1. INTRODUCTION AND SCOPE

Acva Investing Corp (“Company,” “we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of personal information in accordance with applicable data protection legislation. This Privacy Policy (“Policy”) describes the manner in which we collect, use, disclose, retain, and safeguard personal information when you access our website, engage our services, submit an application, or otherwise communicate with us. This Policy is intended to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, the General Data Protection Regulation (GDPR) where applicable, and other applicable federal, provincial, and international privacy laws. By using our services or providing personal information to us, you consent to the practices described herein.

2. INFORMATION WE COLLECT

We may collect and process the following categories of personal information: (a) Identity and contact information, including name, date of birth, address, telephone number, and email address; (b) Financial information, including income, assets, investment objectives, and account details as necessary for the provision of our services; (c) Employment and professional information, where relevant to applications or client onboarding; (d) Communications and correspondence with us; and (e) Technical and usage data collected automatically, such as IP address, browser type, device identifiers, and pages visited. We may also receive personal information from third parties, including identity verification providers, financial institutions, and credit reporting agencies, where permitted by law and as necessary for the purposes set out in this Policy.

3. PURPOSES OF PROCESSING

We process your personal information for the following purposes: to provide, administer, and improve our services; to comply with legal, regulatory, and supervisory obligations, including know-your-client (KYC) and anti-money laundering (AML) requirements; to assess and manage risk and to ensure the security and integrity of our systems and operations; to conduct internal business operations, including auditing and quality assurance; to communicate with you and respond to your inquiries; to send marketing and promotional materials where we have obtained your consent or where otherwise permitted by law; and to process and evaluate employment applications. We will not use your personal information for purposes incompatible with those described herein without providing notice and, where required by law, obtaining your consent.

4. DISCLOSURE AND SHARING OF INFORMATION

We may disclose your personal information to: (a) our service providers, agents, and contractors who assist us in operating our business, subject to contractual obligations to protect such information; (b) regulatory authorities, law enforcement agencies, and other bodies when required or permitted by applicable law, including in response to lawful requests or to protect our rights and interests; and (c) successors or assigns in the event of a merger, acquisition, or other business transfer. We do not sell, rent, or trade your personal information to third parties for their marketing purposes. Any disclosure is made only to the extent necessary for the stated purposes and in accordance with applicable law.

5. DATA SECURITY AND RETENTION

We implement appropriate technical, administrative, and physical safeguards designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Such measures include, but are not limited to, access controls, encryption, secure transmission protocols, and staff training. Notwithstanding the foregoing, no method of transmission over the Internet or electronic storage is completely secure; we cannot guarantee absolute security of your personal information. We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes and enforce our agreements.

6. YOUR RIGHTS

Depending on your jurisdiction, you may have certain rights in relation to your personal information, including the right to access, correct, or request deletion of your data; to restrict or object to certain processing; to data portability; and to withdraw consent where processing is based on consent. To exercise any of these rights, or to make an inquiry or complaint regarding our handling of your personal information, please contact our Privacy Officer using the details below. We will respond to legitimate requests in accordance with applicable law. If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority in your country of residence.

7. CONTACT INFORMATION

For questions, requests, or complaints regarding this Privacy Policy or our privacy practices, please contact:

Acva Investing Corp
Privacy Officer
Email: info@acvainvesting.ca
Telephone: +1 (418) 800-3274
Address: 650 Avenue Wilfrid-Laurier, Québec QC G1R 2L4, Canada