Privacy Policy

Last Updated: March 11^th 2024

WealthAgile Inc., a corporation existing under the laws of Canada (“WealthAgile”, “we”, “us”, “our” or the “Company”) has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit us at wealthagile.com, or when you access or use any associated Sites, electronic communications, APIs, or mobile applications (collectively, the “Site”).

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us at tim@wealthagile.com.

This privacy policy applies only to our collection, retention, processing, sharing and transferring of your Personal Data (as defined below) on or through our Site. This policy is not applicable to any information collected offline or via channels other than our Site.

By using our Site, you hereby consent to our Privacy Policy and agree to its terms.

1. Information We Collect

The Personal Data that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Data.

If you contact us directly, we may receive additional information about you such as your name, email address, telephone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

When you register for an account, we may ask for your contact information, including items such as your name, company name, address, email address, and telephone number. We may require you to provide us with additional Personal Data as you use our Site.

When you access our Site, we may automatically collect information from the device used to access the Site. Such information may include, but is not limited to, your device type; your device's network connections; your device's name; your device's IP address; information about your device's web browser and the internet connection being used to access the Site; geolocation information; and information that tells us how you use the Site, such as what you have searched for and viewed on the Site and the way you use the Site, statistics regarding how pages are loaded or viewed, the Sites you visited before coming to the Site and other usage and browsing information collected through Cookies.

2. How We Use or Process Information

We use the information we collect in various ways, including to:

• Provide, operate, and maintain our Site

• Improve, personalize, and expand our Site

• Understand and analyze how you use our Site

• Develop new products, services, features, and functionality

• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the Site, and for marketing and promotional purposes

• Send you emails

• Manage risk, and protectthe Site and you from fraud

• Comply with our legal and regulatory obligations and to enforce the terms of use of our Site

3. Cookies

When you visit our Site, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a user and to customize your online experiences, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Site. Certain aspects and features of our Site may only be available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Site may be limited or not possible.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

4. Why We May Retain Personal Data

We may retain personal information which may be associated with an identified or identifiable person (“Personal Data”) to fulfill our legal or regulatory obligations and for our business purposes, including “Know Your Client” and anti-money laundering protocols. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

5. Ways We May Share Information

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

We may share your Personal Data or other information for the following reasons:

With our affiliates: We may share your Personal Data with affiliates of WealthAgile to, among other things, provide services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of WealthAgile products, services, and communications.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for WealthAgile's business purposes or as permitted or required by law, including:

• if we need to do so to comply with a law, legal process or regulation;

• to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to WealthAgile or WealthAgile's affiliates;

• if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial or other loss or in connection with an investigation of suspected or actual illegal activity;

• to protect the vital interests of a person;

• to investigate violations of our Site terms and conditions or enforce a user or other agreement or other legal terms applicable to any service available on our Site;

• to protect our property, services and legal rights;

• to help assess and manage risk and prevent fraud against us, our users and fraud involving our Site, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals;

• to facilitate a purchase or sale of all or part of WealthAgile's business;

• to companies that we plan to merge with or be acquired by; and

• to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction.

In addition, WealthAgile may provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why users visit our Site. This data will not personally identify you or provide information about your use of the Site. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. What Privacy Choices Are Available to You?

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you register for an account on the Site or in the context of your use of the Site. You may be provided with instructions and prompts within the experiences as you navigate the Site.

• Choices Relating to the Personal Data We Collect

  • Personal Data. You may decline to provide Personal Data when it is requested by WealthAgile, but access to certain services and portions of the Site may be unavailable to you.

  • Location and other device-level information. The device you use to access the Site may collect information about you, including geolocation information and user usage data that WealthAgile may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.

• Choices Relating to Our Use of Your Personal Data

  • Online Tracking and Interest-Based Advertising. We may work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party Sites.

    • For more information on third-party advertising-related cookies and interest-based advertising, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit AdChoices.

  • Mobile Device Tracking. You may opt out of the processing and use of certain Personal Data on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at https://youradchoices.ca/appchoices/.

• Choices Relating to Your Registration and Account Information

  If you have an account on the Site, you generally may review and edit Personal Data by contacting us. Contact us at tim@wealthagile.com if you do not have an account or if you have questions about your account information or other Personal Data.

• Choices Relating to Communication

  • Notices, Alerts and Updates from Us:

    • Marketing: If you register an account with us, we may send you marketing content about our Site or services and products, as well as the products and services of unaffiliated third parties and affiliates of WealthAgile through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications by following the instructions in the communications you receive. You may also adjust your communication preferences in your account settings. For messages sent via push notifications, you may manage your preferences in your device.

