This Privacy Policy applies to residents of Canada (including Quebec) and the United States. Quebec residents have additional rights under Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25), which are described throughout this policy.

We take your privacy seriously. This Privacy Policy explains what personal information Keyspire Group Inc. collects, why we collect it, how we use and protect it, and what choices you have.

By using our website, registering for an event or program, or otherwise interacting with Keyspire, you consent to the practices described in this policy.

1. WHO WE ARE

Keyspire Group Inc. ("Keyspire", "we", "us", "our") is a real estate investing education company incorporated in Ontario, Canada. We are responsible for the personal information we collect and hold.

Privacy contact: [email protected]

Phone: 1-888-556-2244

Mailing address: 260 Holiday Inn Drive, Unit 23, Building A, Cambridge, Ontario, Canada N3C 4E8

2. WHAT PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us directly and information collected automatically when you use our website or services.

Information you provide to us:

• Contact information: name, email address, phone number, mailing address

• Account and registration details: login credentials, program enrollment information

• Payment information: billing address, payment method details (processed securely — we do not store full credit card numbers)

• Communications: messages, questions, or feedback you send us

• Program participation: coaching session notes, event attendance, community posts, testimonials

• Identity and financial qualification information collected during program enrollment (e.g., household income range, net worth range)

Information collected automatically:

• Device and browser information: IP address, browser type, operating system, device identifiers

• Usage data: pages visited, time spent, links clicked, referring URLs

• Geolocation data: if you access our website from a mobile device with location services enabled, we may receive your approximate location. You can disable location services through your device settings at any time

• Cookie and tracking data: as described in Section 7 below

Information from third parties:

Meta (Facebook/Instagram) — when you interact with our ads or content on Meta platforms

Google — when you interact with our Google Ads or when Google Analytics collects data about your visit

Browser-based cookie data — from visitors who have consented to cookie tracking on our website (see Section 7)

3. WHY WE COLLECT YOUR INFORMATION AND HOW WE USE IT

We collect and use personal information only for legitimate business purposes, including:

• Delivering programs, coaching, events, and services you have purchased or enrolled in

• Processing payments and managing your account

• Communicating with you about your programs, account, and relevant updates

• Sending marketing emails or SMS messages you have opted into (you can opt out at any time)

• Improving our website, programs, and services

• Responding to your inquiries and providing customer support

• Complying with our legal obligations

• Protecting the safety and security of our community and platform

• Enforcing our Terms of Use and other agreements

• Targeting prospective customers with our services where your consent is required and has been obtained

Automated decision-making: Keyspire does not use automated decision-making processes to make binding decisions about individuals based solely on automated processing of personal information.

Quebec residents: We rely on your consent as our legal basis for collecting and using your personal information, except where otherwise permitted by law. You have the right to withdraw consent at any time, subject to legal or contractual restrictions.

4. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law. We may retain personal information for the following specific reasons:

• To ensure that we do not communicate with you if you have asked us not to

• To inform you about new products, services, features, and events offered by Keyspire

• To ease your re-enrollment into a program upon completion of a term

• To provide you with a refund, if entitled

• To provide accurate accounting and financial information to you

• To better understand traffic to our website so that we can provide the best possible experience

• To detect and prevent abuse of our website, illegal activities, and breaches of our Terms of Service

• To comply with applicable legal, tax, or accounting requirements

• To establish, exercise, and defend legal claims

• To prevent fraud and protect the rights, property, or safety of Keyspire, our clients, or the public

General retention periods:

• Customer and program records: retained for a minimum of 1 year after your last transaction

• Marketing contact records: retained until you opt out or request deletion

• Website usage data: retained for up to 26 months

• Coaching session notes and recordings: retained for 30 days after the session date

When information is no longer needed, we securely delete or anonymize it.

5. WHO WE SHARE YOUR INFORMATION WITH

We do not sell your personal information. We may share it with:

Service providers:

We use trusted third-party providers to operate our business. These include:

• CRM and marketing automation platforms (HubSpot, GoHighLevel)

• Payment processors

• Email and SMS delivery platforms

• Website hosting and analytics providers

• Video conferencing and event platforms

• AI transcription and note-taking tools

• OpenAI, L.L.C. — which powers our AI Investor Assistant (see Section 8)

These providers are contractually required to protect your information and may only use it to provide services to us.

Community and program participants:

As part of your participation in Keyspire's coaching programs and community, some of your personal information — such as your name and general location — may be visible to other program participants within your coaching group or community space. If you do not wish to have your information visible to other participants, please contact us at [email protected].

Business transfers:

If Keyspire is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

Legal requirements:

We may disclose your information where required by law, court order, or regulatory authority, or where necessary to protect the rights, safety, or property of Keyspire, our members, or the public.

Affiliated programs:

If you enroll in a program delivered by an authorized affiliate provider (such as the Canadians Investing in the US program), we may share your registration information with that provider to fulfill your enrollment. You will be informed of this at the time of purchase.

6. INTERNATIONAL DATA TRANSFERS

Some of our service providers are located outside Canada, including in the United States. When your personal information is transferred outside Canada, it may be subject to the laws of that jurisdiction. We take steps to ensure that appropriate safeguards are in place, including contractual data processing agreements with our service providers.

Quebec residents: If your information is transferred outside Quebec, you have the right to be informed of the nature of the information being communicated, the name of the country or jurisdiction to which it is communicated, and the name of the person receiving it. Please contact us at [email protected] for details.

7. COOKIES AND TRACKING TECHNOLOGIES — COOKIE POLICY

This section serves as Keyspire's Cookie Policy. It explains how Keyspire uses cookies and similar technologies on our websites, landing pages, and online services (collectively, the "Sites").

By using our Sites, you agree that we can use cookies and similar technologies as described in this section, subject to your choices and, where required, your consent.

What are cookies and similar technologies?

Cookies are small text files placed on your device when you visit a website. Similar technologies include pixels, tags, SDKs, local storage, and scripts that collect or access information on your device.

Types of cookies we use:

Strictly necessary cookies

Required for our Sites to work properly. These cannot usually be disabled and do not require consent.

Performance and analytics cookies

Help us understand how visitors use our Sites to improve content and user experience.

Functionality cookies

Remember your choices and preferences to improve convenience and personalization.

Advertising and targeting cookies

Used to deliver, measure, and improve our online advertising including interest-based ads and retargeting.

Social media and embedded content cookies

Enable social sharing buttons and embedded videos. These providers may use their own cookies to track usage.

Third-party tools we use:

Google Analytics (Google LLC) — website traffic analysis and performance measurement

Meta Pixel (Meta Platforms Inc.) — advertising measurement and retargeting

HubSpot (HubSpot Inc.) — CRM, marketing automation, and form tracking

GoHighLevel — CRM and marketing automation

Each provider has its own privacy and cookie policy governing their use of data collected through their tools.

Do Not Sell or Share My Personal Information:

Keyspire does not sell your personal information. If you wish to opt out of the sharing of your personal information for targeted advertising purposes, please contact us at [email protected] with the subject line "Do Not Sell or Share My Personal Information." We will process your request and respond within 30 days.

Do Not Track and Global Privacy Control:

Keyspire honours the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we will treat it as a request to opt out of targeted advertising and the sharing of your personal information for such purposes. Your opt-out choice is specific to the browser and device you are using. Some browsers have a "Do Not Track" feature — we currently honour GPC as the primary opt-out mechanism.

Legal basis and regional requirements:

Quebec (Law 25)

Quebec's Law 25 requires that Keyspire obtain your meaningful consent before placing non-essential cookies on your device. A cookie consent banner is implemented on keyspire.com to collect and manage your preferences before these tools are activated. You may withdraw consent at any time through the cookie settings tool on our website.

Canada and United States

We rely on appropriate legal bases including your consent and our legitimate interests. In certain US states, you may have additional rights regarding targeted advertising. We honour those rights as required by applicable law.

How you can manage cookies:

On-site tools

Use our cookie consent banner or settings centre to accept, reject, or customize non-essential cookies. This tool must be used before non-essential cookies are activated for your session.

Browser settings

Most browsers allow you to block or delete cookies. If you block all cookies, parts of our Sites may not function properly.

Third-party opt-out tools

Some third-party providers offer their own opt-out mechanisms. These tools are managed by the third parties and are outside of our direct control.

Cookie retention:

Session cookies are deleted when you close your browser. Persistent cookies remain for a longer period or until you delete them. We aim to set reasonable retention periods consistent with the purpose of each cookie and applicable law.

8. AI INVESTOR ASSISTANT — DATA PROCESSING

Keyspire offers an AI Real Estate Investor Assistant ("AI Investor Assistant") to eligible coaching clients. The AI Investor Assistant involves the collection, upload, and processing of personal information in ways that are specific to this product.

What data is processed:

To personalize your AI Investor Assistant, Keyspire's coaching team may upload personal information you have provided during your coaching engagement. This may include your investor profile, Know Your Client (KYC) information, onboarding call notes, coaching session summaries, investor goals, financial information, and other relevant personal information.

Third-party processing by OpenAI:

The AI Investor Assistant is powered by OpenAI, L.L.C. ("OpenAI"). When you use your AI Investor Assistant, your inputs are transmitted to and processed by OpenAI for the purpose of generating responses. Your use of the AI Investor Assistant is also subject to OpenAI's privacy policy and terms of use.

AI recording and transcription:

You acknowledge and consent to the use of artificial intelligence technologies by Keyspire to record, transcribe, and analyze coaching conversations and communications between you and Keyspire's coaching team. Such recordings and transcriptions may be securely stored in our internal systems for business, operational, quality assurance, and record-keeping purposes. Keyspire handles all recordings and transcriptions in accordance with applicable privacy and data protection laws.

Your consent:

By signing the Keyspire AI Investor Assistant Supplemental Agreement, you consent to the collection, upload, and processing of your personal information as described above, including its transmission to OpenAI.

Access Link confidentiality:

Your AI Investor Assistant is accessed via a unique, personalized access link. This link provides direct access to your personal data. You must not share this link with any other person. Keyspire accepts no liability for privacy breaches resulting from your sharing of your access link.

Full AI terms:

For complete terms governing your use of the AI Investor Assistant, please review the Keyspire AI Terms of Use at keyspire.com/ai-terms-of-use.

9. SMS COMMUNICATIONS

If you opt in to receive SMS messages from Keyspire, we will send you program updates, event reminders, and promotional messages. Message and data rates may apply.

To opt out of SMS messages at any time, reply STOP to any message we send you, or contact us at [email protected] or 1-888-556-2244.

We comply with Canada's Anti-Spam Legislation (CASL) and the U.S. Telephone Consumer Protection Act (TCPA). We will only send SMS messages to individuals who have provided express consent.

We do not sell, rent, or share SMS opt-in information with third parties for their marketing purposes.

10. SECURITY

We have implemented a security program that includes technical, organizational, and administrative measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction, in a manner consistent with accepted industry standards and applicable law.

Our security measures include:

• Secure servers and encrypted data storage

• Firewall protection and network vulnerability monitoring

• Access controls limiting employee access to personal information on a need-to-know basis

• Staff training on data privacy policies and procedures

• Regular internal reviews and audits of our security measures

• Specific incident response and management procedures activated whenever we become aware that personal information may have been compromised

Where you have a password or access link to any Keyspire service, you are responsible for keeping it secure and confidential. Do not share your password or access link with anyone.

No method of data transmission or storage is 100% secure. If you believe your information has been compromised, please contact us immediately at [email protected]. In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and relevant regulators as required by law.

11. YOUR RIGHTS AND CHOICES

Depending on where you live, you may have the following rights regarding your personal information:

All users:

• Access: Request a copy of the personal information we hold about you

• Correction: Ask us to correct inaccurate or incomplete information

• Withdrawal of consent: Withdraw your consent to our use of your information at any time (subject to legal or contractual restrictions)

• Opt out of marketing: Unsubscribe from marketing emails using the link in any email, or contact us directly

• Do Not Sell or Share: Contact us to opt out of the sharing of your personal information for targeted advertising (see Section 7)

Quebec residents (additional rights under Law 25):

• Right to de-indexation: Request removal of information collected unlawfully or no longer necessary for its original purpose

• Right to portability: Request your personal information in a structured, commonly used technological format

• Right to be informed of automated decisions: Be informed if we use automated processing and request human review (note: Keyspire does not currently use automated decision-making)

• Right to lodge a complaint: With the Commission d'accès à l'information du Québec (CAI)

US residents:

US residents may have rights under applicable state or federal privacy laws. Please contact us at [email protected] to learn more about your rights and how we handle your personal information. We will respond to all verifiable requests within the time frames prescribed by applicable law.

To exercise any of your rights, contact us at [email protected]. We will respond within 30 days. We may need to verify your identity before processing your request.

12. WORKFORCE AND JOB APPLICANT PRIVACY

This section applies to personal information collected from current employees, contractors, and individuals who apply for positions with Keyspire Group Inc.

Job applicants:

When you apply for a position with Keyspire, we collect personal information you provide in your application, resume, cover letter, and during the interview process. This may include your name, contact information, employment history, education, references, and any other information you choose to provide. We use this information solely for the purpose of evaluating your application and communicating with you about the hiring process.

If your application is unsuccessful, we may retain your information for up to 12 months in case a suitable position becomes available, unless you request earlier deletion. If you are hired, your application information becomes part of your employment record.

Current employees and contractors:

We collect personal information from employees and contractors necessary to manage the employment or contracting relationship. This includes contact information, payroll and banking details, performance information, and other information required by law or for the operation of our business.

Employee and contractor personal information is used only for legitimate employment and business purposes and is protected in accordance with applicable employment and privacy laws. Access to employee personal information is restricted to those with a legitimate need to know.

Your rights as a workforce member:

Employees and contractors have the right to access and correct their personal information held by Keyspire. To exercise these rights, contact us at [email protected].

13. CHILDREN'S PRIVACY

Our website and services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13 without parental consent, we will delete it promptly. If you believe we have collected information from a child under 13, please contact us at [email protected].

14. LINKS TO OTHER WEBSITES

Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites. We encourage you to review the privacy policies of any third-party site you visit.

15. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. When we make material changes, we will update the effective date at the top of this page and, where appropriate, notify you by email or through our website. Your continued use of our website or services after any update constitutes your acceptance of the revised policy.

16. HOW TO CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact our Privacy Officer:

Privacy Officer, Keyspire Group Inc.

260 Holiday Inn Drive, Unit 23, Building A

Cambridge, Ontario, Canada N3C 4E8

Email: [email protected]

Phone: 1-888-556-2244

You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or, if you are a Quebec resident, with the Commission d'accès à l'information du Québec at www.cai.quebec.