Privacy Policy

Last Revision Date: July 31, 2026

Wealth Write-Up Inc. (or “The Company”) is committed to protecting and safeguarding the privacy of your personal and financial information.

This privacy policy applies to The Company. It describes our requirements and practices for protecting personal information collected when you use our services or www.wealthwriteup.com. This policy also governs all The Company's applications and the other websites we operate. Job applicants are encouraged to see the Job Applicant Privacy Policy for information regarding the handling of their personal information.

This policy covers the collection, use and disclosure of personal information by The Company and its partners, employees and consultants. It is intended to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and its regulations (“PIPEDA”), Canada's anti-spam legislation (“CASL”), as well as substantially similar provincial privacy laws and regulations of general application, including but not limited to the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta) and Law 25 respecting the protection of personal information in the private sector (Quebec). In addition to being subject to these laws, we abide by the confidentiality rules established by the professional orders and institutes of chartered accountants.

This privacy policy is current as of the “last revision date” noted at the top of this page.

Scope of this policy

We process personal information in two distinct capacities. This policy applies to information we collect, use and disclose for our own business purposes, such as information we collect concerning customers and their representatives, users of our services (including users authorized by our customers) prospective customers, website visitors, event registrants, and other individuals who interact with our sales, marketing and account teams or other personnel.

This policy does not apply to information The Company processes on behalf of its customers. Information that our customers and their authorized users submit to the Wealth Write-Up application, including any personal information (e.g., personal information contained within accounting, investment or financial records), constitutes “Customer Data.” We process Customer Data solely upon the instructions of our customers, in accordance with our Software as a Service Agreement and Data Processing Addendum. The collection, use and disclosure of Customer Data is subject to the privacy policies of the organizations that provide the Customer Data to us, and not this policy. Should your personal information appear within Customer Data, kindly direct any inquiries or requests to the organization that submitted it; we shall assist that organization in responding as required by our agreements and by applicable law.

This privacy policy addresses the following questions:

1. What is personal information?
2. What personal information do we collect?
3. How do we collect your personal information?
4. How do we use your personal information?
5. When and how do we get your consent, and how can you withdraw it?
6. How do we use automated tools and artificial intelligence?
7. Who do we provide your personal information to?
8. Where do we keep your personal information?
9. What do you need to know about third parties and third-party websites?
10. How do we keep your personal information confidential in our dealings with our affiliates and third parties?
11. How long can we use, disclose or keep your personal information?
12. How do we manage information about minors?
13. How do you access your personal information?
14. What happens if the personal information we have is inaccurate?
15. How quickly do we respond to your written requests for information?
16. How can you contact us?

What is personal information?

“Personal information” refers to any information that relates to an individual and directly or indirectly identifies that individual or otherwise relates to an identifiable individual.

This policy does not apply to personal information concerning the performance of an individual's duties within a company, such as the individual's name, title and position as well as the address, email address and telephone number of the individual's place of work, to make or facilitate contact in connection with the individual's employment, business or occupation.

Information that is aggregated and/or anonymized and cannot be associated with an identifiable individual is not considered personal information.

What personal information do we collect?

The types of personal information we collect depend on a variety of factors, such as the type of services or products you request or use, applicable legal and regulatory requirements and the means by which you communicate with us. Personal information collected may include:

• Contact information, such as your name, email address, phone number or account information
• Identity information, including government-issued identification, which enables us to establish and verify your identity, name, date of birth and occupation
• Financial information, which enables us to determine your eligibility for and ability to benefit from products or services
• Activities on The Company's websites, social media, or applications, such as pages and events viewed and your clickstream data, account logins, preferences and IP addresses if they can be used to identify you as an individual
• Geolocation information collected when you browse The Company's websites, social media, or use The Company's applications or monitoring services;
• Communications information, such as audio and video recordings of meetings, calls and video conferences with our representatives, transcripts of such communications, summaries, notes and analyses derived therefrom (including by means of automated or artificial intelligence tools), and related metadata such as participant names, dates, times and duration;
• Cybersecurity information, such as monitoring data, alerts and reports we receive from third parties in the course of providing our monitoring services;
• Any other information you provide

How do we collect your personal information?

