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Privacy on DealMaker

Last updated: January 2020

Importance of Your Privacy.

Novation Solutions Inc. O/A DealMaker (“DealMaker”)’s software allows companies to communicate with their stakeholders, often via the company’s lawyers or financial partners (brokers or finders). Communications may include sending updates and other information. DealMaker provides the technology for companies, law firms, investment brokers and other capital markets participants who are using DealMaker. This Privacy Policy describes how DealMaker collects, uses, maintains and discloses the information of people whose information is provided to DealMaker, or who upload their own personal information by visiting the website and utilizing the application (the "Application").

At DealMaker, your privacy is of great importance to us. We understand that you are entrusting us with certain personal information. In exchange, you expect and deserve a commitment to treat your information with respect. Please read this Privacy Policy carefully before submitting any information through the Application. By submitting any information through the Application you are acknowledging that you have read and understand this policy. If you do not agree with the data practices described in this Privacy Policy, you must exit the Application without accessing or using any of our services.

A Special Note About Children.

Children are not eligible to use the Application and we ask that minors (under the age of 13) do not submit any personal information or use the Application. DealMaker does not collect or maintain information from those actually known to be under the age of 14, and no part of the Application is structured to attract anyone under the age of 14. Other age restrictions may be set forth in DealMaker’s Terms of Use from time to time.

How We Collect Information and The Information We Collect

There are several ways in which we may collect personal information fro you. For the most part, we collect information directly from you within the Application by way of example, je your name, user name, password, address, phone number, date of birth, e-mail address, tax information, Social Insurance Number, trading account information, information regarding your registration and/or participation in securities transactions, and information regarding your cell phone and/or other mobile device, and other information mandated by a securities exchange regulator or customarily collected in securities transactions. See below for all Categories of information we collect.

In addition, when you use the Application, DealMaker automatically collects and records technical information on our server logs from your browser or mobile platform, including your IP address and location. DealMaker also collects and uses additional information from users such as transaction location, purchase activity, Application open date and time, idle time, and all clicks and/or swipes within the application (together with time and order). DealMaker may also collect information posted by users on social media sites for users that have opted to connect to or otherwise link DealMaker with social media accounts including Facebook and Twitter. Generally, we do not use or otherwise process this technical data in way that can identify you, except where we are required to treat it as personal information under applicable law.

Additionally, DealMaker may receive information about you from third parties, including other users of the Application in connection with your participation or eligibility to participate in a securities transaction with another user.

Categories of Information Collected.

We collect the following categories of information:

  1. Information we receive from you or our users of the Application. To access the Application, you'll need to provide certain personal information which may include, without limitation, your name, address, date of birth, phone number, user names, e-mail address, information regarding registration details, tax information, social insurance number, trading account information, tax information and other information related to status within certain investments or other information required to comply with securities laws such as personal connections or net worth.

  2. Technical information we collect. In order for DealMaker to enable our users to provide the best possible experience for you on the Application, we collect and track certain user information. When you visit the website, our web server may send a cookie to your browser, which may store the cookie on your computer for a variable duration. This cookie is intended to store a limited amount of information about your site visit. The cookie tracks aggregate information on how our site is being used, including session counts, navigation patterns, pages visited, etc. These cookies, however, do not store any personally identifiable information such as your name, email address or phone number as you browse the site. When you submit a question, we store your cookie identification in our system. This cookie allows our site to recognize you when you return. DealMaker may also utilize web logs to track aggregate information about how our site and/or the Application is being used. Web logs track anonymous user information, including the number of visitors to the Application, operating systems, Internet Provider addresses (if publicly available), and browser type. Unlike cookies, web logs are maintained only on DealMaker servers and do not store or place anything on your computer.

  3. If you come to the DealMaker Website from an online banner ad, an anonymous identification number may be passed to the Website. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising, marketing and banner advertisement campaigns.

  4. Other Information we get from your use of the Application. We may collect information about the service that you use and how you use them. This information includes:

    1. Device information. We may collect device-specific information (such as your hardware model, operating system version, browser diagnostics, unique device identifiers, and mobile network information including phone number).

    2. Location information. When you use the Application, we may collect and process information about your actual location. We may also use various technologies to determine location, some of which may be made available through third party licensors.

    3. Information from surveys. You may have the option of completing an online survey at the website or within the Application from time to time. Participation in surveys is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us in connection with any such survey.

    4. Information from the "Contact Us" section of the Application. You may contact DealMaker through the "Contact Us" feature. Participation in this area is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us.

    5. Information collected other sections of the Application. DealMaker may, from time to time, make various resources available to you within the Application. At times we may collect personal information in connection with providing such services.

