Privacy Policy:

Here’s the revised and summarized version of the Privacy Policy for **Fairfax Partners Inc.** and its affiliate companies, incorporating an insider trading clause and updating the information as per your request:

---

**Privacy Policy**

**LAST UPDATED: September 2, 2024**

Your privacy is important to us. This Privacy Policy ("Policy") applies to services provided by **Fairfax Partners Inc.** and its affiliate companies (“we”, “us”, or “Fairfax Partners”) and our websites **fairfaxpartners.ca**, **parting-clouds.com**, product pages, mobile or web applications, or other digital products that reference this Policy (collectively, the “Services”). This Policy explains what information we collect, how we use it, and your rights concerning your Personal Information.

We may update this Policy from time to time. You are encouraged to review the Policy periodically, as any changes will be posted on this page, and continued use of the Services after any updates constitutes your acceptance of the updated Policy.

### **Scope and Applicability**

This Policy applies to information we collect when you visit our website or use the Services. We will only collect and process information where we have lawful bases, such as your consent, the performance of a contract, or our legitimate interests.

Our Services may contain links to third-party websites or integrations with third-party applications. These external sites have their own privacy policies, and we are not responsible for their information practices.

### **What Information Do We Collect?**

1. **Information You Provide**

- **Account Information**: When creating an account, you may provide personal data such as your name, email address, password, and payment information.

- **Customer Content**: Any information you provide when using the Services (e.g., uploads, messages, call recordings).

- **Payment Information**: Payment details for subscriptions or purchases, such as credit card numbers, are handled by third-party processors (e.g., Stripe).

- **Communication Information**: When you contact us, we collect information about the communication, including your name and email.

- **Social Media Information**: Information from your interactions with us via social media platforms like Facebook or LinkedIn.

- **Other Information**: Information provided through webinars, surveys, or events.

2. **Information We Collect Automatically**

- **Log Data**: IP address, browser type, and the date and time of your interactions with our Services.

- **Usage Data**: How you use the Services, including content viewed and features used.

- **Device Information**: Information about your device, operating system, and browser.

- **Analytics**: Data collected via cookies and tracking technologies to analyze user behavior.

- **Call Recordings**: Calls made through the Services are recorded unless disabled by you.

3. **Information From Third Parties**

- **Third-Party Integrations**: Data provided by external platforms (e.g., Google login).

- **Marketing Information**: Demographic data received from partners or third parties.

- **Service Providers**: Information from third-party service providers assisting in operating our business.

### **How We Use Your Information**

We may use your personal information for the following purposes:

- **Account Management**: To create and manage your account and ensure your access to the Services.

- **Service Delivery**: To deliver, personalize, and improve the Services.

- **Communication**: To contact you regarding updates, offers, and other relevant information.

- **Marketing**: To send you promotional messages about our products or services, which you may opt out of.

- **Payment and Billing**: To process payments and manage subscription services.

- **Security and Fraud Prevention**: To maintain the security of our Services and protect against unauthorized activities.

- **Legal Compliance**: To comply with applicable laws and respond to legal requests.

**Insider Trading Clause**: Fairfax Partners strictly prohibits the use of non-public material information for trading purposes. All users of our Services agree not to use any confidential information accessed through Fairfax Partners for the purchase or sale of securities or other financial instruments.

### **How We Share Your Information**

We may share your personal information in the following scenarios:

- **With Service Providers**: We work with third-party service providers to help deliver our Services (e.g., payment processors, data hosting).

- **For Business Transfers**: Personal data may be disclosed in the event of a business transaction, such as a merger or acquisition.

- **For Legal Purposes**: We may disclose your personal data to comply with legal obligations, including responding to law enforcement requests.

- **With Your Consent**: We may share your information with third parties with your explicit consent.

We do not sell your personal data to third parties.

### **Cookies and Tracking Technologies**

We use cookies and similar tracking technologies to enhance your user experience, for analytical purposes, and to deliver targeted ads. You may modify your browser settings to disable cookies, though some features of the Services may not function correctly without them.

### **Data Retention**

We retain your personal data as long as necessary to fulfill the purposes outlined in this Policy, including for legal, accounting, or regulatory compliance. If you close your account, we will retain certain data in anonymized or aggregated form for analytical purposes.

### **Security of Your Information**

We implement reasonable security measures to protect your personal data from unauthorized access, alteration, and misuse. However, no security system is entirely foolproof, and we cannot guarantee absolute security. You are responsible for safeguarding your account information, such as passwords.

### **Your Rights**

Depending on your jurisdiction, you may have the right to:

- Access the personal data we hold about you.

- Request the correction or deletion of your data.

- Object to the processing of your data.

- Withdraw consent for data processing (where applicable).

- Lodge a complaint with your local data protection authority.

You may exercise your rights by contacting us at **connect@fairfaxpartners.ca**.

### **Legal Basis for Processing**

We rely on the following legal bases for processing your data:

- **Performance of a Contract**: When we process data to provide Services you have requested.

- **Legitimate Interests**: For security, fraud prevention, and improving our Services.

- **Compliance with Legal Obligations**: To fulfill legal and regulatory requirements.

### **Transfer of Personal Data**

Your data may be processed and stored in countries outside of your own, including Canada and the United States. By using our Services, you consent to the transfer of your information to these countries, which may have different data protection laws.

### **Do Not Track Signals**

We do not respond to "Do Not Track" signals as our tracking technologies are designed to support the functioning of our Services, rather than for cross-site tracking or ad targeting.

### **Children Under 16**

Our Services are not intended for individuals under the age of 16, and we do not knowingly collect personal data from children. If you believe we have collected data from a minor, please contact us, and we will take appropriate action to delete the information.

### **Contact Us**

If you have any questions or concerns about this Privacy Policy or your personal data, please contact us at:

**Fairfax Partners Inc.**

Email: **connect@fairfaxpartners.ca**