Privacy Policy

Effective date: June 15, 2024

Last updated: October 24, 2025

1. General information

1.2. Introduction

Purpose of this Policy. This privacy policy (the “Policy“) describes the practices of Alfar Capital (hereinafter the “Company“, “we“, “us“, “our“) regarding the collection, use, communication, retention and destruction of information that concerns a natural person and allows that person to be identified, directly or indirectly (hereinafter “Personal Information“).

Persons covered by this Policy. This Policy applies to all persons who use our services and to visitors and users of the Alfar Capital website (the “Website“) (hereinafter “you“, “your“). This Policy does not apply to the Personal Information of the Company’s employees, representatives and consultants, or of any other person affiliated with the Company.

Consent. By using our Website, you agree that we may collect, use, communicate, disclose, destroy and retain (hereinafter “Process” or “Processing“) your Personal Information in accordance with the terms described herein. If you do not agree to be bound by this Policy, please do not access or use our Website. You may also ask us to withdraw your consent (see section 3 – Your rights of this Policy).

Cookie banner. You may change your choices at any time in our Cookie Banner, the pop-up window that requests your consent to certain collections, uses and communications of your Personal Information on the Website.

1.3. Privacy Officer

Contact information of the Privacy Officer. Any comments, questions or complaints regarding this Policy and the Company’s privacy practices may be addressed to our Privacy Officer at:

Title: CFO

Telephone: 1.514.506.0855 x11

Email: [email protected]

Address: 1 Westmount Sq, Suite 1400, Westmount, Quebec H3Z 2P9

2. Processing of Personal Information

2.2. Collection of Personal Information

2.2.1. Means of collection

Various means. We collect your Personal Information through our Website in several ways:

Automatically. When you connect to our Website, the device you use to connect will communicate Personal Information to us;
Electronic forms. When you complete and submit one of our electronic forms;
Emails. Through the emails you send us using one of the email addresses available on our Website;
Cookies. Through cookies and other similar technologies (such as pixels), including the cookies and pixels identified in our Cookie Banner.

(Cookies are text files placed on your device. Cookies may contain personal information.)

2.2.2. Personal Information collected

Categories of information collected. In the course of our activities, we may collect and process various types of Personal Information, including the information listed below:

Identification information, such as your first and last name, mailing address, email address or telephone number;
Demographic and contact information, such as your age or place of residence;
Technical or digital information, including connection information and other information about your activity on the Website, such as your IP address, the pages you viewed, the time and date of your visits, your number of connections, your domain name, the referring site address (if you access the Website from another site), the type of browser you use, your device’s operating system and other hardware and software information;
Your consents collected through the Cookie Banner;
Information required to provide our services, such as information about the services we have provided or are providing to you;
Information you choose to provide or send to us, for example when you complete an online form, respond to solicitations or surveys, or communicate with one of our employees or representatives; and
Information that could be used to locate you, identify you or profile your online activity and preferences for the purposes indicated in the Cookie Banner.

2.3. Use of Personal Information

Purposes. We may use your Personal Information for the purposes described below:

To operate, maintain, monitor, develop, improve and provide the features of our Website;
To develop, improve and offer new services;
To process and resolve complaints;
To build a profile of your activities and interests in order to provide you with targeted advertising and personalized recommendations;
To send you newsletters for promotional purposes, if you consent;
To analyze and locate the Website’s audience and compile statistics in order to improve our services and the Website;
To identify you;
To answer your questions;
To assist you with your request;
To protect our rights and those of our employees, officers and directors. For example, we may retain your Personal Information to protect our interests in connection with potential litigation;
To secure our assets and property, including our Website;
To detect and prevent fraud, errors, spam, abuse, security incidents and other harmful activities;
For any purpose identified in our Cookie Banner; or
For any other purpose required or permitted by applicable law.

