Privacy Policy

Effective Date: December 31, 2023

Your privacy is important to DNA ADVISORS INC (“DNA Capital”, “we”, “us”, “our)

This Privacy Policy (“Privacy Policy”) sets out our practices with respect to the collection, use, disclosure of the personal information of individuals (“you”, “your”) who interact with us, including when visiting or viewing our website at https://www.dnacapital.ca/ (our “Website”), making inquiries, or using any of our services (including our financial products or services). It also sets out the rights you may have with respect to your personal information.

Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your personal information. If you do not agree with our policies and practices, your choice is not to use our Website or our services, or otherwise interact with us. By accessing or using this Website or our services, or otherwise interacting with us, you indicate that you understand, accept, and consent to the practices described in this Privacy Policy.

This Privacy Policy may change from time to time (please see “Changes to This Privacy Policy”, below). Your continued use of this Website or our Services, or other interaction with us, after we make changes indicates that you accept and consent to those changes. Please check the Privacy Policy periodically for updates. Where required by applicable laws, if the changes we make are significant, we will provide a more prominent notice or obtain your consent to any new ways that we collect, use, and disclose your personal information.

1. What is “personal information”?

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. It can also include more technical information, where this information can be linked to you. Information that is aggregated and/or anonymized, or otherwise cannot be associated with an identifiable individual is not considered to be personal information.

2. What personal information we collect and why we collect it

We may collect the following information when you interact with us:
• Contact information, such as your name, email, postal addresses, and telephone number. For corporate users of our services, we may need to collect the company name, the signing officers’ names and other personal details;

• Identity verification information, which may include in addition to your contact information, date of birth, and forms of government-issued photographic identification.

• Financial and account information, such as bank account numbers and information related to your account with us. In some instances, we create personal information about you, such as records of your interactions with us and details of your accounts;

• Comments and inquiries, such as those you may post through comment or inquiry forms on our Website;

• Technical information, including your browser type and version, time zone setting, browser plug-in types and versions, operating system, or information about your internet connection, the equipment you use to access our Website, IP address and usage details;

• Geolocation information, such as may be collected when you use our Website; and

• Audiovisual information, including CCTV or other types of video camera technologies that we may have installed in our premises;

• Any other information you provide to us.

3. How we collect personal information from you

We collect personal information in a variety of ways, including:
• Directly from you, such as when you interact with us by mail, email, over the telephone, through completion of an online form on our Website, meeting with us in our offices, or in any other direct manner.

• Through technologies we use online, such as when you interact with our websites, marketing emails, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons or single pixel gifs or analytics engines. The technologies we use include:

o Cookies, which are small text files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For more information, a list of cookies we utilize, and methods you can use to enable or disable cookies, please see our Cookie Policy.

o Web analytics tools such as Google Analytics, which uses cookies to analyze your use of our Website, to create reports about visitor and user activities for us and to provide further services associated with the use of our Website.

Third parties involved in providing these technologies may use tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of our website to any other personal information they may have collected on you. We encourage you to review the privacy policies of third parties as well.

4. How we use personal information

We may use the personal information we collect to provide you with our services, to manage our business operations, to communicate offers and information we think might interest you, to conduct research, and as otherwise permitted or required by law. More specifically, we may use your personal information for the following purposes:

• Providing products and services. We use your personal information in order to provide our services, including such purposes as:
o Verifying your identity;
o Verifying your eligibility for services that we offer;
o processing your transactions;
o taking or verifying instructions from you;
o creating, administering, and maintaining your account; and
o fulfilling your requests and responding to your inquiries.

• Managing our operations. We use your personal information to manage our operations, including:

o deploying and managing our information technology applications and systems, including managing our Website;
o maintaining our services;
o notifying you of changes to our services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
o meeting our contractual and legal obligations;
o maintaining the security of the public, our users and our employees;
o processing employment applications; and
o protecting ourselves and third parties from errors and fraud.

• Marketing. We use your personal information to inform you about news, services, or offers that we believe may be of interest to you. We may do this by communicating with you in a variety of ways, such as by email, telephone, direct mail, text message or through social media.

If you no longer wish to receive electronic marketing messages, please let us know by following the unsubscribe directions provided in our electronic marketing messages.
• Research and analytics. We may use your personal information in order to conduct research and data analytics by tracking and analyzing current or previously collected information for the following purposes:

o improving or developing new services;
o managing and improving our operations;
o understanding our customers’ interests and priorities and tailoring our services;
o measuring the effectiveness of our marketing and promotional activities; and
o understanding how visitors interact with our Website and ensuring it functions properly.

When possible, we will use your information in an aggregated and/or anonymized format.

5. How we share personal information

In addition to specific situations discussed elsewhere in this Privacy Policy, we share or disclose information as provided below:
• Affiliates. DNA Capital and its corporate affiliates (e.g., parent company, subsidiaries, or other companies under common control) may share personal information with each other and use it for the purposes described in this Privacy Policy. This allows DNA Capital and each entity within the group to comply with applicable laws, regulations and requirements and ensures that your information is consistent and up-to-date.

• Service providers. We may share your information with service providers. Among other things, service providers may help us to manage our operations, provide us with information technology systems, administer our Website and provide technical support.

• Business transactions. If another company acquires, or plans to acquire, our company, business, or our assets, or if we undergo a reorganization or financing of parts of our business (including the proceedings of insolvency or bankruptcy), we may share information with other parties to the transaction, including at the negotiation stage.

• As permitted or required by law. Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances. These circumstances include situations where it is necessary to disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.

Other than as listed above, we may, with your implied or express consent, share or disclose your personal information with third parties, in accordance with applicable laws.

6. Cross-border transfers

Your personal information may in some cases be transferred to jurisdictions outside the jurisdiction in which we operate and in which you are located or reside, to service providers or our affiliates. As a result, your personal information may be subject to the laws of those other jurisdictions and may be available to foreign government authorities under lawful orders and laws applicable in such jurisdictions.

7. Third parties

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
If you post a comment to our Website, an anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/.

8. How we protect and retain personal information

We have adopted physical, technological and organizational processes and procedures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. We restrict access to your personal information to those of our personnel, service providers and third parties on a need to know basis. We maintain policies and practices as part of our Compliance Manual & Code of Conduct that set out key roles and responsibilities and provide a framework for our handling of your personal information throughout its lifecycle, including our policies relating to consent management, security safeguards, outsourcing personal information handling to service providers, retention periods, and handling complaints regarding DNA Capital’s management of personal information.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, after which we will destroy such information as promptly as reasonably possible. Under some circumstances we may anonymize your personal information as an alternative to destruction so that it can no longer be associated with you.

9. How we manage consent

When you use our services or otherwise interact with us, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. In some cases, your consent may be “implied”; that is, your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.
We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy.

You may be entitled under applicable law to withdraw your consent (except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us). However, this will not affect the legality of any processing we have carried out prior to such withdrawal. If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the services or information that you requested or that could be offered to you. If you wish to withdraw your consent, please contact our privacy officer in writing (please see the “Contact Us” section below).

10. What rights you have over your personal information

You are entitled to request access to, and, if necessary, correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (please see the “Contact Us” section below). It is your responsibility to provide accurate, correct and complete information.
Your right to access or correct your personal information is subject to applicable legal restrictions. Upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. We may take reasonable steps to verify your identity before granting access or making corrections.

11. Changes to This Privacy Policy

If we decide to change our Privacy Policy, we will post a new version of the Privacy Policy reflecting these changes on the Website. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to visit our Website, use our services or otherwise interact with us after the modified version of the Privacy Policy has been posted or you have been informed of such update, you agree to be bound by all such changes unless you advise us in writing, by phone or by e-mail that you wish to withdraw your consent in accordance with the procedures provided in this Privacy Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop visiting our Website, using our services or otherwise interacting with us. It is your obligation to regularly review this Privacy Policy to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated.

12. Contact Us

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the coordinates below:
If you have any questions, comments or complaints about our privacy practices, please contact us at: Daniel Labrecque, Chairman and CEO, DNA Capital, 1000 Sherbrooke Street West Suite 2500, Montreal, QC H3A 3G4 info@dnacapital.ca.

Effective Date: December 31, 2023 Introduction This policy, along with our privacy policy (“Privacy Policy”), details the use of cookies on the website www.dnacapital.ca (“Website”), owned and operated by DNA ADVISORS INC. (“DNA Capital”, “we”, “us” “our”). By using the Website, you signify your acceptance of and agreement to abide by this Cookie Policy and our Privacy Policy. This Cookie Policy answers the following questions: • What is a cookie? • What are cookies used for? • Your choices with cookies • Cookie features and functions 1. What is a cookie? Cookies are small text files sent by a website server and stored on the device that accessed the site, so that they can be accessed again later. They are saved in the directory of the web browser that was used to access the website (on the device’s hard disk or other local storage medium), and stored in RAM while the web browser is running. The information does not usually directly identify you, but it can give you a more personalized web experience. 2. What are cookies used for? Cookies are used to store various kinds of information that can be used to make a website functional, to learn more about a user’s interaction with the website’s content, to help improve a user’s experience when visiting the website, or to assist the website owner in its promotional efforts. On our Website, we use cookies for all of these functions. For example, some of our cookies remember your preferences so you don't have to repeat your choices when you visit our Website. In addition, to obtain visitor statistics, we use analytics tools (internal and external) that collect data such as pages accessed, time of day the site was visited, the type of browser used to access our Website, and the internet protocol address of the visiting device. Some of these tools use cookies to facilitate the collection of this information. Wherever possible, we collect and use this data in aggregate form so that it cannot be reasonably manipulated to identify any particular user included in the group. 3. Your choices with cookies 3.1 Managing cookies through our cookie settings You can control your cookie preferences with respect to our Website through our Cookie Choices page. 3.2 Managing cookies through your browser You can change your preferences for our Website and/or the websites of any third-party providers by modifying your browser settings. You can also delete cookies at any time. Please note that most browsers automatically accept cookies. Therefore, if you do not want cookies to be used, you may need to delete or block cookies yourself. If you reject the use of cookies, you can still visit our website, but some functions may not work properly. You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for other information on cookies in general. 4. Cookie characteristics and categories 4.1 Cookie duration • Session cookies (also known as "temporary cookies"): Session cookies are intended to remain in your browser only during your browsing session, i.e., until you close your browser. • Persistent cookies: Persistent cookies remain in your browser after the session (unless deleted). Some persistent cookies do not expire, but most will have lifespans measured in days, weeks or years. 4.2 Origin of cookies • First-party cookies: First-party cookies are cookies set by the dnacapital.ca domain that are typically used to identify preferences (for example, language preferences), to ensure basic site functionality (logging into your account, managing your cart) or to support our internally-managed analytics or marketing efforts. • Third-party cookies: Third-party cookies are set by other parties, although the originating domain may be either dnacapital.ca or a third party domain. These cookies may be required for external analytics tools or services, or to enable the display of certain advertisements outside the Website. 4.3 Categories of cookies • Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be disabled in our systems. They are usually only set in response to actions constituting a request for services, such as logging into your account, managing your cart or filling in forms. You can set your browser to block or alert you about these cookies, but if you block these cookies some parts of the site may not work as a result. • Functional cookies: Functional cookies allow the Web site to remember the choices you make (e.g. text size changes, personalized pages, other preferences). • Performance cookies: Performance cookies collect information about how you use the Website and your user experience, such as page visits and any error messages. They help us to know which pages are the most and least popular and see how visitors move around the site We use this information to analyze and improve the operation of the site for a better user experience. • Advertising or targeting cookies: Advertising or targeting cookies are used to improve advertising. Common applications include targeting ads based on information relevant to the user, as well as improving reporting on the performance of advertising campaigns and avoiding showing users ads they have already seen. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. The following table sets out the cookies we use on the site and briefly describes their functions. Name of Cookie Domain Control Expiration Description STRICTLY NECESSARY COOKIES FUNCTIONAL COOKIES PERFORMANCE COOKIES ADVERTISING / TARGETING COOKIES