We always collect personal information lawfully and legitimately. We collect this information directly from you, through online technologies, through third-party social networks or indirectly from third-party sources if we have received your consent or are permitted to do so by law.

Typically, such information is collected directly from you, through online technologies, or through third party social networks when you:

• Retain the services of The Company
• Use The Company's goods or services
• Use our websites, applications and social networks
• Speak with or participate in meetings, calls or video conferences with our representatives
• Subscribe to publications
• Log in to our sites or submit to publications
• Submit a request through one of our “Contact Us” email boxes
• Register for events (webcasts, seminars, conferences, publications or media alerts) through our websites or mailing lists or through the registration processes on some of our sites

Directly from you

We may collect personal information directly from you by mail, email or telephone, through The Company's websites or applications, or in any other direct manner, e.g., when you provide us with the information necessary for us to provide you with services or you request information from us. You may voluntarily provide us with unsolicited personal information, including through The Company's websites or third parties that provide services to The Company for data collection purposes.

Through online technologies

We may collect certain types of information electronically when you interact with our websites, applications, email, social media accounts or online ads, or through the use of our third-party technologies, which include cookies, log files, web beacons and analytic engines to retrieve data about the use of our websites and applications. This data is generally not identifiable and is therefore not considered personal information. You can refer to our Cookie Policy for more details.

We may also collect certain types of information about you through our monitoring services that you choose to subscribe to, such as alerts, reports and monitoring data. Please note that our monitoring services may use third party software components governed by the terms and privacy practices of those third parties. For more information, please see the section “What do you need to know about third parties and third-party websites?”.

Third-party social networks

We may collect your personal information if you interact with us through our social media pages and accounts (e.g., Facebook, Twitter, Instagram). For example, we collect personal information that our respective social media platforms allow us to collect from our subscribers. We may also collect any content you upload to our social media pages.

From third-party data providers

Where permitted by law, we may obtain business contact information concerning prospective customers and their representatives, such as name, title, organization and work contact details, from third-party data providers, and we may combine such information with information collected through our websites and analytics tools for the purpose of managing our sales and marketing activities.

How do we use your personal information?

We may use the personal information you submit to provide programs and services, manage our operations, carry out marketing activities or conduct research and analysis, or otherwise to the extent permitted or required by law:

To provide services

We use your personal information for the purpose of providing services to the extent permitted or required by law, which take the following forms:

• Identifying you
• Providing services (including services provided through The Company's websites or applications)
• Creating, administering and maintaining your accounts
• Responding to your requests for information about The Company's applications, services and events and to your questions

To manage our operations

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

• Roll out and manage our website, applications, social media, and IT systems
• Enable you to participate in events
• Inform you of changes to our services, conditions or policies and send you messages, notices or alerts
• Identify cyber threats, fraud and other crimes and protect ourselves and others from errors and fraud
• Keep the public and our users and employees safe
• Respond to requests, warrants and orders from courts and other agencies in accordance with our contractual, legal and regulatory obligations
• Ensure the continuity of our services

To manage our sales and business development activities

Upon notice to participants, we may record, transcribe, summarize and analyze meetings, calls and video conferences with our representatives in order to:

• Maintain accurate records and notes of our discussions with prospective and existing customers;
• Train, coach and evaluate our sales and account personnel and perform quality assurance; and
• Manage our sales pipeline and customer relationships, including by recording meeting summaries and follow-up items in our customer relationship management system

To carry out marketing activities

We use your personal information for our marketing activities, including to:

• Send you publications, invitations to events and invitations to our internal activities
• Gather your opinions and feedback through surveys
• Register you for our events

To conduct research and analysis

We may use your personal information to conduct research and data analysis based on the tracking and analysis of current or previously collected information for the following purposes:

• Improve and manage our services and activities or develop new ones
• Improve our sales, marketing and service processes
• Measure the effectiveness of our services, activities, events and marketing
• Understand how visitors interact with our website and make sure it works properly

Whenever possible, we use your information in aggregate and/or anonymized form. To better serve you, we may collect the information you provide in person, online, by phone or in writing.