2.4. Communication of Personal Information

2.4.1. Communication of Personal Information

Third parties to whom Personal Information is communicated. In addition to circumstances where a law or regulation permits or requires the communication of Personal Information without your consent, we may communicate your Personal Information to third parties where necessary to fulfil the purposes set out in section 2.3 – Use of Personal Information of this Policy. Accordingly, your Personal Information will be communicated to:

Cookie providers

Your Personal Information will be communicated to the third parties listed in our Cookie Banner for the purposes indicated there.

Email services

We communicate your Personal Information to email service providers (such as Gmail, Outlook) to manage our email.

Cookie Banner provider

Our Cookie Banner is provided by a third party, identified in the banner itself.

Web hosts

We use web hosting services to host our Website. All Personal Information we collect through the Website may be communicated to these hosts.

Government agencies

We may communicate your Personal Information to government agencies in response to requests from public authorities or courts, in order to comply with the law or legal proceedings.

2.4.2. Communication outside Quebec

Communication of Personal Information outside Quebec. We may communicate your Personal Information outside Quebec.

3. Your rights

Your rights. Subject to the limits provided by law, you may exercise the rights set out below by writing to our Privacy Officer at the contact information provided in section 1.3 – Privacy Officer. We may ask to verify your identity before responding to any of these requests:

Right of access. You have a right of access to your Personal Information. This includes, among other things, the right:
- To be informed of the Personal Information we hold about you;
- To receive computerized Personal Information in the form of a written and intelligible transcript;
- To receive communication of the Personal Information and a copy of it; and
- To consult your Personal Information free of charge.
Right of rectification. You have the right to rectify your Personal Information. This includes, among other things, the right to:
- Request that any inaccurate, incomplete or ambiguous Personal Information be rectified, modified or updated;
- Request that any Personal Information whose collection, communication or retention was not authorized by law be deleted, rectified, modified or updated;
- Request that any outdated or unjustified Personal Information be deleted, rectified, modified or updated;
- Submit written comments and have them added to your Personal Information or, where applicable, to your file.
Withdrawal of consent. You have the right to ask us to withdraw or modify your consent to a use or communication of your Personal Information at any time, subject to applicable legal and contractual restrictions.

Please note that certain collections, uses and communications are essential to the provision of our services and that, in such circumstances, you will not be able to withdraw your consent and still receive the desired service. In other circumstances, withdrawing consent may affect the quality of the desired service. In either case, we will inform you of the consequences of your choice when you ask us to withdraw or modify your consent.

Complaints. You may file a complaint regarding our practices and policies for the protection of your Personal Information.
You may also contact our Privacy Officer with any questions about this Privacy Policy.

4. Security measures

Purpose of our security measures. We have implemented physical, technological and organizational security measures designed to adequately protect the confidentiality and security of your Personal Information against loss, theft and unauthorized access, breach, disclosure, reproduction, communication, use or modification. These measures include:

the use of Secure Socket Layer (SSL) technology;
restricted access privileges to Personal Information;
the use of backup systems; and
the use of a firewall.

Non-exhaustive list. Given the public nature of this Policy, we have not listed all of the measures we have implemented.

No guarantee of zero risk. Despite the measures described above, we cannot guarantee the absolute security of your Personal Information.

5. Changes to this Privacy Policy

Changes to this Policy. We reserve the right to change this Policy at any time in accordance with applicable law. If we do, we will publish the revised Privacy Policy and update the date of the last update shown on it. If you continue to use our Website after the new version of the Policy takes effect, your use of our Website and services will be governed by that new version.

6. Links to third-party websites

Responsibility for third-party websites. Our Website may from time to time include references or links to websites or services provided and operated by third parties. These websites and services are governed by privacy policies that are entirely separate from and independent of ours. We therefore assume no responsibility for the content or activities of these sites. This Policy applies only to the Website and the services we offer.

7. Governing law

Laws of Quebec and Canada. The laws of Quebec and of Canada, excluding their conflict-of-law rules, govern this Policy and your use of the Website. Your use of the Website may also be subject to other local, provincial, national or international laws.