Privacy Policy

Privacy on DealMaker - Updated September 2023

Protecting Your Information Is Our Priority
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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, broker-dealers, and other capital markets participants who are using DealMaker. All transfer agent related-activity accessed through the website is conducted by DealMaker Transfer Agent LLC O/A DealMaker Shareholder Services (“DealMaker SS”), an affiliate of DealMaker and a SEC-registered transfer agent. In certain cases, securities-related activity accessed through the website may be conducted by DealMaker Securities LLC (“DM Securities”), an affiliate of DealMaker and an SEC and FINRA registered broker-dealer.

This Privacy Policy describes how DealMaker and its affiliates (collectively “DealMaker,” “We” or “Us”) collect, use, maintain and disclose 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. “You”, “your” or “User” refers to anyone who accesses or browses the website or uses the Application. 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.
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‍How We Collect Information and The Information We Collect
‍There are several ways in which we may collect personal information from you. We collect information directly from you within the Application, for instance:  your name, user name, password, address, phone number, date of birth, e-mail address, tax information, Social Insurance Number or Social Security 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 regulatory body or customarily collected in securities transactions. See below for all Categories of information we collect.
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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 a 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: 

‍Basic Identifying Information which may include, without limitation, your name, address, date of birth, phone number, user names, e-mail address;
‍Government Issued Identifiers which may include registration details, tax information, Social Insurance Number or Social Security Number, 
‍Sensitive Personal Information such as  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 including: 
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‍Device Information Or Other Unique Identifiers: 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 other categories of 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. 
‍Internet or Other Network Activity: DealMaker may also utilize web logs to track aggregate information about the use of our website and/or the Application. 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. We may use analytics programs such as Google Analytics to assist in collecting and analyzing web log information. Unlike cookies, weblogs are maintained only on DealMaker servers and do not store or place anything on your computer. You may access our cookie policy and learn how to manage your cookies here: https://dealmaker.tech/cookies
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‍3. Anonymous Information From Online Banner Ads. 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. Additional Information we receive from your use of the Application. We may collect information about the services that you use and how you use them. This information includes:

a. Device Information Or Other Unique Identifiers:  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).
b. Geolocation Data 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.
c. User Content: 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.  We may also collect 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.
D. Inferences:  We may use analytics programs such as Google Analytics to assist in drawing inferences based on the anonymized information identified above.  This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall characteristics of particular investments.
e. Information collected in 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.  We may provide different or additional notices or choices regarding your personal information at that time.  
f. Information You Provide To Our Affiliates. You may provide information directly to an affiliate (for example, DealMaker Shareholder Services or DealMaker Securities) exclusively for use by this affiliated entity. For example, you may be asked to provide your name, email address, phone number, ownership interest in an issuer and broker dealer of record. You consent to the sharing of this information with DealMaker’s affiliated entities and to DealMaker’s use of this information, as described in this Privacy Policy. You have the right to limit the other affiliated entities from contacting you for marketing purposes or otherwise.

How We Use Your Information.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 specific uses already described, DealMaker may use the information provided to us: 
(i) to deliver services requested by you; 
(ii) to provide customer support and improve services requested by you; 
(iii) to manage customer accounts; 
(iv) to remedy technological problems; 
(v) to automatically update services offered through the Application;
 (vi) to verify your identity in connection with a service requested by you; (vii) to prevent fraudulent, unauthorized or illegal activity in connection with the website or Application; 
(viii) to protect against a legal liability and/or defend DealMaker’s legal rights;
 (ix) in response to an authorized request from legal or public authorities (for example, the police, a Court or government agency); and
 (x) to provide additional services as described to you at the time you request the service.

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 the 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.

DealMaker is not responsible for the use of your information that you provide to third parties, either personally or through third party websites. For information on how third party websites and applications use the information you share with the third party, we encourage you to read the third parties’ privacy policy and terms of use.

How Your Information Is Disclosed and Shared.

‍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, affiliates 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 information 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 Of Your Personal Information

‍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 regulatory retention obligations.

Transfer of Your Personal Information

‍Your personal information will be processed at our operating locations and in places where the parties (you or third parties) are located. This means your information may be stored on servers or databases co-managed with hosting providers outside of your home country, province or state where data protection laws may differ from your home jurisdiction.

By accessing the website and Application and providing us with your personal information, you consent to the transfer of your personal information to servers and databases located outside of your home jurisdiction.

‍Access Request, Correcting or Deleting your Personal Information

‍At any time, you can make a request to us at info@dealmaker.tech or via mail to:

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

, 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, correct inaccuracies or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. If you are a resident of California, Colorado, Connecticut, or Virginia you have the right to access, correct, and delete personal information under the applicable law (if these laws are applicable and once these laws become effective). 

Please note that some of the rights may vary depending on your country, province, or state of residence. 

