PROTECTION OF PERSONAL INFORMATION POLICY

We respect the privacy of visitors to our website and are committed to protecting it to the extent possible, in accordance with applicable laws, including the Act respecting the Protection of Personal Information in the Private Sector. This Protection of Personal Information Policy (the “Policy”) applies to Finalta Capital Inc. and its affiliates as well as companies for which Finalta is acting as agent (collectively referred to as “we” in this Policy).

This Policy describes our standards for the collection, use, disclosure, and retention of your personal information. It also explains the methods we use to protect your personal information and the right you have to access it. If applicable, personal information collected offline may also be subject to contractual provisions.

The collection of personal information and the purposes for which it is collected

Personal information is defined as any information which relates to a natural person and allows that person to be identified.

You may visit our website without providing any personal information about yourself. In this case, our web server will only collect the IP address that you used to access the site. We use this information to determine the number of visits to our site and the average time spent visiting it. It is also used to establish user statistics, identify which web pages were viewed, and measure overall site performance.

The only personal information we collect is the information you voluntarily provide to us when submitting online forms to contact us or subscribe to our newsletters. We also collect information transmitted to us offline in the context of a commercial relationship with you.

This information is collected to:

• Manage subscriptions to our newsletters and, more generally, to effectively communicate with you and promote our products and services.
• Evaluate your creditworthiness and enable us to make decisions in the context of an application for the financing of a business with which you are associated. Such information includes, but is not limited to, personal information relating to assets, liabilities, financial transactions, income, and personal biographical data (employment, education, etc.).

Furthermore, we use log files, also known as “cookies”, on our website. Cookies are information files saved by your web browser on your device (computer or cell phone). Cookies enable us to recognize visitors to the website and view the order in which various site pages are accessed. Cookies also enable us to improve site functionality and meet the information needs of our visitors. They allow us to identify and target site visitors who have demonstrated an interest in certain pages of our site. Cookies do not contain personal information, but they may be used to enable the display of Finalta advertisements on other sites visited by a user of our website. Please note that you can configure your browser so that it notifies you of the receipt of a cookie file. You will then have the opportunity to refuse the deposit of the cookie on your device.

The third-party services that use cookies, which may be downloaded by your device when you visit the finaltacapital.com site, are:

Google Analytics

Google Analytics is a web analytics service that provides information on how visitors use our website. The cookies used by Google Analytics document the means used to access the site, the origin of the visitor, the pages visited, the time spent consulting pages on the site, etc. Click on this link to learn more about the cookies used by Google Analytics. You can also opt out of Google Analytics cookies: [https://developers.google.com/analytics/devguides/collection/analyticsjs/user-opt-out]

Google Adwords - Conversion tracking

Google Adwords Conversion Tracking allows us to see how a user behaves after clicking on an ad. For example, this tool enables us to link visits to our website with advertising campaigns in order to evaluate their effectiveness.

Google Adwords - Remarketing

The remarketing feature allows us to customize our advertising campaigns to reach users who have already visited our website by providing them with Finalta advertisements while they are visiting other websites.

Consent

When we collect your personal information, we obtain your consent to use it for the purposes for which it was collected, as described above. We must obtain your consent prior to using your information for other purposes or collecting additional information about you.

You may withdraw your consent at any time, subject to legal or contractual restrictions. For example, you cannot withdraw your consent if we need such information to give you a loan.

Under certain circumstances, we may be obligated to collect, use or disclose your personal information without your knowledge or consent. This may happen when, for legal or security reasons, it is difficult to obtain consent. This is particularly the case when information is gathered to investigate a breach of contractual obligations, to detect fraud, or to enforce a law. In such cases, the need to obtain consent could be detrimental to the objective for which the information was collected.

Restrictions

We limit the collection of your personal information to information necessary for the purposes described above. We collect this personal information directly from you, unless you consent that we collect it from third parties or as otherwise permitted by law. We may not disclose your personal information to anyone without your consent, except as may be required by law.

Your personal information is only accessible to those who are authorized to access it and for whom it is necessary in the performance of their duties.

Occasionally, we exchange your personal information with service providers or agents to ensure the proper administration of our products or to provide you with the services you request. These service providers or agents must agree to comply with privacy legislation before any personal information is transmitted to them.

Retention period

We retain your personal information only for the length of time it is needed to fulfil its intended purpose. After this time period, the information is destroyed. When we destroy your personal information, we take steps to ensure that no unauthorized person can access it during the destruction process.

Security measures

We have implemented rigorous security measures to ensure that the personal information entrusted to us remains confidential and is protected from loss, theft, unauthorized access, disclosure, copying, use, or modification. However, the integrity and confidentiality of e-mails exchanged over the Internet cannot be guaranteed.

Access and rectification

You have the right to know if we have any personal information about you and to review that information, if applicable. You may verify the accuracy and completeness of your personal information and, if necessary, request that it be corrected. We will respond to any request for rectification within a reasonable time frame.

Requests to access your information or request corrections must be sent to the following address:

Director of Privacy Policy Gerassimos Touliatos
Finalta Capital Inc.
1002, Sherbrooke Street West, Suite 1550
Montreal (Québec) H3A 3L6 CANADA
D: 514 360 0721
gtouliatos@finaltacapital.com
www.finaltacapital.com

Concerns and complaints

We agree to respond to your enquiries and diligently investigate any complaints you may have about your personal information.

Policy modifications

We reserve the right to modify this policy from time to time. In such a case, our website will be updated and a notice to this effect will be posted with a link to our updated policy. The use of this site following the posting of such a notice constitutes your consent to these modifications.