which allow us to embed various YouTube features in our websites and apps. Certain of our Services include videos that we host on YouTube. When you interact with these videos on the Services, YouTube may collect your personal information, including, if you are signed on to Google, your Google user name and other account information – although we do not receive this information. For more information, please visit Google’s privacy policy: https://policies.google.com/privacy?hl=en&gl=us.

Facebook Custom Audiences

We may use Facebook Custom Audiences, which is a service that allows us to serve demographically-targeted ads to our users that also have Facebook accounts, as well as allowing us to serve such ads to Facebook users that are demographically similar to our users.

To serve ads to our users that also have Facebook accounts, we provide Facebook with a mathematically encrypted version of limited personal information, such as your email address or other potentially connecting information, which could be matched to your Facebook profile. Facebook runs the same one-way encryption function on the same data element in the profiles of its members in order to identify the Facebook account holders that are also ButterflyMX users, allowing Facebook to target those users with relevant advertising on Facebook, based on broad demographic factors selected by us. Further information about this process is available in the Privacy Center under Facebook’s user Settings and Privacy. To opt out of the use by ButterflyMX of the Personal Information we hold about you for such purposes, please see Your Choices and Rights [include internal hyperlink].

Your receipt of advertising on such platforms is governed by the privacy policy, terms of use, and preference options provided by Facebook. You may opt out of Facebook Custom Audiences by logging into your Facebook account and changing your privacy or advertising settings as per Facebook’s opt out instructions.

How and When We Disclose Personal Information

We may share or disclose your Personal Information to the following categories of recipients, or have such recipients collect and process your Personal Information on our behalf:

Group companies and affiliates. We may disclose, share, or transfer your Personal Information to any business entity that is part of our corporate family in order to provide residents, visitors or our business customers with our Services.
Service providers and professional advisors. We may share your Personal Information with our vendors, service providers, and contractors who provide services to us or on our behalf in connection with the Services we provide to business customers, residents and visitors. For example, we may share your Personal Information with advertising networks placing online ads on our behalf, and companies providing use with analytics reports respecting how users interact with our websites and app. We may also share your Personal Information with our professional advisors such as our attorneys, accountants, and insurance providers.
Business customers. As a service provider to our business customers, such as landlords and property owners and managers, we may share with such customers the Personal Information of the residents of and visitors to the properties owned or managed by those customers.
Parties involved in a corporate transaction. We may disclose your Personal Information to relevant third parties in the event of a divestiture, merger, consolidation, or asset sale, or in the unlikely event of a bankruptcy.
Law enforcement or other governmental entities. We may disclose your Personal Information as required or permitted by law, including where we believe in good faith that such action is necessary to comply with the law, prevent unlawful activity, defend our rights, or maintain security.
Other parties with your consent. We may disclose your information to any other party where you have provided consent to such disclosure for the intended purposes.

We do not disclose Personal Information to third parties for their own marketing purposes.

Identity Verification

ButterflyMX offers a service to property owners/managers that enable those parties to offer prospective residents the ability to conduct self-guided tours of a building. If you wish to do a self-guided tour of a building that uses this feature, you will be required to verify your identity to help ensure the safety of building residents, prevent theft or other security incidents and generally protect the property in question.

ButterflyMX uses a trusted third-party provider of secure identify verification services for this purpose. When you sign up for a self-guided tour of a property, with your consent, our service provider may collect your government-issued ID (i.e., your driver’s license) and a photo “selfie” that you take of yourself, then compare the information from both documents to verify your identity. Our service provider may collect and store biometric information in order to provide us with this service; however, ButterflyMX receives from the provider only an indication that your identity has (or has not) been successfully verified. We do not collect, receive, store, or otherwise process any biometric information. We require our service providers to comply with the requirements of all applicable privacy laws, including those governing biometric information.

For greater certainty, identity verification is required only for those signing up for a self-guided tour. No identity verification is required for existing residents, or for visitors whose entry is authorized by a resident, and ButterflyMX does not collect, create or use biometric information respecting such individuals, nor direct or permit third parties to do so on its behalf.

