Welcome to Wealthstack Solutions Inc.'s (the Platform Service Provider“The PSP”) Privacy Policy. The PSP respects your privacy and is committed to protecting your Personal Information and complying with applicable data protection and privacy laws. This policy (“Policy”) will inform you as to how we process your Personal Information and tell you about your privacy rights and how the law protects you.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your Personal Information. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Reference to “consent”, “your consent” or “your explicit consent” shall include the ticking of a tick box or clicking on a “submit” button, “subscribe” or “I agree” button or “send” button or sending a reply by email after we have made available our Privacy Policy to you.

1. 1. IMPORTANT INFORMATION AND WHO WE ARE

   1. Responsible Party
      1. The PSP is the Responsible Party when engaging with you as a potential customer / client user of our website and other social media sites (“Sites”) or our services (“Services”) and responsible for your Personal Information (also collectively referred to as "The PSP", "we", "us" or "our" in this Privacy Policy).
      2. We have appointed a Privacy Officer (PO) who is responsible for overseeing questions in relation to this Privacy Policy.
   2. Processing on behalf of third party: As per the nature of our business we make technology available to financial institutions (customer of the PSP (“The PSP Customer”)) to enable them to engage and process their customers Personal Information. Where We Process a Data Subject (i.e. resident or visitor or Authorised User) Personal information on instructions from The PSP Customer and subject to a Software as a Service Agreement or Services Agreement between the PSP and The PSP Customer, We will act as a third party processor/operator and The PSP Customer will act as the Responsible Party. As Responsible Party The PSP Customer has sole responsibility for the legality, reliability, integrity, accuracy and quality of the Personal Information he/she/it or someone on their behalf makes available to Us.
   3. Contact details
      1. If you have any questions about this Policy, including requests, or our privacy practices, please contact our Privacy Officer on the contact details below:
         1. Full name of legal entity: Wealthstack Solutions Inc.
         2. Privacy Officer: Vincent Heys
         3. Email address: vincent@wealthstack.ca
         4. Other Contact details: telephone at +1 289 682 8411
         5. Registered address: 2115 South Service Road, Oakville, LGL 5W2, Canada
   4. Changes to the Privacy Policy and your duty to inform us of changes
      1. We keep our Privacy Policy under regular review. This version was last updated as per the date in the footer. Archived versions (if available) can be obtained by contacting us. Any changes made to our Privacy Policy in future will be posted on our website. The new version will apply the moment it is published on our website or incorporated by reference in any communication.
      2. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
   5. Integration into other sites: This Privacy Policy applies to our website(s) and our electronic communications only. We do not exercise control over the sites who provide services or products to you as part of their own offering. These other sites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We cannot be held responsible for any wrongful handling of end users’ information by other sites.
   6. Third-Party links: Our Sites may include links to Third-Party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. If you disclose your Personal Information to a Third-Party, such as an entity which operates a website linked to this our website or social media sites, THE PSP SHALL NOT BE LIABLE FOR ANY LOSS OR DAMAGE, HOWSOEVER ARISING, SUFFERED BY YOU AS A RESULT OF THE DISCLOSURE OF SUCH INFORMATION TO THE THIRD-PARTY. This is because we do not regulate or control how that Third-Party uses your Personal Information. You should always ensure that you read the privacy policy of any Third-Party. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. 2. THE DATA WE COLLECT ABOUT YOU

