PROPULIA CAPITAL PRIVACY POLICY

OUR COMMITMENT
This policy has been prepared taking into account the laws applicable to the operations of PROPULIA CAPITAL, namely the Act respecting the protection of personal information in the private sector and other similar laws and regulations of Quebec or Canada. Propulia Capital is committed to respecting applicable laws and protecting your privacy.

Your data is collected for specific, explicit and legitimate purposes that are compatible with these purposes, as more fully described in this policy.

It is kept in an adequate, relevant manner and limited to what is necessary for the purposes for which it is processed.

Your personal information is accurate and kept up to date, and any inaccuracies will be dealt with, erased or rectified.

Appropriate measures have been put in place to ensure the security of your personal information.

OUR ACTIVITIES

The Company’s principal activity is to invest in order to support the growth and development of small and medium-sized businesses, while generating a satisfactory return for limited partners. The Company’s activities also include the provision of a variety of services, such as support for value creation through consulting services, development and commercialization of technology platforms, as well as investment management and disposal of shares invested in portfolio companies.

PURPOSE

This policy applies to personal information collected by Propulia Capital or any of its affiliates to the extent necessary to carry out its activities. This Policy describes what personal information we collect, how we use, disclose, process and retain it, and how you can access, update or correct your personal information. It also explains your rights with respect to the protection of your privacy.

USE OF OUR SERVICES

We use your personal data to provide you with the information or services you require and any business relations arising therefrom, as well as to collect information enabling us to improve our products and services (including through the use of cookies).

PERSONAL INFORMATION WE COLLECT

This is any information that identifies you or could be associated with you, and may include :

Information about your identity and contact details, such as your first name, last name, date of birth, home address, telephone number and e-mail address;
Information about your company, its founders, shareholders, directors or partners;
Business information such as financial data, activities, lenders and contact data;
Information related to services requested and offered;
Information collected when you visit our website;
Information collected through our website contact form or automatically collected through cookies and other session tools (e.g. browsers).
The technologies we use are the following: Cookie Compliance, Google Analytics and Signals, Microsoft 365, including the Office suite as well as Forms for data collection, WordPress, Linkedin, (data relating in particular to advertising reports, location, marketing, search history, cross-device reports, actions on our site and reports on interests and demographics).

COOKIE POLICY

We use cookies and similar tracking technologies on our web site to improve our services, optimize our web site, compile statistics for web site usage analysis and traffic management purposes, and to collect information and personal data based on your choice of settings.

You can change your cookie settings at any time, and you can accept or decline cookies at any time. If you wish to delete cookies that are already on your computer or prevent the installation of cookies in the future, please refer to your browser’s instructions by going to your browser’s HELP menu.

The following information may be stored in a cookie file:

the point of origin of your visit to our website,
the links and advertisements you click on,
the type and version of browser you are using,
the type and model of your device,
any other information you transmit when using our website,
The IP address is not stored by cookies but may be transmitted to third parties when you authorize the use of cookies.

YOUR CONSENT

By visiting our website or using our services, you consent to the collection, use and disclosure of your personal information in accordance with this policy. Your consent may sometimes be implied when it is deemed to be given based on your action or inaction in collecting, using, or disclosing your personal information.

Except as required by law, we will seek your consent when we wish to use your information for a new purpose or for a purpose other than those described in this Policy.

Unless otherwise provided by law or by virtue of your contractual obligations to us, you may withdraw your consent at any time by contacting the person responsible for the protection of your personal information.

WHO HAS ACCESS TO YOUR INFORMATION

Propulia Capital is the sole recipient of your personal information and undertakes not to market it. We restrict access to only authorized persons at Propulia Capital, except for the following third parties who must agree to respect our requirements regarding the confidentiality and security of your information:

Authorized managers and contractors

Our authorized managers and contractors may need to access information about you in order to perform the functions assigned to them as part of the services we provide to you. All such persons are required to comply with privacy protection requirements.

Service providers, authorized resellers and partners

We share certain information with these third parties to market our services, conduct our business, communicate with you, manage our databases, operate our technology systems or applications and infrastructure, as well as to implement our internal procedures, including with our auditors and our advertising and marketing strategy.

Corporate and Subsidiary Reorganizations or Other Transactions

You consent to the disclosure of your personal information to third parties for the following purposes:

Sale or transfer of all or part of our business
Merger
Any other financing operation or other strategic operation on the capital of our company (including in the event of insolvency or bankruptcy)
Restructuring, sale of shares or other change in control of the company
Other authorized reasons

The law permits or requires the collection, use or disclosure of information without consent (e.g. investigations to prevent or take action against illegal activities or potential threats to our rights, court order, exercise of our legal rights, protection of the security of our infrastructure or services, or cooperation with government or law enforcement agencies).

Where applicable, before disclosing personal information outside Quebec, we will conduct a privacy impact assessment and enter into a written agreement with the third party concerned to mitigate the risks identified as a result of this assessment.

RETENTION PERIOD OF YOUR PERSONAL DATA

Propulia Capital undertakes to keep your personal information for no longer than is necessary for the purposes for which it is processed and for the retention periods stipulated by applicable laws. After this period, your information will be destroyed in a secure manner.

WHERE YOUR PERSONAL INFORMATION IS STORED

In Canada, Montreal, Province of Quebec (Microsoft server).

The data and your IP address are stored by Google on servers located in the United States, which means that access to this information will be subject to the jurisdiction of local laws and courts.

In the event that other storage locations are chosen in the future, this policy will mention them.

YOUR RIGHTS

You have the right to access your personal information, subject to legal restrictions. Requests for access, correction or deletion of your information will be processed within thirty days unless they are exceptionally extensive or complex, in which case we will inform you of the time required to process your request.

Access to personal information is free of charge, but reasonable fees may be charged for transcription, reproduction or transmission of your information.

PERSON RESPONSIBLE FOR THE PROTECTION OF YOUR PERSONAL INFORMATION

Ms Nathalia Del Moral, Partner

Contact information: privacy@propuliacapital.ai

This person is responsible for ensuring the protection of your personal information, including handling privacy incidents involving your personal information.

CHANGES TO OUR POLICY

We may amend this policy at any time to comply with the law or to update our service offering. Any changes will be published in this policy.