Privacy Policy

Disclaimer

Launch Crowdfunding Corp. (“Launch”) created this Privacy Policy to explain how we collect, use, and share your personal information. Please read this Privacy Policy carefully before using our website (“Site”) and services (“Services”). Launch is a start-up crowdfunding portal operating under National Instrument 45-110. This policy applies to all visitors, registered users, and investors who access or use our Site or Services.

What Is Personal Identifying Information (PII)?

Personal Identifying Information (“PII”) is any information that, alone or combined with other information, can be used to identify you as an individual. Examples of PII include your name, address, email address, phone number, date of birth, financial information, government-issued identification numbers, and investment history.

What Information Does Launch Collect?

We collect information you provide directly when you register for an account, complete your investor profile, make an investment, or communicate with us. This includes:

• Full legal name, date of birth, and contact information
• Mailing address and province of residence
• Financial institution details for securities delivery
• Investment transaction history through our platform
• Identity verification documents as required under NI 45-110
• Electronic signatures and acknowledgement records
• Communications you send to us or through our platform

We also collect certain information automatically when you use our Site, including your IP address, browser type, device identifiers, pages visited, and time of access. This information helps us secure the platform and satisfy regulatory record-keeping obligations.

Collection of Information by Third Parties

Launch uses third-party service providers to help operate our platform and process transactions. These include payment processors (Square), email service providers (Postmark), authentication providers (Google), and cloud infrastructure providers (Supabase, Vercel). Each provider has its own privacy policy governing their use of your data.

We do not sell your personal information to third parties. We share your information with third parties only as necessary to provide our Services, comply with legal obligations, or with your explicit consent.

How Launch Uses Your Information

We use your PII to:

• Verify your identity and eligibility to invest under NI 45-110 requirements
• Process investment transactions and issue share certificates
• Comply with regulatory reporting requirements to provincial securities commissions (BCSC, OSC, ASC)
• Maintain transaction records for the mandatory 8-year retention period
• Send transactional communications (investment confirmations, certificate delivery, cancellation notices)
• Detect and prevent fraud or unauthorized access
• Improve and maintain our platform and Services

How Launch Shares Your Information

We may share your personal information in the following circumstances:

• With issuers: Your name, contact information, and investment details are shared with the company whose securities you purchase, as required for security issuance and the shareholder register.
• With regulators: Provincial securities commissions (BCSC, OSC, ASC) may require us to provide investor and investment data as part of our regulatory obligations under NI 45-110.
• With service providers: Payment processors, email providers, and infrastructure providers receive the minimum information necessary to provide their services.
• Legal compliance: We may disclose information when required by law, court order, or to protect the rights and safety of our users or the public.

Security of Your Information

Launch implements commercially reasonable security measures to protect your PII, including encrypted data transmission (TLS), encrypted data storage, access controls, and audit logging of all significant actions on your account. However, no method of transmission over the internet or electronic storage is 100% secure.

Investment records are retained for a minimum of 8 years as required under NI 45-110. During this period, your information cannot be deleted from our system regardless of account closure or request.

Your Rights and Controls

Subject to the mandatory record-retention requirements of NI 45-110, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information in your investor profile
• Withdraw consent for marketing communications (transactional emails required by regulation cannot be opted out)
• Request information about how your data has been shared

To exercise these rights, contact us at shayne@lfgmanagement.ca. Note that investment records subject to the 8-year retention requirement under NI 45-110 cannot be deleted upon request.

Cookies

Our Site uses cookies and similar tracking technologies to maintain your session, remember your preferences (including disclaimer acceptance), and analyze site usage. Essential cookies required for platform operation cannot be disabled. You may configure your browser to reject non-essential cookies, though this may limit some functionality of the platform.

Changes to This Policy

Launch reserves the right to update this Privacy Policy at any time. We will notify registered users of material changes via email. Your continued use of the Site or Services after changes are posted constitutes acceptance of the revised policy. We encourage you to review this policy periodically.

If you have questions about this Privacy Policy or our data practices, please contact Launch Crowdfunding Corp. at shayne@lfgmanagement.ca.