Privacy Policy
July 10, 2025
1. Introduction
Startly Inc. (“Startly”, “we”, “our” or “us”) is committed to protecting the privacy and security of the personal information entrusted to us.
This Privacy Policy explains how we collect, use, disclose, retain and safeguard personal information obtained through our website located at www.startlycapital.com (the “Website”), our investor portal, our communications with you, and in connection with the exempt market dealer services we provide.
By using the Website or providing personal information to Startly, you acknowledge that your information will be handled in accordance with this Privacy Policy and applicable privacy laws.
This Privacy Policy should be read together with our Website Terms of Use and any client agreements or other documentation that may apply to your relationship with Startly.
2. About Startly
Startly Inc. is a registered exempt market dealer in the Canadian jurisdictions in which it is authorized to conduct business.
As part of our regulatory obligations, we collect and use personal information to establish client relationships, assess investor eligibility and suitability, comply with securities and anti-money laundering legislation, administer investments, and provide related services.
Questions regarding this Privacy Policy may be directed to Startly using the contact information provided at the end of this Policy.
3. Scope of this Privacy Policy
This Privacy Policy applies to personal information collected from:
* visitors to our Website;
* individuals who register for an account or use our Investor Portal;
* prospective and existing investors;
* representatives of issuers and investment funds;
* individuals who communicate with us by email, telephone or other means; and
* other individuals whose personal information we collect in connection with our business operations.
This Privacy Policy does not apply to information that has been anonymized so that it can no longer reasonably identify an individual.
Where another agreement or privacy notice governs specific services or transactions, that document will supplement this Privacy Policy to the extent applicable.
4. Personal Information We Collect
The personal information we collect depends on the nature of your relationship with Startly and the services you request.
Contact Information
We may collect information such as:
* name;
* residential and mailing address;
* telephone number;
* email address;
* date of birth; and
* citizenship or residency information.
Identity Verification Information
To comply with applicable securities and anti-money laundering legislation, we may collect information necessary to verify your identity, including:
* government-issued identification;
* passport information;
* driver’s licence information;
* identity verification records;
* photographs where required for verification purposes; and
* information required to verify beneficial ownership or control.
Employment and Business Information
Depending on the circumstances, we may collect:
* employer name;
* occupation;
* job title;
* business address;
* business contact information; and
* professional background relevant to investment suitability.
Financial and Investment Information
Where required for onboarding, suitability assessments or regulatory compliance, we may collect information relating to:
* income;
* net assets;
* financial resources;
* investment experience;
* investment objectives;
* risk tolerance;
* investment time horizon;
* liquidity requirements;
* source of funds; and
* source of wealth where required by law.
Accredited Investor and Eligibility Information
Where an investment is offered pursuant to a prospectus exemption, we may collect information necessary to determine your eligibility, including information supporting accredited investor status or another applicable exemption under Canadian securities laws.
Anti-Money Laundering and Regulatory Information
To comply with applicable legal and regulatory obligations, we may collect information relating to:
* politically exposed persons (PEPs);
* heads of international organizations (HIOs);
* sanctions screening;
* anti-money laundering reviews;
* terrorist financing screening;
* beneficial ownership; and
* other information required under applicable legislation or regulatory guidance.
Communications
We collect information contained in communications you send to us, including:
* emails;
* telephone conversations where recorded in accordance with applicable law;
* correspondence;
* inquiries submitted through the Website;
* completed forms; and
* documents uploaded through the Investor Portal.
Technical Information
When you visit the Website, we may automatically collect certain technical information, including:
* IP address;
* browser type;
* operating system;
* device identifiers;
* pages visited;
* referring websites;
* dates and times of access; and
* other information relating to your interaction with the Website.
5. How We Collect Personal Information
We collect personal information directly from you whenever possible.
For example, we may collect information when you:
* visit our Website;
* create an Investor Portal account;
* complete onboarding documentation;
* submit subscription documents;
* communicate with our representatives;
* request information regarding our services; or
* participate in an investment opportunity.
Where appropriate and permitted by law, we may also collect personal information from third parties, including:
* identity verification providers;
* issuers and investment fund managers;
* financial institutions;
* public records;
* credit reporting agencies where authorized;
* government authorities;
* regulatory databases; and
* other lawful sources.
We may combine information obtained from multiple sources where necessary to satisfy our legal and regulatory obligations or to administer our services.
6. How We Use Personal Information
We use personal information only for legitimate business purposes and in accordance with applicable law.
Depending on the circumstances, we may use personal information to:
* establish and administer client accounts;
* verify identity;
* determine investor eligibility under applicable securities laws;
* satisfy Know Your Client (KYC), Know Your Product (KYP) and suitability obligations;
* comply with anti-money laundering, anti-terrorist financing and sanctions requirements;
* evaluate prospective investment transactions;
* process subscriptions and investment transactions;
* communicate with investors, issuers and prospective clients;
* respond to inquiries and requests;
* administer the Investor Portal;
* maintain accurate business records;
* improve our Website and services;
* detect fraud, unauthorized activity and cybersecurity threats;
* comply with legal, regulatory and contractual obligations; and
* exercise or defend legal rights where necessary.