Residents of the E.U.: Under the General Data Protection Regulations (GDPR), residents of theE.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 info@dealmaker.tech, attention Privacy Officer.

‍Residents of California: Under the CCPA, residents of California also have the right to notice of the categories of information collected, the rights to access information regarding the disclosure of personal data, the right to refuse the sale or sharing of personal data, the right to correct or  delete personal data in certain circumstances and the right not to be discriminated against for exercising consumer privacy rights. Please direct any inquiries regarding the foregoing to info@dealmaker.tech, attention Privacy Officer and see the section below entitled “Your California Privacy Rights.”.

Identity VerificationTo process your requests, we will need to verify your identity to confirm that the request came from you. We may contact you by phone or e-mail to verify your request. For certain requests, we may also ask you to provide details about your identity or the most recent purchase that you made.

Residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf to access or delete your personal information (if these laws are applicable and  once these laws become effective). To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

The Right to opt-Out of Cookies and Sale/Sharing Using Tracking Technologies ( Google Analytics)

Our use of online tracking technologies such as geolocation may be considered a “sharing” under applicable law if this information is provided to a third party, even if the information is de-identified. 

Categories of third parties to whom this personal information may be shared include advertisers and marketing partners and data analytics providers.

Residents of Colorado, Connecticut, and Virginia can opt out of sharing  by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our website and selecting the appropriate preference.” 

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 admin@dealmaker.tech 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 in, which are essential to your participation in the transaction.

Changes to Privacy Policy.We may change, modify, add, remove, or update this Privacy Policy at any time (“Change(s)”). 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 the effective date at the top of this Privacy Policy will be updated. Any 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. You will be deemed to consent to any Changes to this Privacy Policy by your continued or subsequent use of the website or Application following the Changes.

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. Said third party may alter, update or change this Privacy Policy.

‍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.

How to Contact Us:
If you have any questions about this Privacy Policy, please contact us at info@dealmaker.tech or at:
‍DealMaker Attn: Privacy Officer
77 King St West,
Suite 400
Toronto, ON
Canada
M5K 0A1

Your California Privacy Rights.
If you are a California resident, under the California Consumer Privacy Act (“CCPA”) you have additional rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know.
You have the right know the categories of personal information we collect and the purpose for which we use it including:

● The categories of personal information we collected.  Please see the section above entitled ”Categories of Information Collected” ;
● The sources from which personal information was collected.  Please see the section above entitled “How We Collect Information and The Information We Collect”;
● The commercial purpose for collecting personal information (in accordance with the services offered through the website or the Application).  Please see the section above entitled “How We Use Your Information.”;
● The categories of third parties with whom we shared personal information. Please see the section above entitled “How your Information is disclosed and shared” ; and
● The specific pieces of personal information we have collected about you.

We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:
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We disclose Basic Identifying Information with service providers and third parties, such as analytics, payment processors and anti-money laundering software.
We disclose de-identified Geolocation Data with businesses, service providers, and third parties such as analytics.
We disclose Inferences with businesses and service providers who help administer marketing.

The above noted information is shared.  We do not sell your personal information. 

As stated in  the section entitled “Data Security, Storage and Retention Of Your Personal Information,” we typically 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 regulatory retention obligations.

‍The Right To Request and the Right to Access.You have the right to request and obtain access to personal information about you that we have collected, used or disclosed over the past 12 months including those categories above.  If you would like more information, please submit a request to:

‍DealMaker Attn:
Privacy Officer
77 King St West,
Suite 400Toronto,
ON Canada
M5K 0A
‍Or Via email to: info@dealmaker.tech

‍Right to Correct or Delete. You have the right to request that we correct or delete the personal information we have collected from you over the last 12 months. If you request that we delete your information, there are some exceptions pursuant to which we are not permitted to delete your personal information.

Right to Limit the Use of Sensitive Personal Information:  
California residents have the right to limit the use of sensitive personal information. We  only collect sensitive personal information, as defined by applicable California law, with your consent and only use the sensitive personal information for the use disclosed at the time of collection. We do not use sensitive personal information for inferring characteristics about you.

‍Right Not To Be Discriminated Against.You have the right not to be discriminated against for exercising your consumer privacy rights under the CCPA.

‍Right Not To Sell or Share My Personal Information.

‍The CCPA gives California residents the right to ask companies not to sell to or share their personal information with  third parties. We do not sell your personal information.  Other than as described in the forgoing, we do not share your personal information.If you are a California resident and would like to exercise your CCPA rights, correct or delete your personal information, please contact us by either of the following methods: 

Via Mail:
DealMaker Attn: Privacy Officer
77 King St West,
Suite 400Toronto,
ON Canada
M5K 0A1
Via Email:  info@dealmaker.techDealMaker will respond to a California consumer privacy request for access or deletion within 45 days of receiving and verifying the request. We may extend this time period by up to an additional 45 days, if reasonably necessary and with prior notice, to you.
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