PRIVACY POLICY

Effective Date: 23/07/206

1. Introduction

Toro Investments, Inc. (“Toro Investments,” “Tiinc,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, retain, and safeguard personal information when you:

  • Visit or interact with our website;
  • Submit a contact or inquiry form;
  • Contact us regarding an investment, acquisition, partnership, or other business opportunity;
  • Communicate with our representatives; or
  • Otherwise provide personal information to Toro Investments.

This Privacy Policy applies to Toro Investments’ Canadian operations and website. It does not automatically apply to websites or services operated independently by our subsidiaries, portfolio companies, business partners, or other third parties, which may maintain their own privacy policies.

2. About Toro Investments

Toro Investments, Inc. is a privately held holding company headquartered in Saint-Bruno-de-Montarville, Quebec, Canada.

Toro Investments manages a diversified portfolio of institutional-grade assets independently appraised at approximately CAD $26.7 million. The company pursues systematic acquisitions and value-add investment strategies supported by the performance of its subsidiaries and portfolio holdings.

3. Personal Information We Collect

“Personal information” means information that identifies an individual or that can reasonably be associated with an identifiable individual.

Depending on how you interact with us, we may collect the following categories of information.

3.1 Information You Provide Directly

When you submit a form, contact us, or communicate with our representatives, we may collect:

  • Your first and last name;
  • Email address;
  • Telephone number;
  • Company or organization name;
  • Job title or professional role;
  • Mailing or business address;
  • Your preferred method of communication;
  • The nature and content of your inquiry;
  • Information about a proposed investment, acquisition, financing, partnership, property, asset, or business opportunity;
  • Documents, presentations, proposals, or other files you voluntarily provide;
  • Records of correspondence and follow-up communications; and
  • Any other information you choose to provide.

Please do not submit unnecessary sensitive information, such as social insurance numbers, passwords, banking credentials, medical information, or government-issued identification, through a general website inquiry form.

If sensitive information is required for a legitimate transaction, Toro Investments will provide an appropriate and secure method for submitting it.

3.2 Investor and Business Inquiry Information

When you approach us regarding an investment or business opportunity, we may collect information concerning:

  • Your identity and contact information;
  • Your company, ownership structure, and representatives;
  • Your relationship to the proposed opportunity;
  • The nature, size, and structure of a potential transaction;
  • Business, financial, operational, or property-related information;
  • Professional qualifications and experience;
  • Information required to evaluate the opportunity; and
  • Information necessary for due diligence, compliance, conflict checks, or fraud prevention.

Submitting an inquiry does not create an advisory, fiduciary, investor, partnership, agency, or contractual relationship with Toro Investments.

3.3 Information Collected Automatically

When you visit our website, certain information may be collected automatically through cookies, server logs, analytics technologies, and similar tools, including:

  • Internet Protocol address;
  • Browser type and version;
  • Device type and operating system;
  • General or approximate geographic location;
  • Referring website or source;
  • Pages viewed and links selected;
  • Date and time of access;
  • Time spent on individual pages;
  • Website navigation and interaction data;
  • Cookie or device identifiers; and
  • Technical information used to diagnose errors, prevent misuse, and maintain website security.

We do not use website analytics information to make investment, credit, employment, or other significant decisions about individual website visitors.

4. How We Use Personal Information

Toro Investments may use personal information for the following purposes:

  • Responding to questions, requests, and inquiries;
  • Evaluating investment, acquisition, financing, partnership, and business opportunities;
  • Communicating with prospective investors, partners, vendors, advisers, and other business contacts;
  • Conducting preliminary assessments and due diligence;
  • Scheduling meetings and managing business relationships;
  • Verifying the identity and authority of persons communicating with us;
  • Maintaining records of inquiries and correspondence;
  • Operating, maintaining, securing, and improving our website;
  • Measuring website traffic and understanding how visitors interact with the website;
  • Detecting errors, fraudulent activity, cybersecurity threats, and misuse;
  • Complying with legal, regulatory, tax, accounting, insurance, and contractual obligations;
  • Establishing, exercising, or defending legal rights;
  • Completing a corporate transaction, reorganization, financing, acquisition, or sale; and
  • Carrying out other purposes disclosed when the information is collected or otherwise permitted by law.

We will not use personal information for a materially different purpose without obtaining additional consent where required.

5. Consent

By voluntarily providing personal information to Toro Investments, you consent to its collection, use, and disclosure for the purposes identified in this Privacy Policy and at the time of collection.

Consent may be express or implied, depending on the nature and sensitivity of the information and the circumstances in which it is collected.

You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice. Withdrawing consent may prevent Toro Investments from responding to an inquiry, evaluating an opportunity, maintaining a business relationship, or providing a requested service.

Where required, consent for optional analytics or other non-essential cookies will be requested separately through our website’s cookie preferences or consent mechanism.

6. Cookies and Website Analytics

Cookies are small data files stored on a visitor’s browser or device. We may use cookies and similar technologies to operate our website, maintain security, understand website performance, and improve the visitor experience.

6.1 Essential Cookies

Essential cookies support functions necessary for the website to operate properly and securely. These may include cookies used for:

  • Website security;
  • Fraud and abuse prevention;
  • Network management;
  • Form functionality;
  • Session management; and
  • Remembering privacy or cookie preferences.

Because these technologies are necessary for website operation, they may not be subject to optional consent where permitted by law.

6.2 Analytics Cookies

With your consent where required, we may use analytics tools such as GOOGLE ANALYTICS to understand:

  • How many visitors access the website;
  • Which pages are visited;
  • How visitors navigate the website;
  • Which devices and browsers are used;
  • How visitors arrive at the website; and
  • Whether technical errors or performance issues occur.

Analytics providers may use cookies or similar identifiers and may process information on our behalf.

You can manage non-essential cookies through the cookie preference tool available on our website. You may also configure your browser to block or delete cookies. Blocking certain cookies may affect website functionality.

7. Disclosure of Personal Information

Toro Investments does not sell or rent personal information.

We may disclose personal information in limited circumstances to:

  • Employees, officers, or authorized representatives who require the information for legitimate business purposes;
  • Website hosting, cloud storage, cybersecurity, analytics, communications, and information-technology service providers;
  • Lawyers, accountants, auditors, insurers, financial institutions, consultants, and other professional advisers;
  • Subsidiaries, affiliates, portfolio companies, or transaction participants where relevant to an inquiry or proposed opportunity;
  • Government, regulatory, tax, law-enforcement, or judicial authorities where required or permitted by law;
  • Parties involved in a proposed or completed financing, merger, acquisition, reorganization, asset sale, or similar corporate transaction; and
  • Other persons with your consent or at your direction.

Service providers are permitted to access personal information only to the extent reasonably necessary to perform services for Toro Investments and are expected to protect the information appropriately.

8. Processing Outside Quebec or Canada

Toro Investments operates in Canada. However, certain service providers, including website hosting, cloud, email, security, and analytics providers, may process or store personal information outside Quebec or outside Canada.

Information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to its courts, law-enforcement agencies, or government authorities.

Toro Investments assesses relevant privacy and security considerations before entrusting personal information to service providers outside Quebec, as required by applicable law.

You may contact our Privacy Officer to request additional information about our service providers and the jurisdictions in which personal information may be processed.

9. Retention of Personal Information

Toro Investments retains personal information only for as long as reasonably necessary to:

  • Fulfil the purposes for which it was collected;
  • Respond to and maintain records of inquiries;
  • Evaluate or document a business opportunity;
  • Maintain an ongoing business relationship;
  • Satisfy legal, regulatory, tax, insurance, accounting, or contractual requirements;
  • Resolve disputes; or
  • Establish, exercise, or defend legal rights.

Retention periods vary according to the nature and sensitivity of the information and the reason it was collected.

When personal information is no longer required, we will securely destroy, delete, or anonymize it, subject to applicable legal requirements and reasonable backup-system limitations.

10. Security Safeguards

Toro Investments uses reasonable administrative, technical, organizational, and physical safeguards appropriate to the sensitivity of the personal information under its control.

These safeguards may include:

  • Access controls and authentication measures;
  • Restrictions based on business need;
  • Secure hosting and network protections;
  • Encryption where appropriate;
  • Malware, threat, and intrusion protections;
  • Confidentiality obligations;
  • Service-provider due diligence;
  • Secure document disposal;
  • Employee awareness and internal privacy procedures; and
  • Incident-detection and response measures.

No electronic system, website, email service, or method of data transmission is completely secure. Accordingly, Toro Investments cannot guarantee absolute security.

11. Privacy Incidents

Toro Investments maintains procedures for responding to suspected losses, unauthorized access, disclosures, or other confidentiality incidents involving personal information.

Where an incident creates a risk of serious harm or otherwise meets the applicable legal reporting threshold, Toro Investments will notify affected individuals and the appropriate privacy authority as required by law.

12. Your Privacy Rights

Subject to applicable laws and certain exceptions, you may have the right to:

  • Request confirmation of whether Toro Investments holds personal information about you;
  • Request access to your personal information;
  • Request correction of inaccurate, incomplete, or outdated information;
  • Withdraw consent to certain uses or disclosures;
  • Request information about how your information has been used or disclosed;
  • Request information about the categories of persons who have access to your information;
  • Request information about applicable retention periods;
  • Request a copy of eligible computerized personal information in a structured and commonly used technological format;
  • Request deletion or destruction where applicable;
  • Request the cessation of dissemination or de-indexing of information where the legal requirements are satisfied; and
  • Submit a question or complaint regarding Toro Investments’ privacy practices.

We may ask you to provide sufficient information to verify your identity before processing a request. We will respond within the period required by applicable law.

Certain information may not be provided where disclosure is prohibited or restricted by law, would reveal another person’s personal information, would compromise confidential commercial information, or is protected by solicitor-client privilege or another legal privilege.

13. Children’s Privacy

Our website and services are intended for business and professional audiences and are not directed toward children under the age of 14.

We do not knowingly collect personal information from children under 14 without the consent required by applicable law. A parent or legal guardian who believes that a child has provided personal information to us may contact our Privacy Officer.

14. Third-Party Websites

Our website may contain links to websites operated by subsidiaries, portfolio companies, business partners, professional advisers, or other third parties.

Toro Investments is not responsible for the privacy, security, content, or data-handling practices of independently operated third-party websites. Visitors should review the privacy policy of each external website before providing personal information.

15. Changes to This Privacy Policy

Toro Investments may update this Privacy Policy periodically to reflect changes to:

  • Our business activities;
  • Our website or technologies;
  • Our service providers;
  • Our privacy practices; or
  • Applicable legal and regulatory requirements.

The revised Privacy Policy will be posted on our website with an updated “Last Updated” date. Where required, we will provide additional notice or obtain renewed consent before applying a material change.

16. Privacy Officer and Contact Information

The person with the highest authority within Toro Investments acts as the person responsible for the protection of personal information unless this responsibility has been delegated in writing.

Questions, concerns, complaints, consent withdrawals, and requests to access or correct personal information should be directed to:

Privacy Officer
Toro Investments, Inc.
Saint-Bruno-de-Montarville, Quebec, Canada
Email: toroinvestmentsinc@gmail.com
Telephone: +1 514-965-5410

Please include sufficient information to allow us to understand and respond to your request. Do not send sensitive identification documents through ordinary email unless specifically instructed to do so through a secure method.

If you are not satisfied with our response, you may have the right to contact the Commission d’accès à l’information du Québec or another applicable Canadian privacy authority.