We identify the purposes for which we use your personal information at the time we obtain it and your free and informed consent from you prior to each specific use. When you consent to our use of your personal information, your consent covers all processing activities performed for the same purpose. When your personal information is used for multiple purposes, The Company will seek your consent for each purpose.

When and how do we get your consent, and how can you withdraw it?

We generally obtain your consent before collecting your personal information and, in all cases, before it is used or disclosed for any purpose. You may give us your consent in writing or electronically. You may also consent to The Company's collection, use and disclosure of your personal information by providing it to us in a clearly intentional manner (e.g., by accessing our websites or applications, using our services, submitting an information request, participating in a survey or event, etc.). The Company may also rely on your implied consent to collect, use and disclose your personal information where implied consent is permitted by applicable legislation.

We will not, as a condition of providing our professional services or products, require you to consent to the collection, use, disclosure or protection of information that is not required to fulfill the specified and legitimate purposes for which the information is requested.

If you provide us with information about another individual, we will assume that you are authorized to do so and that you have obtained that individual's consent to it collection, use and disclosure for the purposes set out in this policy.

Individuals who do not wish to have their personal information collected, used or disclosed should refrain from providing it to The Company. If you have already consented to the collection, use or disclosure of your personal information, you may subsequently withdraw your consent at any time, subject to legal or regulatory requirements or contractual obligations, and with reasonable notice, by contacting the privacy officer using the contact information provided below (Section 16). Our privacy officer can also advise you of the implications of withdrawing your consent.

If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe instructions included in each commercial electronic message.

We use technologies such as cookies to track your interactions with our websites and improve your experience. You can remove or disable some of these technologies from your browser (please refer to your browser's instructions or help page for more information on how to block, delete and manage cookies on your computer or mobile device). You can manage your privacy preferences for certain third parties by using the features of their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may render some of our website features unusable.

How do we use automated tools and artificial intelligence?

We may use automated tools and artificial intelligence software (“AI tools”) to support our internal operations, deliver or improve our services and support our internal operations. In some cases, we use AI tools to process your personal information, to support the purposes described in this policy.

For example, we employ AI tools to transcribe and analyze recorded meetings and calls. These tools generate transcripts, summaries and conversational insights, such as topics discussed and follow-up items, which our personnel review and use for the purposes described in this policy.  

We do not employ AI tools to render decisions concerning individuals based exclusively upon automated processing.

Our service providers are contractually prohibited from using data that we provide for processing, including recordings or transcripts, to train their artificial intelligence models. For inquiries regarding our use of these tools, please contact our Privacy Officer using the contact information provided below (Section 16).

Who do we provide your personal information to?

We may disclose personal information that we collect or that you provide as described in this policy, including:

• With your express or implied consent, to individuals or entities outside of The Company in accordance with applicable laws.
• To The Company's subcontractors and service providers who need to know this information or require it in the course of their duties, including providers of meeting recording, transcription and conversation-analysis services; customer relationship management systems; website analytics, tag-management and advertising services; sales and marketing intelligence and data-enrichment providers; cloud hosting; and communications tools.
• With our affiliates, to the extent required for the purposes described in this privacy policy and to comply with applicable laws, regulations, and requirements.
• As part of a transaction, subject to applicable legal requirements. We may decide to outsource all or part of our operations to a third party, merge with another entity or carry out any other form of legal transaction. If your personal information is required for such transactions, we will comply with legal requirements for the disclosure of personal information and ensure that your personal information is treated in accordance with applicable privacy legislation.
• To the extent permitted or required by law. Applicable laws may permit or require the use, communication or disclosure of personal information without consent in specific circumstances. This may include but is not limited to transferring, communicating (both orally and in writing), sending or making available or accessible your personal information to another person or entity without your consent if we reasonably believe that disclosure is necessary to mitigate or prevent a threat to the life, health or safety of a person or for public safety, for a law enforcement agency to take certain measures (e.g., to prevent, detect, investigate, prosecute or punish criminal offences) or if we believe that such action is necessary to protect and/or defend our rights, property or personal safety as well as those of the public and our users and employees.
• in response to lawful requests by public authorities, regulators, law-enforcement agencies, or to comply with court orders or legal processes.