Security & Transfer of Personal Information

We have implemented and maintain commercially reasonable and appropriate technical and organizational measures designed to protect the confidentiality, integrity, and security of your personal information. These measures are consistent industry practices for similar businesses and adhere to the requirements of applicable privacy laws. Please note, however, that no security measures are perfect or impenetrable. We therefore cannot guarantee and do not warrant the absolute security of your personal information. You may contact us using the contact information provided below to learn more about the appropriate safeguards that apply to your personal information.

Personal information collected from residents and visitors in Canada is stored and processed on servers located in the United States, where it will be subject to the laws of that jurisdiction.

Retention

We retain your Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it or as required or permitted by law; to prevent fraud; to facilitate an investigation; to defend against legal claims; to exercise our legal rights and for other legitimate and lawful business purposes. Because these needs can vary for different categories of personal information, actual retention periods can vary significantly based on criteria such as whether your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information; whether your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which we collected the information; whether the Personal Information is reasonably required to protect or defend our rights or property; or whether we are otherwise required or permitted to keep your Personal Information by applicable laws or regulations. Where Personal Information is used for more than one purpose, we may retain it until the purpose with the latest period expires.

Your Choices & Rights

You may decline to share certain information with us, in which case we may not be able to provide you with some of the features and functionality of the Services. Once you have registered for an account with us, you may update or correct your profile information and preferences at any time by accessing your account preferences page through the Services. Although any changes that you make to your profile information or preferences are reflected promptly in active user databases, we may retain certain information you previously submitted for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.

Depending on the province in which you live and subject to local law, you may have certain rights with respect to your personal information. These may include: the right to access, correct, and delete your personal information; the right to restrict or object to our use of your personal information; and the right to receive a portable copy of your Personal Information in a usable format. Where legally required, if you provide us with consent to use your Personal Information you may withdraw that consent at any time, however, such withdrawal will not impact the lawfulness of our use of your Personal Information based on your consent up to that point.

Please note that as a processor to our business customers, we are only permitted to process tenant and visitor privacy requests when permitted by our business customer (e.g. your property owner, property manager, etc.), which may elect to handle directly requests related to applicable privacy rights.

To make a request related to your personal information, obtain further information about our privacy practices, provide comments or concerns respecting our privacy practices or otherwise exercise the privacy rights that may be available to you under applicable laws, you may contact us by completing this form https://preferences.butterflymx.com/privacy or by contacting our Data Privacy Office by e-mail at dpo@butterflymx.com or by mail at:

Attn: Privacy
ButterflyMX
44 West 28th Street
4th Floor
New York, NY 10001

In order to fulfill your request, we may require additional information from you, such as to verify your identity before releasing any Personal Information to you. We will respond to requests within the relevant time periods established by applicable law. We are committed to finding a fair and reasonable resolution to any request, concern, or complaint you bring to our attention. However, if you are unsatisfied with our response to your request, you may have the right to lodge a complaint with applicable governmental authorities, subject to local law.

If you do not wish to receive marketing communications from us, you can opt out by using the unsubscribe process at the bottom of the email, but you may still receive transactional or administrative emails from us (i.e., customer service).

Children’s Privacy

We do not knowingly collect or maintain information from persons under 13 years of age (“children”), and no part of the Services is directed to children. If we learn that information has been collected through the Services from children we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child has provided us with Personal Information without your consent, please

Quebec Residents

We do not provide Services with respect to properties located in the Province of Québec, and accordingly do not provide Services to any residents of or visitors to properties located in that province. More generally, we do not knowingly collect or maintain information respecting residents of Québec, and no part of the Services or our marketing is directed at that province.

Changes to this Privacy Notice

We reserve the right to make changes to this Privacy Policy at any time, by posting a revised version of the policy here. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. The effective date of the most recent revisions is indicated at the beginning of the Privacy Policy.

Where we make revisions that materially change our privacy practices or our processing of personal information, we will use additional means to bring the revisions to your attention, such as by placing a prominent notice on this website, or in some cases by notifying you directly. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.

Contact Us

Please contact us with any questions, comments, or concerns about this Privacy Notice or our use of your personal information by e-mail at dpo@butterflymx.com or by mail at: