Privacy Policy

1. PURPOSE AND SCOPE

Espace Lookwello Inc. (“Lookwello”, “we”, “our” or “us”) operates a technology platform for booking and connecting people, allowing users to discover beauty, personal care and wellness professionals and establishments, view their services, availability and profiles, and make bookings.

Lookwello also offers professionals features allowing them, in particular, to create and manage their presence on the platform, present their services, manage their availability and receive bookings.

This Privacy Policy (the “Policy”) describes Lookwello’s practices regarding the collection, use, disclosure, retention, destruction and protection of personal information.

It applies to personal information collected by Lookwello through:

• its website;
• its mobile application;
• its client and professional accounts;
• its booking features;
• its support and communication services;
• and any other feature or service operated by Lookwello.

This Policy does not apply to the privacy practices of professionals, establishments or other third parties that are not controlled by Lookwello.

2. DEFINITIONS

For the purposes of this Policy, the following terms have the meanings given below:

“Service” means the website, the mobile application and the digital features, products and services operated by Lookwello, including the search, booking and professional profile management features.

“User” means any person who accesses or uses the Service, including a client, a visitor or any other person using Lookwello’s features.

“Professional” means a professional, self-employed worker, salon, establishment or business that uses Lookwello to present or offer its services and to receive or manage bookings.

“Personal information” means any information concerning a natural person that allows that person to be identified directly or indirectly, in accordance with applicable legislation.

“Processing” means any operation performed on personal information, including its collection, use, consultation, disclosure, retention, modification or destruction.

“Consent” means the valid authorization given by a person regarding the collection, use or disclosure of their personal information, when consent is the applicable basis for the processing.

“Subcontractor” means any person or organization mandated by Lookwello to carry out, on its behalf, an activity requiring access to personal information.

“Confidentiality incident” means, in particular, any access to, use, disclosure or loss of personal information that is not authorized by law, as well as any other situation that may compromise the protection of personal information.

“Anonymization” means the process by which information is processed so that it no longer reasonably allows a natural person to be identified, directly or indirectly, in accordance with applicable legal requirements.

“PIA” means a privacy impact assessment carried out to assess the risks associated with a project involving personal information and to determine the measures to reduce them.

“Applicable laws” means the laws and regulations applicable to Lookwello regarding the protection of personal information, privacy and information security, depending on the jurisdiction concerned.

3. PERSON IN CHARGE OF THE PROTECTION OF PERSONAL INFORMATION

Lookwello is responsible for the personal information it holds and processes in the course of its own activities.

In accordance with the applicable requirements, Lookwello has designated a person in charge of the protection of personal information, responsible for overseeing the application of this Policy and the governance of personal information within the organization.

Person in charge of the protection of personal information:

Espace Lookwello Inc.

privacy@lookwello.com

The person in charge of the protection of personal information exercises, in particular, the following responsibilities:

• overseeing personal information protection policies and practices;
• ensuring the implementation of the applicable governance measures;
• processing requests for access, rectification and other requests relating to personal information;
• handling complaints;
• coordinating privacy impact assessments;
• overseeing the management of confidentiality incidents;
• coordinating the necessary corrective measures;
• contributing to the awareness and training of persons with access to personal information.

The title and contact information of the person in charge of the protection of personal information are made public in accordance with the applicable requirements.

4. PERSONAL INFORMATION PROTECTION PRINCIPLES

Lookwello applies the following principles in managing personal information:

4.1 Necessity

Lookwello limits the collection and use of personal information to what is necessary for the identified purposes.

4.2 Transparency

Lookwello provides the individuals concerned with the information they need to understand the practices applicable to the collection, use and disclosure of their personal information.

4.3 Purpose limitation

Personal information is used only for the purposes identified at the time of collection or for any other purpose authorized by applicable legislation.

4.4 Accuracy

Lookwello takes reasonable measures to ensure that the personal information it uses is sufficiently accurate, complete and up to date for the purposes for which it is used.

4.5 Security

Lookwello implements security measures appropriate to the nature and sensitivity of the personal information and to the risks associated with its processing.

4.6 Limited retention

Lookwello retains personal information only for the period necessary to achieve the purposes for which it was collected, in accordance with its Personal Information Retention and Destruction Policy and subject to applicable legal obligations.

4.7 Accountability

Lookwello maintains policies, procedures, controls and governance mechanisms designed to ensure the responsible management of personal information.

5. CATEGORIES OF PERSONAL INFORMATION

Depending on the nature of the services used, Lookwello may collect and process the following categories:

The nature of the information collected depends on the features used.

Lookwello applies a data minimization principle and does not collect personal information that is not necessary for the identified purposes, subject to applicable legal requirements.

6. INFORMATION RELATING TO BOOKINGS

When a user makes a booking, Lookwello processes the information required to create, confirm, manage and follow up on the appointment.

This information may include, in particular:

• the user’s name;
• their contact information;
• the selected professional or establishment;
• the booked service;
• the date and time;
• the status of the booking;
• the information required for communications relating to the appointment.

The information required to carry out a booking may be disclosed to the professional concerned.

Lookwello remains responsible for the personal information it processes for its own purposes.

The professional remains responsible for the personal information it collects or uses directly for its own professional activities, in accordance with the obligations that apply to it.

7. INFORMATION RELATING TO PROFESSIONALS

When a professional uses Lookwello, we may process information relating to:

• their identity;
• their business or establishment;
• their contact information;
• their profile;
• their services;
• their prices;
• their availability;
• the authorized users of their account;
• their subscription;
• their use of the Service;
• their communications with Lookwello.

Certain professional profile information is intended to be publicly accessible so that users can discover the services offered.

The professional remains responsible for the accuracy, legality and relevance of the information it publishes.

8. PURPOSES OF COLLECTION AND USE

Lookwello uses personal information for the following purposes:

Provision and administration of the Service

• creating and managing accounts;
• authenticating users;
• providing the platform’s features;
• enabling the search for professionals;
• managing bookings;
• managing professional profiles;
• providing user support.

Communications

• confirmations;
• reminders;
• changes and cancellations;
• administrative communications;
• security-related communications;
• responses to support requests.

Security and abuse prevention

• protecting accounts;
• detecting unusual activity;
• preventing fraud;
• preventing abuse;
• protecting the infrastructure;
• investigating incidents.

Improvement of the Service

• analyzing use of the Service;
• identifying problems;
• improving features;
• developing new services;
• producing aggregated or anonymized statistics.

Administration and compliance

• complying with legal obligations;
• responding to legally valid requests;
• managing contractual obligations;
• establishing, exercising or defending rights.

9. BASES FOR PROCESSING AND CONSENT

Depending on the nature of the processing and applicable legislation, Lookwello may process personal information on the basis of:

• the need to provide a requested service;
• the consent of the individual concerned;
• a legitimate interest, where this basis applies;
• a legal obligation;
• any other basis permitted by applicable legislation.

When consent is required, Lookwello obtains it in accordance with the applicable requirements.

Consent must be obtained in a manner that is manifest, free, enlightened, specific and understandable and, where required, express and separate.

When sensitive personal information is involved, Lookwello applies the specific consent requirements provided for by applicable legislation.

When consent is withdrawn, Lookwello stops the processing based on that consent where required by law, subject to information that must continue to be processed for another legally authorized purpose.

10. PRIVACY SETTINGS

When Lookwello offers features with privacy settings, they are designed to provide, by default and without any action by the user, the highest applicable level of privacy.

This rule is applied in accordance with the legal requirements applicable to technological products and services.

Cookie settings are handled in accordance with the specific rules applicable to them.

11. PRIVACY IMPACT ASSESSMENTS

Lookwello integrates the protection of personal information into its development and technology management processes.

A privacy impact assessment (PIA) is carried out when required by applicable legislation, in particular before:

• the acquisition, development or overhaul of an information system or electronic service involving personal information;
• the disclosure of personal information outside Québec when such an assessment is required;
• certain disclosures of information without consent for study, research or statistical purposes when required by law.

PIAs are carried out in proportion to the sensitivity of the information, the purposes of the processing, its quantity, its distribution and the medium used.

The conclusions and protective measures resulting from these assessments are taken into account before the project concerned is implemented.

12. DISCLOSURE OF PERSONAL INFORMATION

Lookwello does not sell its users’ personal information.

Information may be disclosed in the following circumstances.

Professionals

The information required to carry out and manage a booking may be disclosed to the professional concerned.

Service providers

Lookwello may disclose the necessary information to suppliers that provide, in particular:

• hosting;
• IT infrastructure;
• electronic communications;
• notifications;
• mapping;
• geolocation;
• security;
• backup;
• technical analysis.

Authorities

Information may be disclosed when required or authorized by law.

Business transactions

In the context of a merger, acquisition, reorganization, financing, sale of assets or other business transaction, certain information may be disclosed when permitted by law and subject to the applicable protective measures.

13. SUBCONTRACTORS AND SUPPLIERS

Lookwello may retain the services of third-party suppliers for certain technological or operational functions.

Lookwello selects and oversees these suppliers taking into account, in particular:

• the nature of the information processed;
• the sensitivity of the information;
• security measures;
• confidentiality obligations;
• contractual requirements;
• the place of processing;
• the risks associated with the processing.

Lookwello maintains an up-to-date internal register of suppliers and subcontractors with access to personal information.

This register includes, in particular, where relevant:

• the identity of the supplier;
• the function provided;
• the categories of information concerned;
• the place of processing;
• the applicable protective measures.

The list of suppliers may be provided on request where appropriate, subject to confidential or security information that cannot be disclosed.

14. PROCESSING OUTSIDE QUÉBEC OR CANADA

Some of Lookwello’s suppliers may process or host personal information outside Québec or Canada.

Before any disclosure of personal information outside Québec when required by law, Lookwello carries out a privacy impact assessment covering, in particular:

• the relevant factors regarding the protection of personal information;
• the legal framework applicable in the jurisdiction concerned;
• the protective measures available;
• the applicable contractual terms.

Where required, the disclosure is governed by a written agreement and by the appropriate measures provided for by applicable legislation.

15. COOKIES AND SIMILAR TECHNOLOGIES

Lookwello uses various technologies, including cookies, to ensure the operation and security of its services.

15.1 Strictly necessary cookies

Certain cookies are necessary for the operation of the site, in particular for:

• authentication;
• session management;
• security;
• certain essential features.

These technologies may be used without consent when their use is necessary for the operation of the Service.

15.2 Analytics, tracking or profiling cookies

Non-essential cookies and technologies used in particular for the purposes of:

• analytics;
• tracking;
• advertising;
• personalization;
• profiling;
• are only activated after the required consent has been obtained.

When consent is required, Lookwello provides a mechanism allowing users to:

• accept the categories concerned;
• refuse them;
• change their preferences later.

Refusing non-essential cookies does not prevent access to the essential features of the Service.

Lookwello does not make access to essential features conditional on the acceptance of non-necessary cookies.

16. MOBILE APPLICATION AND PERMISSIONS

The Lookwello mobile application may request certain device permissions.

Location

Location may be used to display nearby professionals.

When precise location is used, the required permission is requested at the operating system level.

Notices

Notifications may be used to send:

• confirmations;
• reminders;
• appointment changes;
• account-related information.

Camera and gallery

These features may, in particular, allow professionals to upload photos.

Permissions can be changed or withdrawn in the device settings.

17. MESSAGES AND COMMUNICATIONS

Lookwello may use the contact information provided by users to send the communications necessary for the operation of the Service.

These communications may concern, in particular:

• accounts;
• bookings;
• confirmations;
• reminders;
• security;
• support;
• significant changes to the Service.

Promotional communications are sent in accordance with the applicable legal requirements and the user’s communication preferences.

Withdrawing consent to promotional communications does not prevent the sending of communications necessary for account administration or for carrying out a booking.

18. SECURITY OF PERSONAL INFORMATION

Lookwello implements reasonable and appropriate technical, administrative and organizational measures to protect personal information against risks including:

• unauthorized access;
• unauthorized use;
• unauthorized disclosure;
• loss;
• modification;
• destruction.

Depending on the systems concerned, these measures may include:

• encryption of data in transit;
• password protection;
• access control;
• permission management;
• need-to-know access;
• logging;
• backups;
• monitoring;
• application and infrastructure security measures;
• incident management procedures.

Access to personal information by employees and suppliers is limited to the persons who need it to perform their duties.

19. CONFIDENTIALITY INCIDENTS

Lookwello maintains a formal confidentiality incident management procedure.

A confidentiality incident includes, in particular, any unauthorized access to, use, disclosure or loss of personal information, as well as any other breach of its protection.

When an incident comes to its attention, Lookwello takes reasonable measures to:

• contain the incident;
• limit the risk of injury;
• secure the systems concerned;
• identify the information affected;
• assess the risk of serious injury;
• determine corrective measures;
• make the required notifications;
• prevent the incident from recurring.

Lookwello keeps a register of confidentiality incidents in accordance with the applicable legal requirements.

The register includes, in particular, the required information regarding the incident, its nature, the information concerned, the persons affected, the risk assessment and the measures taken.

The register is kept up to date and retained for the minimum period prescribed by law. For Québec private enterprises, the CAI currently indicates a minimum period of five years from the date or period on which the enterprise became aware of the incident.

When an incident presents a risk of serious injury, Lookwello notifies the Commission d’accès à l’information and the persons concerned in accordance with the applicable legal requirements.

20. RETENTION AND DESTRUCTION

Lookwello retains personal information only for the period necessary to achieve the purposes for which it was collected, to manage the relationship with the user, to comply with legal obligations and to exercise or defend its rights.

Retention periods are determined based on, in particular:

• the nature of the information;
• its sensitivity;
• the purpose of the processing;
• the relationship with the user;
• legal obligations;
• security needs;
• the risks associated with its retention.

At the end of the applicable period, personal information is destroyed or, when the legal conditions are met, anonymized.

Anonymization is carried out in accordance with legal requirements and generally recognized best practices. Information is considered anonymized only when it no longer allows a natural person to be identified, directly or indirectly, in accordance with the applicable criteria.

The detailed rules are set out in Lookwello’s Personal Information Retention and Destruction Policy.

21. ACCOUNT DELETION

Users may request the deletion of their account using the features available on the platform.

Deleting an account does not necessarily result in the immediate deletion of all personal information.

Certain information may be retained when necessary in order to:

• comply with a legal obligation;
• prevent or detect fraud;
• settle a dispute;
• establish, exercise or defend a right;
• comply with a contractual or regulatory obligation.

When retention remains necessary, the use of the information is limited to the purposes justifying its retention.

22. RIGHTS OF THE INDIVIDUALS CONCERNED

Subject to the restrictions and exceptions provided for by applicable legislation, a person may, in particular, request:

• access to their personal information;
• the rectification of inaccurate or incomplete information;
• the deletion of information where permitted by law;
• the withdrawal of their consent when the processing is based on it;
• the cessation or limitation of certain processing where provided for by law;
• the portability of certain information when this right applies.

The person may also request, in accordance with the applicable rules, information about the personal information collected, the categories of persons who have access to it within Lookwello and the applicable retention periods.

23. PROCESSING OF REQUESTS

Any request relating to personal information must be sent to the:

Person in charge of the protection of personal information

Espace Lookwello Inc.

privacy@lookwello.com

Lookwello may request the information reasonably necessary to verify the identity of the requester when such verification is necessary to protect personal information.

Subject to the specific time limits provided for by applicable legislation, Lookwello processes access or rectification requests within a maximum of 30 days of receipt, with the possibility of an extension where permitted by law. When the time limit is extended, the person concerned is informed in accordance with the applicable requirements.

24. COMPLAINTS

Any person who wishes to file a complaint about Lookwello’s privacy practices may contact the person in charge of the protection of personal information:

privacy@lookwello.com

Lookwello examines each complaint, carries out the necessary verifications and communicates its response in accordance with the applicable requirements.

A person may also contact the Commission d'accès à l'information du Québec (CAI) or any other competent authority.

25. PERSONS UNDER 16 YEARS OF AGE

The Service of Lookwello is intended for persons aged at least 16 years.

This age limit is a rule of access to the Service established by Lookwello. It must be read together with the Terms of Use.

Lookwello does not knowingly seek to collect personal information about persons under 16 years of age in circumstances where such collection would be prohibited.

Any person with a concern in this regard may contact:

privacy@lookwello.com

26. AGGREGATED AND ANONYMIZED DATA

Lookwello may use aggregated or anonymized information for purposes including:

• statistics;
• analysis of the Service;
• improvement of features;
• product development;
• performance measurement.

Aggregating data does not necessarily constitute anonymization.

When personal information is anonymized, Lookwello ensures that the anonymization process is carried out in such a way that it is no longer reasonably possible, in the circumstances, to identify the person concerned directly or indirectly, and that this is irreversible.

Anonymization is carried out in accordance with section 23 of the Québec Act respecting the protection of personal information in the private sector, generally recognized best practices and the criteria and terms established by applicable regulations.

27. CHANGES TO THIS POLICY

Lookwello may amend this Policy to take into account, in particular:

• the evolution of the Service;
• new features;
• technological changes;
• changes in suppliers or subcontractors;
• the evolution of Lookwello’s practices;
• legislative or regulatory changes.

The date of the last update is indicated at the beginning of the Policy.

When a change is substantial, Lookwello informs users before it comes into effect where reasonably possible and where required by applicable legislation, in particular by email, in-app notification or notice on the website.

When the change requires new consent, it is obtained in accordance with the applicable requirements.

28. RELATED DOCUMENTS AND POLICIES

This Policy is part of Lookwello’s overall personal information governance framework and must be read together with:

• the Lookwello Terms of Use;
• the Personal Information Governance Policy;
• the Confidentiality Incident Management Policy;
• the Personal Information Retention and Destruction Policy;
• the terms applicable to the referral program;
• any additional notice or policy relating to cookies or to certain features.

29. CONTACT

Espace Lookwello Inc.

Address: 12-11545 Rue De La Gauchetière, Pointe-Aux-Trembles, QC H1B 2H4

Telephone: +1 438 356 6118

General email: support@lookwello.com

Any question, access request, rectification request or complaint relating to the protection of personal information may be sent to:

Person in charge of the protection of personal information — privacy@lookwello.com

© 2026 Espace Lookwello Inc. — All rights reserved.