We will not use personal information for purposes that are materially different from those described in this Privacy Policy without obtaining any consent required by applicable law.
7. When We Share Personal Information
Startly does not sell personal information.
We may disclose personal information where necessary to provide our services, administer investments, comply with legal obligations, or operate our business.
Depending on the circumstances, we may disclose personal information to:
* issuers and investment fund managers in connection with prospective or completed investment transactions;
* custodians, trustees, transfer agents, fund administrators and other service providers involved in administering investments;
* financial institutions involved in processing payments or transactions;
* identity verification, anti-money laundering, sanctions screening and fraud prevention service providers;
* technology service providers that host or support our Website, Investor Portal or business systems;
* legal counsel, auditors, accountants and other professional advisers;
* securities regulatory authorities, self-regulatory organizations, law enforcement agencies or government authorities where required or permitted by law; and
* other parties where you have provided your consent or where disclosure is otherwise authorized or required by applicable law.
All third-party service providers are expected to protect personal information and use it only for the purposes for which it was disclosed.
8. Cross-Border Processing
Some of the service providers that assist Startly may process or store personal information outside Canada.
Where personal information is transferred to another jurisdiction, it may become subject to the laws of that jurisdiction and may be accessible to courts, law enforcement agencies or governmental authorities in accordance with applicable law.
Startly takes reasonable steps to ensure that service providers handling personal information maintain safeguards appropriate to the sensitivity of the information and comply with applicable contractual obligations.
9. Cookies and Website Technologies
The Website uses cookies and similar technologies to improve functionality, enhance user experience and better understand how visitors use the Website.
Cookies are small text files stored on your device when you visit a website.
We may use cookies to:
* remember user preferences;
* maintain secure sessions;
* improve Website performance;
* measure Website usage;
* identify technical issues; and
* help protect the security of the Website.
The Website may also use analytics services that collect aggregated information regarding Website traffic and usage patterns.
Most web browsers allow users to manage or disable cookies through browser settings. Disabling certain cookies may affect the functionality of portions of the Website.
10. Protecting Personal Information
Startly maintains administrative, technical and physical safeguards designed to protect personal information against unauthorized access, collection, use, disclosure, modification or destruction.
These safeguards may include:
* secure information systems;
* encryption where appropriate;
* access controls;
* authentication procedures;
* employee confidentiality obligations;
* cybersecurity monitoring;
* secure document storage; and
* policies governing the handling of personal information.
Although we use reasonable security measures, no method of electronic transmission or storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.
11. Retention of Personal Information
We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy or as otherwise required or permitted by law.
Certain records relating to our regulated dealer activities must be retained for periods prescribed by applicable securities legislation, anti-money laundering legislation and other legal or regulatory requirements.
When personal information is no longer required, it will be securely destroyed, deleted, anonymized or otherwise disposed of in accordance with our record retention practices and applicable law.
12. Your Privacy Rights
Subject to applicable law, you may have the right to:
* request access to personal information that we hold about you;
* request correction of inaccurate or incomplete personal information;
* withdraw your consent to the collection, use or disclosure of personal information where consent is the legal basis for processing, subject to legal or contractual restrictions; and
* inquire about our privacy practices.
Withdrawal of consent may affect our ability to provide certain services. In some circumstances, Startly may be legally required to continue collecting, using, retaining or disclosing personal information in order to comply with applicable securities legislation, anti-money laundering requirements or other legal obligations.
Requests relating to personal information should be directed to our Privacy Officer.
13. Third-Party Websites
The Website may contain links to websites operated by third parties.
This Privacy Policy applies only to personal information collected by Startly. We are not responsible for the privacy practices, security or content of third-party websites. We encourage you to review the privacy policies of those websites before providing personal information.
14. Children’s Privacy
The Website and our services are intended for individuals who have reached the age of majority in their jurisdiction of residence.
We do not knowingly collect personal information from individuals who have not reached the age of majority. If we become aware that such information has been collected inadvertently, we will take reasonable steps to delete it as appropriate.
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, legal obligations or privacy practices.
The revised Privacy Policy will be posted on the Website together with the updated effective date. Your continued use of the Website following the posting of changes constitutes your acknowledgement of the revised Privacy Policy.
16. Contact Us
Questions regarding this Privacy Policy or our privacy practices may be directed to:
Startly Inc.
5700-100 King Street West, Toronto, Ontario M5X 1C7
Email: info AT startlycapital.com
Telephone: 1-647-426-5125
If you believe that your personal information has been handled in a manner inconsistent with this Privacy Policy or applicable privacy legislation, you may contact us. We will investigate your inquiry and respond within a reasonable period in accordance with applicable law.