   1. Personal Information means the information as per the Definitions. It does not include data where the identity has been removed (anonymous data).
   2. We collect, use and share aggregated data and pattern data such as (but not limited to) statistical or demographic data or service and/ or product transactional data for any purpose. Aggregated data or pattern data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or executing a specific transaction type (where applicable). However, if we combine or connect aggregated data or pattern data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy.
   3. You may choose to provide additional Personal Information to us, in which event you agree to provide accurate and current information, and not to impersonate or misrepresent any person or entity or falsely state or otherwise misrepresent your affiliation with anyone or anything.
   4. Submission of Personal Information on behalf of another: If you provide information on behalf of someone else, then it is your responsibility to obtain the necessary consent from the person before making the Personal Information available to us. On receipt of Personal Information, we assume that the necessary consent has been obtained and will process the Personal Information as per your instructions. By submitting such Personal Information on behalf of another person, you indemnify us against any Third-Party claim, where such Third-Party claim relates to Personal Information that has been processed without the necessary consent or other available exception allowed by law.
   5. If you fail to provide Personal Information: Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services/products (including services/products for no charge)). In this case, we may have to cancel a service or product order you have with us, but we will notify you if this is the case at the time.

3. 3. HOW IS PERSONAL INFORMATION COLLECTED?

   We use different methods to collect data from and about you including through:

   1. Direct interactions. You may directly provide us with your Personal Information when you:-
      1. engage with us via Zoom, Skype or any other Video conferencing facility;
      2. apply/sign up for any of our services (subject to the specific service terms and conditions);
      3. apply/sign up for third party integration partner services;
      4. request marketing material from us;
      5. give us feedback; or
      6. contact us via WhatsApp or other social media sites messaging platforms we may subscribe to.
   2. Automated technologies or interactions. As you interact with our services or website, we will automatically collect Technical Data about your equipment, browsing actions, patterns and device(s). We collect this Personal Information by using cookies (see section 4) below), server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
   3. Third parties or publicly available sources. We will receive Personal Information about you from various third parties and public sources as set out below:
      1. Technical Data from the following parties:
         1. analytics providers such as Google ("How Google uses information from sites or apps that use our services", (located at https://policies.google.com/technologies/partner-sites)
         2. advertising networks; and
         3. search information providers.
      2. Identity and Contact Data from publicly available sources.
      3. Technical and Transactional Data from Third-Party service providers that provide a service or product to you, subject to your consent to us to collect the information.
      4. Personal Information as received from your advisor, subject to your consent.

4. 4. COOKIES

   1. Our Sites makes use of cookies to help us understand our users better. Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. Cookies do not harm your computer or any files on your computer. Depending on the type of cookie we use, cookies also allow us to make our websites more user friendly.
   2. To see our Cookies policy - click here.

5. 5. HOW WE USE YOUR PERSONAL INFORMATION

   1. We will not sell your Personal Information. We will only use Personal Information within the framework of the law. Most commonly, we will use Personal Information in the following circumstances:
      1. where you have given us your consent; or
      2. where we need to perform the contract, we are about to enter into or have entered into with you; or
      3. where it is necessary for the protection of your legitimate interest; or
      4. where it is necessary for our legitimate interests (or those of a Third-Party) and your interests and fundamental rights do not override those interests; or
      5. where we need to comply with a legal obligation.
   2. Generally, we do not rely on Consent only as a legal basis for processing your Personal Information although we will get your Consent before sending third-party direct-marketing communications to you via email or text message. You have the right to withdraw Consent to marketing at any time by contacting us or using such automated facilities made available by us.
   3. Purposes for which we will use Personal Information:
      1. We have set out in the table below a description of all the ways we plan to use Personal Information, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
      2. Note that we may process Personal Information for more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
   4. The PSP only shares Personal Information with other companies or individuals outside of The PSP in the following circumstances:
      1. We have your Consent.
      2. We may provide such information to affiliates in The PSP- group of companies, to collaborating companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
      3. We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
         • satisfy any applicable law, regulation, legal process or enforceable governmental request;
         • enforce applicable Terms of Use, including investigation of potential violations thereof;
         • detect, prevent, or otherwise address fraud, security or technical issues; or
         • protect against imminent harm to the rights, property or safety of The PSP, users of this website or the public as required or permitted by law.

