Privacy Policy

1. Scope of this Policy

This Privacy Policy applies to personal information that Tollstam Capital collects through our website at tollstamcapital.com (the "Website"), through electronic communications such as email, and in the course of providing advisory services to our clients. It applies to individuals located in Quebec, elsewhere in Canada, the United States, and, where applicable, other jurisdictions.

2. Person Responsible for Personal Information

As required by Quebec's Law 25, we have designated a person responsible for the protection of personal information within our organization. This person oversees the implementation of and compliance with this Privacy Policy.

You may contact our person in charge of personal information at:

Christopher Tollstam
Founder & CEO
Email: privacy@tollstamcapital.com
Telephone (Canada): +1 (514) 602-4503

3. Information We Collect

We may collect the following categories of personal information:

Information you provide to us

• Contact details: name, professional title, company, email address, telephone number, and any other information you submit through our contact form.
• Inquiry content: the subject and content of any message you send us, including details about your advisory needs.
• Client engagement information: in the context of a formal engagement, financial, corporate, transactional, or other information necessary to provide our services.

Information collected automatically

• Technical information: IP address, browser type, device type, operating system, language settings, referring URL, and pages visited.
• Usage information: time and date of visit, time spent on pages, and similar analytics data.

Information from third parties

• We may, in the context of a client engagement, receive information about you from third parties such as your employer, advisors, counterparties, public records, or commercial databases, in each case for the purposes of providing our services.

4. How We Use Your Information

We use personal information for the following purposes:

• To respond to inquiries and requests for information;
• To evaluate, negotiate, enter into, and perform advisory engagements;
• To communicate with you regarding our services;
• To comply with legal, regulatory, audit, and risk management obligations, including anti-money-laundering, sanctions, "know-your-client", and conflicts-of-interest requirements;
• To operate, maintain, and improve the Website and our services;
• To detect, prevent, and respond to fraud, security incidents, and unlawful activity; and
• For any other purpose disclosed at the time of collection or otherwise authorized by you.

We will not use your personal information for any new purpose that is incompatible with the purposes for which it was collected without first obtaining your consent, except where authorized or required by law.

5. Legal Basis & Consent

Where required by applicable law, we collect, use, and disclose personal information on the basis of your consent. By submitting information to us through our Website, by communicating with us electronically, or by entering into an engagement with us, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may affect our ability to provide you with services.

6. Sharing with Third Parties

We do not sell your personal information. We may share personal information with the following categories of recipients:

• Service providers who process information on our behalf (for example, hosting, email, document management, communications, and analytics providers), under contractual obligations of confidentiality and security;
• Professional advisors such as lawyers, accountants, auditors, and consultants;
• Counterparties and their representatives, but only as necessary and authorized in the context of a client engagement;
• Regulators, law enforcement, and other governmental authorities when required by law, court order, or to protect our rights, property, or safety, or that of others; and
• Successors in connection with a merger, acquisition, reorganization, or sale of assets affecting our business.

7. Cross-Border Transfers

Because Tollstam Capital operates in both Canada and the United States, and because some of our service providers operate outside of Quebec or Canada, your personal information may be transferred to, stored in, or processed in jurisdictions outside the province of Quebec, including in the United States. Personal information in those jurisdictions may be subject to local laws, including laws permitting governmental authorities to access such information.

Before transferring personal information outside of Quebec, we conduct a privacy impact assessment as required by Law 25, and we put in place reasonable contractual and organizational measures designed to ensure that the information receives a level of protection equivalent to that afforded under Quebec law. For more information about our transfer practices, please contact the person responsible for personal information listed above.

8. Retention of Personal Information

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected, including to provide our services, comply with legal, regulatory, accounting, and reporting obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we will destroy, anonymize, or de-identify it in a secure manner.

9. Your Rights

Subject to applicable law, you have the following rights with respect to your personal information:

• Right of access: you may request confirmation that we hold personal information about you and request a copy of such information;
• Right of rectification: you may request that we correct personal information about you that is inaccurate, incomplete, or out of date;
• Right to withdraw consent: you may withdraw your consent to our processing of your personal information, subject to legal and contractual restrictions;
• Right to cease dissemination or de-indexing: in certain circumstances under Quebec law, you may request that we cease disseminating personal information about you or that we de-index a hyperlink leading to such information;
• Right to portability: where applicable under Quebec law, you may request that computerized personal information collected from you be communicated to you or, with your authorization, to a third party in a structured, commonly used technological format; and
• Right to lodge a complaint: as further described in Section 15 below.

To exercise any of these rights, please contact us using the details in Section 15. We will respond within the timeframes required by applicable law. We may require reasonable verification of your identity before acting on any request.

10. Cookies and Similar Technologies

Our Website may use cookies and similar technologies to operate the Website, remember your preferences, and analyze usage. You may control or disable cookies through your browser settings; however, doing so may affect certain features of the Website. Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

11. Information Security

We implement reasonable physical, technical, and organizational measures designed to protect personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification. No method of transmission over the internet or method of electronic storage is, however, fully secure, and we cannot guarantee absolute security.

12. Children's Privacy

Our Website and services are directed to professional and institutional audiences and are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe that we have inadvertently collected personal information from a child, please contact us so we may take appropriate steps to delete such information.

13. Privacy Incidents

If we become aware of a confidentiality incident (such as unauthorized access, use, communication, or loss of personal information) that poses a risk of serious injury, we will, in accordance with applicable law, take reasonable measures to mitigate the consequences and prevent further incidents, and we will notify the affected individuals and the applicable supervisory authority as required.

14. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will post the updated policy on this page and update the "Last updated" date above. Material changes will be brought to your attention by reasonable means.

15. Contact & Complaints

If you have any questions, requests, or complaints about this Privacy Policy or our handling of your personal information, please contact our person responsible for personal information:

Christopher Tollstam
Founder & CEO, Tollstam Capital Group, Inc.
Email: privacy@tollstamcapital.com
Canada: +1 (514) 602-4503 · United States: +1 (786) 367-2276

If you are not satisfied with our response to your complaint, you may also file a complaint with the supervisory authority in your jurisdiction. In Quebec, this is the Commission d'accès à l'information du Québec (www.cai.gouv.qc.ca).