PRIVACY POLICY

Caignite Canada Consulting Inc.
Business Number: 733153233TZ0001
Website: https://caignite.ca
Contact Email: info@caignite.ca
Effective Date: April 15, 2024

1. INTRODUCTION AND LEGAL FRAMEWORK

This Comprehensive Privacy Policy and Terms of Service (the “Agreement”) governs the collection, use, disclosure, retention, and protection of personal information, as well as the terms under which services are provided by Caignite Canada Consulting Inc. (“Caignite”, “Company”, “we”, “us”, “our”).

This Agreement is designed to comply with applicable Canadian laws, including but not limited to:

• Personal Information Protection and Electronic Documents Act (PIPEDA)
• Canada Anti-Spam Legislation (CASL)
• Applicable provincial privacy laws, including Ontario statutes where relevant

By accessing or using our website (https://caignite.ca) and related services (the “Services”), you consent to the practices described herein and agree to be legally bound by this Agreement.

2. SCOPE OF APPLICATION

This Agreement applies to:

• All website visitors
• Subscribers and paying members
• Individuals communicating with the Company
• Any user providing personal information through our platform

It governs both privacy practices and terms of service usage conditions.

3. PERSONAL INFORMATION DEFINITION

“Personal Information” means any information about an identifiable individual, including but not limited to:

• Name, email address, and contact details
• Billing and payment-related information
• IP address, device identifiers, and usage data
• Account activity and preferences

This does not include anonymized or aggregated data.

4. PIPEDA COMPLIANCE PRINCIPLES

Caignite adheres strictly to the ten fair information principles outlined in PIPEDA Schedule 1:

4.1 Accountability

A designated Privacy Officer is responsible for ensuring compliance with applicable privacy laws and internal policies.

4.2 Identifying Purposes

We clearly identify the purposes for collecting personal information at or before the time of collection.

4.3 Consent

Your informed consent is required prior to the collection, use, or disclosure of personal information, except where otherwise permitted or required by law.

4.4 Limiting Collection

We collect only the information necessary to fulfill legitimate business purposes.

4.5 Limiting Use, Disclosure, and Retention

Personal information is:

• Used solely for identified purposes
• Not disclosed without consent unless legally required
• Retained only as long as necessary or legally required

4.6 Accuracy

We take reasonable steps to ensure personal information remains accurate, complete, and up to date.

4.7 Safeguards

We implement administrative, technical, and physical safeguards appropriate to the sensitivity of the information.

4.8 Openness

Our policies and procedures regarding personal information are transparent and available upon request.

4.9 Individual Access

You have the right to:

• Request access to your personal data
• Request corrections where necessary

4.10 Challenging Compliance

You may direct complaints or concerns regarding privacy compliance to our Privacy Officer.

5. PURPOSES OF DATA COLLECTION

We collect personal information for the following purposes:

• Account creation and subscription management
• Payment processing and billing
• Delivery of financial content and communications
• Customer service and support
• Legal, regulatory, and compliance obligations
• Internal analytics and service improvement

6. CONSENT AND WITHDRAWAL

By using our Services, you provide express or implied consent for data collection and use.

You may withdraw consent at any time, subject to:

• Legal or contractual restrictions
• Potential termination of Services due to inability to fulfill obligations

7. CANADA ANTI-SPAM LEGISLATION (CASL)

Caignite complies fully with CASL requirements:

• We send Commercial Electronic Messages (CEMs) only with consent
• All communications include:
  • Clear sender identification
  • A functional unsubscribe mechanism

Unsubscribe requests are processed within 10 business days.

8. DATA DISCLOSURE

We do not sell personal information.

We may disclose information only in the following circumstances:

• To service providers (e.g., payment processors, hosting providers)
• To comply with legal obligations or court orders
• To protect rights, safety, or property of the Company
• In connection with a corporate transaction (e.g., merger, acquisition)

All third parties are contractually obligated to maintain confidentiality.

9. DATA RETENTION

Personal information is retained:

• For the duration of the user relationship;
• As required by Canada Revenue Agency (CRA) recordkeeping obligations;
• As necessary for legal, regulatory, or dispute resolution purposes.

When no longer required, data is securely destroyed via:

• Encrypted deletion
• Secure shredding protocols

10. DATA SECURITY

We implement commercially reasonable safeguards, including:

• Encryption technologies
• Secure servers and firewalls
• Access controls and authentication measures

However, no system can be guaranteed 100% secure. You acknowledge this risk.

11. CROSS-BORDER DATA TRANSFERS

Your data may be stored or processed outside of Canada, including in jurisdictions with different privacy laws.

By using our Services, you consent to such transfers.

12. USER RIGHTS

You have the right to:

• Access your personal information
• Request corrections
• Withdraw consent (subject to limitations)
• File a complaint with the Privacy Officer or the Office of the Privacy Commissioner of Canada

13. TERMS OF SERVICE – FINANCIAL CONTENT DISCLAIMER

13.1 No Investment Advice

All content is for informational purposes only and does not constitute:

• Investment advice
• Legal advice
• Tax advice

13.2 No Suitability Assessment

Caignite does not assess:

• Risk tolerance
• Financial objectives
• Investment suitability

13.3 Assumption of Risk

You assume full responsibility for:

• Investment decisions
• Trading activity
• Financial outcomes

14. LIMITATION OF LIABILITY

To the maximum extent permitted by law:

• The Company shall not be liable for any financial losses;
• No liability for indirect, incidental, or consequential damages;
• Liability is strictly limited regardless of legal theory.

15. PROFESSIONAL CONSULTATION REQUIREMENT

You are strongly advised to consult:

• Licensed financial advisors
• Accountants
• Legal professionals

before making financial decisions.

16. INTELLECTUAL PROPERTY

All content is the exclusive property of Caignite.

Users are granted a limited license for personal use only.

Prohibited actions include:

• Redistribution
• Commercial use
• Sharing access credentials
• Data scraping

Violations may result in:

• Immediate termination
• Legal action

17. TERMINATION OF SERVICE

The Company reserves the right to:

• Suspend or terminate access at its discretion;
• Enforce compliance with this Agreement.

18. GOVERNING LAW

This Agreement is governed by:

• The laws of the Province of Ontario
• The federal laws of Canada

All disputes shall be resolved in Ontario courts.

19. LIMITATION PERIOD

Any claim must be brought within:

One (1) year from the date the claim arises

20. AMENDMENTS

We reserve the right to modify this Agreement at any time.

Continued use constitutes acceptance of updated terms.

21. SEVERABILITY

If any provision is deemed invalid, the remaining provisions remain enforceable.

22. CONTACT AND PRIVACY OFFICER

For privacy-related inquiries, requests, or complaints:

Privacy Officer
Caignite Canada Consulting Inc.
Email: info@caignite.ca

23. FINAL ACKNOWLEDGMENT

By using https://caignite.ca, you:

• Acknowledge full understanding of this Agreement;
• Consent to data practices described herein;
• Accept all risks associated with financial markets;
• Agree to be legally bound by these terms.