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To register you as a Customer / client and/or allow you to create an account; alternatively To register you as a client (End User) of your selected advisor (customer of The PSP) to allow you to utilise your advisor services.	Full name (“Identity”); Age; Date of birth; Sex; Financial goals and account values; and Email address & Telephone number (“Contact”)	Performance of a contract with you (including the browse wrap agreement (Terms of Use of our website) Your consent
   To perform in accordance with our service agreement: Deliver the services or products; Manage payments, fees and charges; Collect and recover money owed to us. To perform the services to you as End User, as agreed to between The PSP and your financial advisor	Identity; Contact; Financial; Transaction; Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) [TAKE NOTE: we do not store credit card - we use third party service providers to execute transactions where you use your card. You should read their privacy policy].
   To manage our relationship with you as a customer/client or End User (on behalf of a financial institute or your financial advisor: To deliver the services and/or products; Notifying you about changes to our terms or privacy policy or service/product terms and conditions; Asking you to leave a review or take a survey.	Identity; Contact; Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers/clients use our products/services)
   To administer and protect our business, website and other electronic platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity; Collect; and Technical.	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
   To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity; Contact; Profile Usage; Marketing and Communications; and Technical.	Necessary for our legitimate interests (to study how customers/clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
   To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical; and Usage	Necessary for our legitimate interests (to define types of customers/clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). Also see our Cookies Policy.
   To make suggestions and recommendations to you about products or services that may be of interest to you	Identify; Contact; Technical; Usage; Profile; and Marketing and Communications.	Necessary for our legitimate interests (to develop our products/services and grow our business) Direct Marketing (existing customer or party that has given its/his/her consent)

   5. Marketing: We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.
      1. Promotional offers from us.
         1. As a customer/client of The PSP we may use your Contact information to submit to you direct marketing communications about our services and/or products that are related and that we feel may be of interest to you.
         2. If you are not yet a customer/client of The PSP we will ask you for your Consent (opt-in) prior to sending you direct marketing material.
      2. Third-party marketing.
         1. We will get your express opt-in consent before we share your Personal Information with any third-party for marketing purposes.
         2. TAKE NOTE: We may provide (without your consent) third-party marketing parties/ advertisers with anonymous aggregate information (Aggregate Data (see 2)b) above)) about our users (for example, we may inform them that 500 men aged under 30 have clicked on a specific product or advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a specific region). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience. IMPORTANT: We do not disclose information about identifiable individuals to our advertisers.
      3. Opting out.
         1. You can ask us or third-parties to stop sending you marketing messages at any time by using the unsubscribe function on our direct marketing communications or by contacting us at any time on info@wealthstack.ca and requesting to op-out of our marketing services.
         2. Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a service purchase, product purchase, service experience or other transactions.
   6. Change of purpose.
      1. We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
      2. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
      3. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. 6. DISCLOSURES OF PERSONAL INFORMATION

   1. We may share Personal Information with the parties set out below for the purposes set out in the table above.
      1. Internal Third-Parties as set out in the Definitions. Where we share Personal Information to our group (collaborating companies/ partners/ agents), we ensure your Personal Information is protected by requiring all our collaborating/group companies to follow this Policy when processing your Personal Information.
      2. External Third-Parties as set out in the Definitions and to those external third parties as per your instructions.
      3. We may provide such information to affiliates in The PSP - group of companies, to collaborating companies or other trusted businesses or persons for the purpose of processing Personal Information on our behalf.
      4. Third-Parties to whom we may choose to sell, transfer or merge all or parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.
   2. We require all Third-Parties to respect the security of your Personal Information and to treat it in accordance with the law. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
   3. We do not allow our Third-Party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

7. 7. INTERNATIONAL TRANSFERS

   1. Some of our External Third-Parties may be based abroad/internationally so their processing of your Personal Information could involve a transfer of data to the country of their residence.
   2. Whenever we transfer your Personal Information internationally, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
      1. We will only transfer your Personal Information to countries that have been deemed to provide a similar level of protection for Personal Information.
      2. Where we use certain service providers, we conclude an agreement with them to confirm that your Personal Information is confidential, they can only process on our instructions and that they should establish and maintain appropriate technological and organisational measurements to protect your Personal Information.
      3. Where we use providers based in the United States of America, we may transfer data to them only in the instance that they are part of the Privacy Shield which requires them to provide protection to Personal Information similar to the conditions we impose, which we believe are good principles to ensure compliance.
   3. By submitting your Personal Information to us you consent to the transfer of your Personal Information globally/internationally (when required) based on the above.

