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Investors & Employees Privacy Notice

Privacy Notice (investors and employees)

Last updated: September 14, 2026

1. INTRODUCTION

Purpose of this privacy Notice

This privacy Notice (“Notice”) explains how we will Process the Personal Information (as defined below) of individuals who hold or have expressed an interest in securities issued by Aventus. This Notice also applies to the information you provide to us as an Employee. 

Aventus respects your privacy and is committed to protecting the Personal Information you provide to us. This Notice will let you know how we collect, Process and manage your Personal Information which we have received through your attendance at our offices or events, through your contact with us by post, phone, e-mail or otherwise and by you submitting application and registration forms/identification documentation, or, if you are an Employee, in the course of establishing, managing or terminating our employment relationship with you. 

Your interactions with our website are governed by our Website and Cookie Privacy Notice, which can be found at aventuscapital.com/privacy-statement.

It is important that you read this Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or Processing Personal Information about you, so that you are fully aware of how and why we are using your Personal Information. This Notice supplements the other privacy notices and fair processing notices and is not intended to override them.

Changes to this Notice and your duty to inform us of changes

This Notice may change from time to time and you should review it periodically. Your continued use of our website indicates your consent to our privacy practices as set out in this Notice.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

2. DEFINITIONS

The following definitions apply to this Notice:

“Aventus”, “we”, “us”, “our” means Aventus Capital Inc., the entity to which the website relates.

“Data Protection Legislation” means applicable laws and regulations to which Aventus is subject relating to privacy and the Processing of Personal Information. 

“Employee” means an individual employed by Aventus and includes an individual who performs a service for or in relation to or in connection with Aventus  as a partner or a director, officer or other office‑holder of Aventus or  as an apprentice, volunteer, participant or student, or under a contract or an agency relationship with Aventus.

“Personal Information” has the meaning given to it or any similar term (e.g., “Personal Information”, “nonpublic Personal Information”, “personally identifiable information”) in applicable Data Protection Legislation and for the avoidance of doubt includes any information which directly or indirectly identifies or otherwise relates to an individual, which is in the possession or under the control of Aventus. 

“Process” or “Processing” (and its cognates) means any operation that is carried out in respect of Personal Information, including but not limited to collecting, storing, using, disclosing, transferring or deleting Personal Information.

“Sensitive Personal Information” has the meaning ascribed to this or any similar term provided by applicable Data Protection Legislation (e.g., “sensitive Personal Information”, “sensitive data”, or “special categories of Personal Information”).

3. THE TYPES OF PERSONAL INFORMATION WE COLLECT

We will collect, use, store and transfer different kinds of Personal Information about you which we have grouped together follows: 

Identity Data, which includes first name, last name, title, date of birth and gender.

Contact Data, which includes address and postal code, email address and mobile and telephone numbers. Please note that business contact information used for contact purposes or, in the case of Employees, purposes related to your employment, is not considered Personal Information.

Transaction Data, which includes details about payments to and from you and other details of transactions and arrangements between you and us, including financial data and voting preference instructions.

Aggregated Data is also collected, used and shared, such as statistical or demographic data. This information may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. For example, we may anonymize and aggregate your Usage Data or Contact Data for general investor profiling purposes.

Profile Data, which includes details of any events that you may have attended and preferred language.

Usage Data, which includes information about how you use our products and services.

Marketing and Communications Data, which includes your preferences in receiving direct marketing material from us and certain third parties and your communication preferences.

Employment Data, if you are an Employee, includes the following types of Personal Information, which we need to establish, manage, or terminate our employment relationship with you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
  • Demographic information such as date of birth, gender, marital and dependent status.
  • Benefits information such as insurance enrollment information, beneficiary and emergency contact information. 
  • Government identification numbers such as social insurance or other national insurance number, driver's license number, or other identification card number.
  • Financial information, such as bank account details and payroll information, wage and benefit information, and compensation history.
  • Employment records such as start date, employment role and location, education and training (including professional memberships, references, work history, and proof of work eligibility) and information about your job performance. 
  • Employee ID and access information such as your photograph, access information (e.g., badge access) and system logs (e.g., when you log on to our IT systems and how you use them). 
  • Other personal details you may have included in a resume or cover letter.

We will only collect Sensitive Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data) if the law allows us to do so and it is necessary for us to conduct our business. For instance, if you are an Employee, we may need to collect information about your marital or family status in order to provide employment benefits. 