We do not sell your personal information.

You must inform us immediately if you become aware that your personal information has been provided to us by another person without your consent or if you have not obtained consent before providing us with another person's personal information, by contacting the privacy officer using the contact information provided below (Section 16).

Where do we keep your personal information?

Customer Data submitted to the Wealth Write-Up application is hosted on servers located in Canada. Other personal information that we collect for our own business purposes, including sales, marketing and communications information, may be stored and processed in Canada, the United States, or such other jurisdictions in which our service providers operate. Personal information that is “in the cloud” can be stored on multiple servers in multiple locations around the world.

Please be assured that The Company has taken steps to protect the personal information handled by its service providers. However, to the extent that personal information is transmitted outside of Canada, it is subject to the laws of the country in which it is held and may be disclosed to the government, courts or law enforcement or regulatory authorities of that country in accordance with the laws of that country.

What do you need to know about third parties and third-party websites?

Our sites, including www.wealthwriteup.ca, may sometimes contain links to external websites, including websites related to events, government entities, non-profit organizations and social networks. Those websites are not governed by this policy.

In addition, our monitoring services described in the section “How Do We Collect Your Personal Information?” may use third-party components, such as monitoring, threat detection and analysis software.

Where personal information is collected by such third parties, such information is subject to the privacy policies of the third parties in question. The Company encourages you to consult the privacy policies of these third parties.

How do we keep your personal information confidential, including in our dealings with our affiliates and third parties?

We have put in place physical, contractual and technological security measures to protect your personal information from loss, theft, unauthorized access, unauthorized disclosure, copying, misuse or alteration. Only The Company, partners, employees or subcontractors with a business need to know personal information or who require such information as part of their duties are granted access it. We also maintain policies and practices to protect your information that:

• Provide a framework for our handling of your personal information;
• Define roles and responsibilities within our organization for handling your information from the moment we gather it until it is destroyed; and
• Govern our internal process for dealing with complaints regarding the protection of personal information.

How long can we use, disclose or keep your personal information?

We may keep your personal information, correspondence or comments in a file that is specific to you. We will use, disclose or keep your personal information for as long as necessary to fulfill the purposes for which it was collected, or as permitted or required by law.

How do we manage information about minors?

The Company recognizes the importance of protecting the privacy of minors, particularly in an online environment such as our websites. The Company's websites are not designed or intended for children under the age of 14. Our policy is that we will never knowingly collect or maintain information provided by anyone under the age of 14. If we learn that we have unknowingly collected personal information about a minor without the consent of their parent or guardian, we will delete that information from our records.

How do you access your personal information?

Subject to certain exceptions, as permitted by law, you have the right to request access to and to correct the personal information that we hold about you.

If you submit a written request to us to review your personal information that we have collected, used or disclosed, we will present it to you to the extent required by law in a generally understandable form with an explanation of any abbreviations or codes used. To exercise your right of access, please contact our privacy officer using the contact information provided below (Section 16).

Before granting you access to personal information on file, used or disclosed, we may ask you to provide us with sufficient proof of identity for that specific purpose only.

To protect your privacy, we will verify your identity before processing any request to access, modify, or delete your personal information. This may involve requesting supporting documentation or using existing authentication methods.

Privacy rights requests submitted to The Company are tracked through a designated internal system, which automatically records submission dates, request types, response deadlines, and actions taken to ensure full traceability and compliance.

We reserve the right to deny access for any reason permitted under applicable law. If we deny access to or correction of personal information, we will provide you with written reasons for such denial within thirty (30) days of your request.

To the extent permitted by law, we also reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive request regarding your access to your personal information, and for any additional copies of the personal information you request. A cost estimate will be provided.

Wealth Write-Up Inc. maintains a documented process for receiving, authenticating, and responding to privacy-related requests from individuals regarding their personal information. This includes requests for access, correction, restriction, objection, data portability, and deletion.