8. 8. DATA SECURITY

   1. We have put in place appropriate technological and organisational measures to prevent Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Personal Information to those employees, agents, contractors and other third-parties who have a business need to know. They will only process Personal Information on our instructions, and they are subject to a duty of confidentiality.
   2. We have put in place procedures to deal with any suspected Personal Information breach and where required by law we will notify you and any applicable regulator of a breach where we are legally required to do so.

9. 9. DATA RETENTION

   How long will we use your Personal Information for?
   1. We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
   2. To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
   3. In some circumstances, you can ask us to delete your data: see your legal rights in clause 12) below for further information.
   4. Should we anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes we will be able to use this information indefinitely without further notice to you.

10. 10. RECORDS

    We will keep detailed, accurate and up-to-date written records regarding any Processing of Personal Information it carries out, including but not limited to, the access, control and security of the Personal Information and approved subcontractors, the processing purposes, categories of processing, any transfers of Personal Information to a third country and related safeguards, the instructions as received from our customers/clients and a general description of the technical and organisational security measures and retention and destruction of Personal Information.

11. 11. SOCIAL MEDIA

    1. Our website(s) or services may provide you with social plug-ins from various social media networks. If you choose to interact with a social network (for example: Facebook, Instagram or LinkedIn) such interactions will be subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
    2. Our social media network page(s) may share web links to relevant web pages. By default, some social media platforms shorten lengthy URL's. You are advised to exercise caution and due care before clicking on any shortened URL's published on social media platforms by this website. Despite our best efforts to ensure that only genuine URL's are published, many social media platforms are prone to spam and hacking and therefore our website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.

12. 12. YOUR LEGAL RIGHTS

    1. Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Information:
       1. Request for Access: Request access to Personal Information. There may be a fee associated with this request - see below
       2. Request Correction of the Personal Information that we hold about you.
       3. Request erasure of your Personal Information.
       4. Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
       5. Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information.
       6. Request the transfer of your Personal Information to you or to a third-party.
       7. Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
    2. If you wish to exercise any of the rights set out above, please contact us at the details mentioned 1)b) above in order for us to advise you further.
    3. Time limit to respond: We try to respond to all legitimate requests within 30 (thirty) days. Occasionally it could take us longer than 30 (thirty) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

13. 13. DEFINITIONS

    1. Consent means any voluntary, specific and informed expression of will in terms of which permission is given for the processing of Personal Information.
    2. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests override the impact such use may have on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    3. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    4. Personal Information means any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
       • age, name, ID numbers, income, ethnic origin, or blood type;
       • opinions, evaluations, comments, social status, or disciplinary actions; and
       • employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).
    5. Responsible Party means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for processing personal information.
    6. Services/Products means the services/ products as reflected on our website and promoted via other sites of ours;
    7. THIRD-PARTIES
       1. Internal Third-Parties: Partners, affiliates, employees, shareholders, directors and/ or agents of The PSP (if applicable) and other divisions within The PSP, acting as joint responsible parties or operators and who may also provide services and/or products similar to those of The PSP.
       2. External Third-Parties:
          1. Service providers acting as operators who provide IT and system administration services or implementation services (for purposes of our products and/or services as acquired by customers/clients).
          2. Professional advisers acting as operators or joint Responsible Parties, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
          3. Canada Revenue Agency, regulators and other authorities acting as operators or joint Responsible Parties who require reporting of processing activities in certain circumstances.
          4. Courts of law or any other authorities where we have an obligation under law to share your Personal Information.
          5. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets.

END OF POLICY