4. HOW WE COLLECT YOUR PERSONAL INFORMATION

We use different methods to collect Personal Information from and about you including through:

a) Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you: 

  • subscribe to our publications;
  • attend an event (for example Annual General Meetings); and
  • request marketing to be sent to you.

b) Third parties. We will also receive Personal Information about you from various third parties including: 

  • As part of our identity and financial crime checking procedures with credit reference agencies, fraud detection agencies and registration or stockbroking industry exchanges as well as public information sources. 
  • Market researchers.
  • From third parties when you have instructed or agreed for them to pass information to us, such as:
    • Your broker, agent, trustee or investment company and companies that introduce you to us; and 
    • Providers of technical, payment and delivery services.
  • If you are an Employee, we may collect information from any references you provide, education institutions, or prior employers. In some cases, and only where permitted or required by law, we may conduct a criminal background check. 

5. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your Personal Information when the law allows us to. We will never sell your Personal Information, and will never share it with third parties for marketing purposes without your consent.

We Process your Personal Information on the basis of consent (e.g., either when you expressly consent to us using your Personal Information, or when we can reasonably infer your consent from your actions, such as when you upload your resume or have had this Notice made available to you and elect to share Personal Information with us) and in accordance with Data Protection Laws. 

Your Personal Information will be collected, stored, disclosed and Processed by Aventus for the following purposes:

  • to maintain our investment records and enable trading on any relevant exchanges;
  • to undertake activities relating to your investments (for example paying dividends, and notifying you about Annual General Meetings); 
  • to communicate with you in the way that you prefer;
  • to understand your needs and interests and to respond to your enquiries;
  • to administer and maintain our IT systems storing Personal Information;
  • to comply with our contractual or legal obligations;
  • to conduct monitoring and analysis required to detect malicious data and understand how this may affect our IT systems; and
  • for purposes otherwise set out in this Notice or otherwise disclosed at the time of collection.

For Employees, we will only use your Personal Information for the purposes of establishing, managing, or terminating our employment relationship.

If we need to use your Personal Information for an unrelated purpose, we will obtain your consent.

Aventus uses your Personal Information on the basis of consent, but there are circumstances where we do not require your consent. These include where we Process your Personal Information to discharge legal or regulatory obligations, or in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings. In the case of Employment Data , the law allows us to Process your Personal Information without consent for the purposes of establishing, managing, or terminating our employment relationship with you.

6. SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES

Aventus uses third-party service providers to help us run our business.  For example, they help us develop products, make service enhancements, market our products and services, or help us comply with applicable law.

Our service providers may only access and use your Personal Information to provide the services under their agreements with us. In some cases, our agreements allow these service providers to use the data to improve their service (for example, to develop tools that prevent fraud or cyberattacks). We carefully assess our service providers’ security practices. We also require that they keep your Personal Information confidential and destroy it when no longer required.

Our service providers include those who support us with:

  • Technology, such as website hosting, data storage and analysis, security and software, and our internal systems.
  • Customer service, such as customer inquiries. 
  • Legal and financial compliance, such as accounting, legal claims, auditing, investigations or business transactions.
  • Business management, such as our professional advisors, insurers, consultants, or lawyers.

Aventus may share anonymous or aggregated data with third parties such as service providers in order to facilitate our business operations. We may Process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.

Aventus may also share or provide access to your Personal Information among its affiliates and business units.

In some cases, the law permits us to disclose your Personal Information to third parties without your consent:

a) Compliance with Law. To the extent required by law (for example, if Aventus is compelled by an obligation or a duty to disclose your Personal Information where we believe it is necessary or appropriate to comply with any legal obligations, rules, regulations or internal Aventus policies and procedures, including (without limitation) in order to comply with tax reporting requirements and other statutory reporting and disclosures to regulatory authorities), or to establish, exercise or defend its legal rights. This may include disclosure to regulatory bodies or government agencies, law enforcement or courts, and in order to investigate unauthorized attempts to access our IT systems, install harmful files or cause damage to Aventus;

b) Business Transactions. As part of a transaction, financing, or for other business needs (for example, if Aventus sells any of its businesses or assets, applies for a loan, or opens bank accounts, in which case Aventus may need to disclose your Personal Information to the prospective buyer, lender or bank, as the case may be, as part of certain due diligence processes);

c) Emergencies. We may disclose your Personal Information to law enforcement, government authorities or their agents in emergencies. This would arise if we think there is imminent danger to the life, health or security of an individual;

d) Financial abuse and protection. We may disclose your Personal Information if we think you might be a victim of fraud, financial abuse or other illegal activity. We may disclose it to law enforcement, government authorities or their agents, other financial institutions or organizations, a family member, or your legal representative; and

e) Court orders, regulatory demands and other legal compliance.  We will disclose your Personal Information to third parties where the law requires us to do so. For example, to comply with court orders or legal and regulatory obligations. We may also disclose your Personal Information to third parties where the law permits us to do so.

