Privacy Policy

Information you provide directly: name, contact details, professional background, investor-status indicators, communications preferences, information contained in enquiry, application or subscription forms, and any other information you choose to provide to us.

Information collected automatically: IP address, device and browser type, referring URLs, pages accessed, dates and times of access, and similar technical information collected via cookies and comparable technologies (see our Cookie Policy).

Information from third parties: where permitted by law, information from public registers, sanctions and politically-exposed-persons databases, credit reference agencies, identity-verification providers, professional advisors and referral sources, for identity verification, sanctions screening, fraud prevention and other compliance purposes.

We collect, use and disclose personal information for the following purposes: (a) responding to enquiries and providing requested materials; (b) assessing eligibility and suitability, including investor-status verification; (c) opening and administering client relationships and any resulting subscription; (d) meeting Know-Your-Client, anti-money-laundering, counter-terrorist-financing, sanctions, tax-reporting (including FATCA/CRS where applicable) and other legal or regulatory obligations; (e) preventing, detecting and investigating fraud, misuse and security incidents; (f) improving and securing the Site and our services; (g) sending administrative and, where permitted, marketing communications; and (h) any other purpose disclosed to you at the time of collection or otherwise permitted or required by law.

We rely on your knowledge and consent to collect, use and disclose personal information, except where an exception under PIPEDA or applicable provincial legislation applies (for example, where required or authorised by law).

Where we send commercial electronic messages, we do so in accordance with Canada's Anti-Spam Legislation (CASL). You can withdraw consent to receive marketing communications at any time by using the unsubscribe link included in each message or by contacting info@caldouncapital.ca.

We use a limited set of cookies and similar technologies for essential Site functionality and, where you have consented, for analytics and performance measurement. See our Cookie Policy for details and choices.

We do not sell personal information. We may disclose personal information to: (a) affiliates and related entities; (b) professional advisors (legal, accounting, tax, compliance, audit); (c) service providers assisting us with technology hosting, communications, identity verification, screening, analytics and record-keeping; (d) potential counterparties in a corporate transaction, subject to appropriate confidentiality safeguards; and (e) government, regulatory, self-regulatory or law-enforcement authorities where required or authorised by law.

Service providers are contractually required to protect personal information and to use it only for the purposes for which it was disclosed.

Personal information may be processed, stored or accessed by service providers located outside Canada, including in the United States and other jurisdictions. When this occurs, personal information may be subject to the laws of those jurisdictions, including lawful access requests by foreign courts, law-enforcement or national-security authorities. We use contractual, organisational and technical measures designed to provide a comparable level of protection.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by law. Records collected for AML, tax and securities-law purposes are typically retained for a minimum of the periods required by applicable legislation (which in some cases is up to seven years or longer following the end of the relationship).

We maintain reasonable administrative, physical and technical safeguards designed to protect personal information against loss or theft, and unauthorised access, disclosure, copying, use or modification, appropriate to the sensitivity of the information. No electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Subject to legal and regulatory limitations, you have the right to: (a) access the personal information we hold about you; (b) request correction of inaccurate information; (c) withdraw consent, subject to legal or contractual restrictions and reasonable notice; and (d) make a complaint. Depending on your province of residence you may also have additional rights, including data-portability rights (in Quebec) and the right to be informed of automated decisions where applicable.

To exercise any of these rights, contact our Privacy Officer at info@caldouncapital.ca. We may need to verify your identity before responding to your request.

If you believe we have not handled your personal information in accordance with this Policy or applicable law, please contact our Privacy Officer. If your concern is not resolved to your satisfaction, you may contact the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or, where applicable, the privacy regulator of your province of residence.

Attn: Privacy Officer, Caldoun Capital Inc., 3549 Morgan Cr., London, ON N6L 0B7, Canada. Email: info@caldouncapital.ca.

We may update this Privacy Policy from time to time. Material changes will be indicated by updating the "Last updated" date at the top of this page and, where appropriate, by more prominent notice.