Deshret Capital Privacy Policy

Deshret Capital Corp. and its affiliates ("Deshret Capital" or "we") is a consulting firm that provides risk management advice to various entities. Deshret Capital is committed to respecting your privacy and the confidentiality of your Personal Information and has developed this privacy policy to comply with Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA") as well as other privacy regulations that set out rules for the collection, use and disclosure of Personal Information in the course of commercial activity such as the European Union’s General Data Protection Regulation (GDPR). This Privacy Policy is a statement of principles and guidelines concerning the protection of Personal Information of our clients, service providers, employees, and other individuals ("you").

By providing your information to us, you have consented to the uses and disclosures and other terms and conditions outlined in this Privacy Policy. You may withdraw your consent at any time by contacting our Chief Privacy Officer whose contact information is outlined below however that may limit our ability to service you.

Definitions:

"Personal Information" means any information about an identifiable individual. It includes, without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment health history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions as well as certain personal opinions or views of an individual.

"Third Party" means a person or company that provides services to Deshret Capital in support of the services offered by Deshret Capital, such as other consultants, brokers, insurance companies, and persons with whom Deshret Capital’s clients do business.

Accountability:

Deshret Capital has created this Privacy Policy and designated a privacy officer in compliance with PIPEDA.

Purposes of collecting Personal Information:

Deshret Capital collects Personal Information that is required or incidental to providing consulting advice and professional services or enabling research and development, as well as establishing, managing or terminating an employment, contractual or partnership relationship.

More specifically, the reasons for Deshret Capital’s collection, use and disclosure of your Personal Information include, but may not be limited to, the following purposes:

* Establishing and managing client relationships, providing consulting advice, performing professional services, fulfilling advisory duties, and avoiding conflicts of interest;

* Developing, managing, and marketing Deshret Capital’s internal systems, databases, overall business and operations, products, and services;

* Sharing Personal Information to and from third parties for the purpose of providing consulting services;

* Evaluating a commercial relationship with clients, suppliers and other third parties, including the evaluation of credit standing and use of information provided by credit reporting agencies;

* Establishing and maintaining commercial relationships with clients, suppliers and other third parties, including the issuance of invoices, the administration of accounts and related payments;

* Establishing, managing and terminating employment, contractual and partnership relationships;

* Responding to client, supplier, and other third party needs and preferences, including to means of communication and evaluations;

* Marketing or providing products and services of third parties with whom Deshret Capital has a commercial relationship;

* Distributing newsletters and other e-mail communications, conference or meeting information and other material to individuals on our contact, mail and e-mail lists, including via third party systems, mailing houses and e-mail service providers;

* Protecting Deshret Capital and others against error, negligence, breach of contract, fraud or other illegal activity, and complying with policies and contractual obligations;

* Engaging in transactions that include the purchase, sale, lease, merger, or any other type of investment, financing, or strategic initiative involving Deshret Capital;

* Complying with any legal or regulatory requirements; and

* For any other purpose to which you consent.

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Your Consent:

By submitting Personal Information to Deshret Capital or its service providers and agents, you consent to our collection, use and disclosure of such Personal Information as set out in this Privacy Policy and as required by law. You may withdraw your consent to certain or all of the identified uses of your Personal Information at any time by contacting the Deshret Capital Chief Privacy Officer, which may be subject to legal and contractual requirements. If you withdraw your consent, we may not be able to provide you with any of our services which may be of value to you. If you provide Deshret Capital or our service providers and agents with Personal Information of another individual, you consent to have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy. Such Personal Information may also be collected through publicly available sources.

Types of Personal Information collected:

The types of Personal Information that Deshret Capital may collect about you include, but may not be limited to, your name, home address, telephone number, personal e-mail address, billing and account information, information about a client's legal or business issue and other information as prompted by the request for proposal and contact forms on our website, and as requested in the course of providing professional services (including but not limited to Personal Information about directors, officers, employees, professional advisors, business partners, investors, shareholders, competitors and customers whom are individuals, employees, contractors, partners, and others).

Use, Disclosure, Retention of Personal Information:

Deshret Capital may disclose your Personal Information to employees, affiliated companies, agents, partners, third parties, insurance companies, insurance brokers, regulators, lawyers, witnesses, advisors, decision-makers, experts, government authorities, and others deemed important to the process of disclosing your Personal Information. Such disclosure is subject to confidentiality requirements. Deshret Capital will only use or disclose your Personal Information where necessary to fulfill the purposes identified above or as required by law. Deshret Capital will retain your Personal Information as permitted or required by law to fulfill the identified purposes or other legal or business purposes. In the event your Personal Information is no longer required, Deshret Capital will ensure the elimination of such Personal Information from any of its physical and online storage facilities.