When a request is received:

• The requester's identity is verified to protect against unauthorized disclosure of personal information.
• The scope and legitimacy of the request are reviewed to ensure it falls within applicable privacy rights under Canadian privacy laws (PIPEDA and substantially similar provincial laws).
• The Company fulfills or denies the request in writing within the legally required timeframe (typically within 30 days), unless an extension is permitted by law.

Individuals submitting requests will be notified if additional time is required or if a request cannot be fulfilled due to legal, regulatory, or contractual constraints.

All privacy-related requests and subsequent actions taken by The Company are logged and retained for accountability and compliance verification to demonstrate compliance with applicable privacy laws and internal controls. These logs are reviewed periodically by the Privacy Officer to ensure timely response, accuracy, and completeness.

The Company maintains an internal Data Subject Request Procedure that defines roles, responsibilities, verification methods, and response timelines to ensure compliance with legal and regulatory requirements.

What happens if the personal information we have is inaccurate?

The Company will ensure that your personal information is kept as accurate, complete and up to date as possible. We expect you to notify us in writing of any changes to your personal information.

You may challenge the accuracy of the personal information we have about you at any time. Subject to any exceptions permitted or required by applicable law, if you can demonstrate that your personal information in our records is inaccurate or incomplete, we will amend it accordingly and, if applicable, disclose it to third parties who also have access to your personal information.

To discuss the accuracy of your personal information, you may contact the privacy officer using the contact information provided below (Section 16).

Wealth Write-Up Inc. has implemented documented processes and procedures to receive, verify, log, and respond to individual requests regarding their privacy rights, including requests for access, correction, restriction, objection, data portability, and deletion of personal information.

All such requests are recorded in a designated privacy request tracking system for monitoring, audit, and compliance purposes. Before processing any access, correction, or deletion request, we take reasonable steps to authenticate the identity of the requester using available information or supporting documentation. This helps ensure that personal data is disclosed only to the individual to whom it belongs.

When a request is received:

• The requester's identity is verified to ensure proper authorization.
• The request details are logged, assigned a tracking number, and acknowledged within a reasonable timeframe.
• The Privacy Officer or delegate evaluates the request in accordance with applicable laws and company policy.
• A written response is provided within 30 days, unless an extension is permitted by law.

For additional details on how we manage data retention, disposal, and privacy requests, please refer to our Data Retention and Disposal Policy, Information Security Policy, and Privacy Rights Request Procedure.

Where applicable, we document the outcome of the request, including whether personal data was accessed, corrected, anonymized, or securely deleted.

When personal information is no longer required to fulfill the purposes for which it was collected, or upon your verified deletion request, Wealth Write-Up Inc. ensures its secure disposal in accordance with our Data Retention and Disposal Policy.

Secure disposal may include:

• Permanent deletion from active systems and backup environments,
• Cryptographic erasure or secure overwriting, and/or
• Physical destruction of paper records.

Once a deletion request has been verified and fulfilled, confirmation of the deletion is documented in our tracking records, along with the date and method of secure disposal.

Disposal actions are documented and subject to internal audit to confirm compliance with applicable privacy laws and professional standards.

The Company will not be liable for any loss resulting from inaccurate, false, imperfect or incomplete personal information provided by you or anyone acting on your behalf.

How quickly do we respond to your written requests for information?

We will respond to each of your written requests within thirty (30) days. If we cannot meet this deadline, we will notify you in writing.

How can you contact us?

The Company is responsible for the personal information under its control and has appointed a Privacy Officer to ensure The Company complies with this policy.

You may contact The Company Inc. to:

• View, update, correct or delete personal information we have about you
• Withdraw your consent
• Obtain information about your access rights
• Discuss privacy issues in general

You may contact the Privacy Officer in writing at:

Wealth Write-Up Inc.

610-1981 McGill College Avenue, 6th Floor

Montreal, Quebec H3A 2Y1

You can also reach the Privacy Officer by email at privacy@wealthwriteup.com