    • Informational and Other: We will send communications to you that are required or necessary to send to users of our Site, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications.

7. What Are Your Rights?

You may have certain rights in respect of your Personal Data. In particular, you may have a right of access and correction. If you wish to exercise these rights, please contact us.

Depending on applicable law where you reside, you may be able to assert certain rights related to your Personal Data identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, we have absolute discretion in providing you with those rights.

Your rights to your Personal Data are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

Access and Portability. You may request that we provide you a copy of your Personal Data held by us. If required by applicable law, this information will be provided subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your Personal Data in a structured, commonly used and machine-readable format, and to have us transfer your Personal Data directly to another data controller.

Rectification of Incomplete or Inaccurate Personal Data. You may update or correct Personal Data at any time by contacting us at tim@wealthagile.com for help.

Erasure. You may request to erase your Personal Data, subject to applicable law. If you wish to deactivate your account, please contact us at tim@wealthagile.com but note that we may retain certain information as required by law or for legitimate business purposes. If you close your account, we will mark your account in our database as "Closed," but may keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with our legal obligations. However, if you close your account, your Personal Data will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required or permitted by law, or in accordance with this Privacy Policy.

Withdraw Consent. To the extent that the processing of your Personal Data is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of any processing we did prior to your withdrawal that was done on the basis of your consent.

Restriction of Processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your Personal Data under certain circumstances. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Automated Individual Decision-Making, Including Profiling. We may rely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your Personal Data, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

If you believe that we have infringed your rights, we encourage you to contact us first so that we can try to resolve the issue or dispute informally. You can also complain about our processing of your Personal Data to the relevant data protection authority.

8. How Do We Protect Your Personal Data?

We may maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. While we are dedicated to securing our systems and Site, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

9. Can Minors Use Our Services?

The Site is not directed to children under the age of majority. We do not knowingly collect information, including Personal Data, from minors or other individuals who are not legally able to use our Site or services. If we obtain actual knowledge that we have collected Personal Data from a minor, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a minor.

10. What Else Should You Know?

• Changes to This Privacy Policy

  We may revise this Privacy Policy from time to time to reflect changes to our business, the Site or services available on our Site, or applicable laws. The revised Privacy Policy will be effective as of the published effective date.

  If the revised version includes a substantial change, we will provide you with at least 15 days' prior notice by posting notice of the change on our Site or requiring your acceptance of the amended Privacy Policy – if required by applicable law. We also may notify users of the change using email or other means.

• Transfers of Your Personal Data to Other Countries

  Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers may store and process your Personal Data outside of Canada, in the United States of America and elsewhere in the world. We will protect your information as described in this Privacy Policy if your Personal Data is transferred to other countries. By using our Site and services available on our Site, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Site and services available on our Site are appropriate or available in any particular jurisdiction.

11. EU Privacy Rights

Users based in the European Union have the following legal rights in respect of their information:

• The right to require WealthAgile to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;

• The right to require WealthAgile to rectify inaccurate information without undue delay;

• The right to request the erasure of their information. Subject to certain conditions, WealthAgile may be required to erase the information in response to such request where:

• the information is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to terminate his or her use of the Site;

• the processing of the information is based on the user's consent (and the other circumstances described in the “Why We May Retain Personal Data” and “Ways We May Share Information” sections above no longer apply), if the user withdraws his or her consent; or

• the user objects to the processing of his or her information and there are no overriding legitimate grounds for the processing.

• Where WealthAgile has disclosed the information of a European Union user to a third party and the user requests the erasure or rectification of the data, WealthAgile will take all reasonable steps to inform the third party of such request.

• The right to restrict WealthAgile from processing their information in certain circumstances, such as where the accuracy of that information is disputed or an objection has been raised (see below). In such circumstances, WealthAgile will only process that information with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;

• The right to receive their information from WealthAgile in a structured, commonly used and machine-readable format;

• The right to object to the processing of their information by WealthAgile where:

  • WealthAgile has relied on the 'legitimate interest' basis for processing that information, in which case we will immediately stop processing the user's information unless we have compelling legitimate grounds which override the interests, rights and freedoms of the user; or

  • the information is used for direct marketing purposes, in which case we will immediately stop processing the user's information for such purposes.

• The right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.

• The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.

12. Contact Us

You may contact us if you have general questions about our Privacy Policy and practices or questions about your account information or Personal Data.

We want to make sure your questions go to the right place:

• Email us at tim@wealthagile.com to contact us about your WealthAgile account or transaction or in relation to any privacy-related matter you have questions or concerns about.