Accuracy of your Personal Information:  

Deshret Capital keeps your Personal Information in active files that are up-to-date; You may request correction to your Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing to the Chief Privacy Officer, whose contact information is outlined below, while providing sufficient detail to identify the Personal Information and the correction being sought.

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Safeguarding your Personal Information:

Your Personal Information is stored on third party servers for which Deshret Capital is subscribed to or physical storage facilities or systems owned or leased by Deshret Capital. To help protect the confidentiality of your Personal Information, Deshret Capital employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. Your personal information may be shared, stored or accessed in Canada, the United States, the United Kingdom, the European Economic Area and other jurisdictions or countries. Your information may be disclosed in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.

At a minimum, the following security measures will be followed to ensure that your Personal Information is appropriately protected:

* Keeping files in secured electronic format only;

* Having at least one source of physical backup storage for all electronic files;

* Using appropriate security measures when destroying your Personal Information;

* Reviewing and updating our security policies and controls as technology changes to ensure ongoing security to your Personal information.

Please note that Deshret Capital has not reviewed, does not control, nor is it responsible for all of the privacy policies and procedures implemented by a party that is unrelated to Deshret Capital, including parties whose website links appear on Deshret Capital’s own website or to whom Deshret Capital distributes your Personal Information and as outlined above.

Openness:

Deshret Capital makes its privacy policies and procedures known to you via this Privacy Policy, which is available to you and the public only on Deshret Capital’s website. This Privacy Policy is made known to Deshret Capital’s affiliates, employees, and partners for whom related training is provided.

Accessing and reviewing your Personal Information:

You have the right to access Personal Information held by Deshret Capital and to challenge its accuracy if need be. Upon your written request, subject to certain exceptions, Deshret Capital will inform you of the existence, use and disclosure of your Personal Information and will give you access to that information. You may request access to your Personal Information, direct any complaints or questions regarding this Privacy Policy or Deshret Capital’s compliance with PIPEDA, by contacting Deshret Capital’s Chief Privacy Officer as described below.

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Cookies used on our Website:

When a visitor accesses the Deshret Capital website, we may use a browser feature called a ‘cookie' to collect information such as the type of internet browser and operating system used by the visitor, the domain name of the website from which the visitor came, the date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated.

A cookie is a small text file containing a unique identification number that identifies the visitor's browser to our computers each time our website is visited. In addition to the purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website. For more information please refer to our Cookie Policy.

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Our Chief Privacy Officer:

Deshret Capital has appointed Fred Barnachawy in our Toronto office as Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on Deshret Capital's privacy practices, please contact Mr. Barnachawy at 110 Cumberland Street, Toronto, Ontario M5R 3V5. You can also reach Mr. Barnachawy by contacting us here and providing a description of your query. The Chief Privacy Officer should act promptly to investigate any complaint and provide a written report of the investigation's findings to you.

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Other information:  

Deshret Capital may amend this policy from time to time at its discretion and as permitted or required by law. Any changes in the Privacy Policy will apply to Personal Information collected from the date the revised Privacy Policy appears on Deshret Capital 's website.

Compliance with GDPR:

If you are based within the European Economic Area (EEA), please note that where necessary to deliver our services we will transfer your Personal Information to countries outside the EEA. Not all countries provide the same level of protection in relation to Personal Information as within the EEA. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to your Personal Information. This will include having a lawful basis for transferring Personal Information and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Information.

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How long do we keep your Personal Information for?

Regarding visitors to our website, we will retain relevant Personal Information for at least twelve (12) months from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world), or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.

Regarding Personal Information we have processed as part of providing our services to any client, we will retain relevant Personal Information for at least six (6) years from the date of our last interaction with that client and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.

If Personal Information is only useful for a short period such as for specific marketing campaigns being run by our Canadian offices, we may delete it.

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About your rights

You have the following rights in relation to the Personal Information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make:

* Your right of access

* Your right to rectification

* Your right to erasure

* Your right to restrict processing

* Your right to data portability

* Your right to object

* Your rights in relation to automated decision-making and profiling

* Your right to withdraw consent

* Your right to lodge a complaint with the supervisory authority

We encourage you to contact us here in case of any questions, comments, or concerns and providing a description of your query.

We also encourage you to visit the European Commission’s website as per the link provided below for more information on data protection laws within the European Union: https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en