TRANSFERS OF PERSONAL INFORMATION OUTSIDE CANADA/US

Aventus operates globally. This means Personal Information may be Processed and disclosed as described above, in any country in which we conduct business or have a service provider. Accordingly, when you provide your Personal Information to Aventus, you acknowledge and agree that we may disclose your Personal Information to recipients (including, but not limited to service providers) located in jurisdictions other than your own (including but not limited to Canada, the UK, the USA, and the European Union). 

Aventus may transfer your Personal Information outside your jurisdiction provided it is in compliance with Data Protection Legislation, which may require us to use contractual or other measures to ensure it is treated with a level of security comparable to our own. 

HOW WE SAFEGUARD YOUR PERSONAL INFORMATION

Aventus has implemented commercially reasonable controls and appropriate technical and organizational measures to protect Personal Information, as well as to maintain the security of our information and information systems in respect of Personal Information. Personal Information is protected with safeguards according to the sensitivity of the information and appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to Personal Information is limited to authorized Employees.

As a condition of employment, Aventus Employees are required to follow applicable laws and regulations, including in relation to Data Protection Legislation. Unauthorized use or disclosure of confidential investor information by an Aventus Employee is prohibited and may result in disciplinary measures.

RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

The period for which Aventus will hold your Personal Information will vary and will be determined by the following criteria:

a) The purpose for which Aventus is using it. Aventus is required to retain Personal Information for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and

b) Legal Obligations. Laws or regulations may set a minimum period for which Aventus must retain your Personal Information.

Depending on the requirements of the Data Protection Legislation of your jurisdiction, Aventus will take reasonable steps using appropriate technical methods in the circumstances to delete or destroy your Personal Information when we no longer have a legal basis to retain it or to ensure that the Personal Information is anonymized or irrecoverable.

YOUR RIGHTS

To the extent provided by the law of your jurisdiction, you may have legal rights in relation to the Personal Information about you that Aventus holds. These rights may include:

a) the right to refuse to provide any Personal Information and the right to object at any time to the Processing of your Personal Information. Please note that such refusal or objection may prevent us from providing products or services to you;

b) the right to confirm whether we Process your Personal Information and to obtain information regarding the Processing of your Personal Information and access to the Personal Information about you that Aventus holds;

c) where consent was provided for certain Processing activities, the right to withdraw your consent to the collection, Processing, use and/or disclosure of your Personal Information at any time. Please note, however, that this will not affect the lawfulness of any collection, Processing, use or disclosure undertaken before your withdrawal and that Aventus may still be entitled to Process your Personal Information on the basis of a legal consent exception. In some cases, withdrawing your consent to the collection, use, Processing or disclosure of some or all of your Personal Information may prevent us from providing products or services to you;

d) in some circumstances, the right to receive a copy of some Personal Information in a structured, commonly used and machine-readable format and/or request that Aventus transmit that data to a third party where this is technically feasible. Please note that this right may, depending on the jurisdiction, only apply to Personal Information that you have provided to Aventus;

e) the right to request that Aventus correct or rectify your Personal Information if it is inaccurate or incomplete;

f) in some circumstances, the right to request that Aventus delete or erase your Personal Information. Please note that such a request may prevent us from providing products or services to you and there may be circumstances where Aventus is legally entitled to retain Personal Information regardless of any such request; and

g) where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by Aventus.

You can enquire about your rights, which are applicable to you, by contacting Aventus using the contact information below.

When you contact us about the above, you may be asked to provide evidence of your identity (e.g., driver’s license or passport) and/or to confirm some details relating to the Personal Information Aventus holds about you. These types of safeguards are designed to ensure that only you, or someone authorized by you, has access to your file.

CHILDREN

We do not knowingly solicit or collect Personal Information from children under the age of 18.

PROCESSING OF PERSONAL INFORMATION FOR MARKETING PURPOSES 

To the extent permitted by applicable law, we may contact you by mail, e-mail, telephone and other electronic means to provide information on products and services that we believe will be of interest, unless you object to receiving such information. If you do not want to receive such communications from us please contact our privacy officer at the details set out below or by using the opt-out facilities provided within the relevant marketing material.

Your option not to receive promotional and marketing material: (a) shall not preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (e.g., your account status and activity or our responses to questions or inquiries you pose to us); (b) shall not preclude us, including our Employees, , from accessing and viewing your Personal Information for our internal business purposes; and (c) shall not preclude us from disclosing your Personal Information as described in this Notice for purposes other than sending you promotional and marketing materials.