How Your Information Is Used.

We and our users use the information provided to us to power the applicable services to you, either directly or through third parties, as further described above in this Privacy Policy. In addition to the uses of the information described above, DealMaker may, from time to time, collect purchasing information and/or data from other sources. DealMaker may collect this information for purposes of performing analytics and conducting user research. This information may be used to communicate and provide additional information that may be of interest to you and our other users.

In addition, DealMaker may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with DealMaker rights or property, or Application users or anyone else that could be harmed by such activities.

How Information Is Share and Disclosed.

DealMaker DOES NOT disclose any personal information about you to or with any person or organization except (i) as authorized by you, (ii) as described in the relevant portion of the Application or within any agreement between us, (iii) as may be required by law or court order, or (iv) as otherwise set forth herein.

DealMaker may share your information in the following circumstances (i) with the companies or third party service providers who are invited to collaborate on the transactions you invest in, as part of the provision of these services, (ii) with your advisors in connection with making available to you certain information relating to the companies or investments you may be interested in, and (iii) with third party service providers who assist DealMaker in providing our services to you, and are contractually obligated to only use the information for that purpose.

If (i) using the Application, you invest in a securities offerings under Rule 506(c) of Regulation D of the Securities Act of 1933, as amended (the "Securities Act") and, you have been verified as an "accredited investor" as defined by Rule 501 of Regulation D of the Securities Act, and (ii) you upload proof of accredited investor status to the Application, DealMaker may communicate your verified accredited investor status to the companies you invest in who are also using DealMaker.

In addition, DealMaker may sell, disclose or otherwise use information gathered within the Application to third parties on an aggregated basis where such does not identify you personally. More specifically, DealMaker may provide to third parties aggregate statistics or information about sales, trends, online traffic patterns, related information or other statistical de-identified information. Other than as described in the foregoing, third parties cannot collect personal information about individual users.

Data Security, Storage and Retention

DealMaker employs measures to protect against the unauthorized access, disclosure, modification or destruction of the information we collect. While we are committed to ensuring the security of the information, no protection measure can provide a 100% guarantee of security. Consequently, we do not warrant or guarantee the security of the information.

Your personal data is stored and / or processed or otherwise used by DealMaker in Canada. We retain your information for as long as necessary or relevant for the listed purposes in this Privacy Policy, or as required by any applicable legal and retention obligations.

Access Request

You can make a request to us at [email protected] at any time, if you would like to know what personal information DealMaker has about you, what it is being used for, and with whom it has been shared. If you notice inaccuracies or wish to update any part of your personal information, you may contact us at any time.

Residents of the E.U: Under the General Data Protection Regulations (GDPR), residents of the E.U also have the right to request the erasure of personal data, right to restrict processing, and in certain circumstances the right to data portability. Please direct any inquiries regarding the foregoing to [email protected], attention Privacy Officer.

Anti-Spam legislation.

Periodically, we or our users may send you commercial electronic messages to alert you to various improvements to our services or other opportunities, via the Application. You may request to stop receiving commercial electronic messages from us at any time by (i) using the “unsubscribe” mechanism in our emails (ii) altering your settings in the Application or (iii) by sending an e-mail to [email protected] to remove yourself from any mailings.

Please note that if you have been invited to participate in a transaction, and you opt-out of receiving emails from DealMaker, you may still receive certain notifications related to the transaction you are participating which are essential to your participation in such transaction.

Changes to Privacy Policy.

We may change or update this Privacy Policy at any time. If we make a change to our Privacy Policy in the future that will affect how we treat your information, we will post such change on the website or within the Application, and such change will be deemed to be effective 2 days from the date of such posting. We encourage you to review this Privacy Policy periodically.

Business Transfer.

We may, in the future, sell or otherwise transfer some or all of our assets or equity to a third party. Your personally identifiable information and other information we obtain from you via the Website or the Application may be disclosed to any potential or actual third party purchasers of such assets or equity and may be among the assets transferred.

Links.

The website or Application may contain links to other websites or applications that are owned and operated by third parties that are not affiliated with us. When you use those links, you leave the Website or Application (as applicable) and we are unable to control how the owners of the websites or applications you link to handle any information they gather about you, including their privacy practices and use of cookies. This Privacy Policy applies only to the Website and Application and does not govern activities on linked websites or applications. We encourage you to review the privacy policy of any other website or application you visit, download or access to understand its practices on how it collects, uses and discloses your information.

Contact:
DealMaker Attn: Privacy Officer
77 King St West, Suite 400
Toronto, ON Canada
M5K 0A1

PLEASE PRINT AND RETAIN A COPY OF THIS AGREEMENT FOR YOUR RECORDS.