Privacy Policy

Inovia Capital Inc. (“Inovia”, “us”, “we”, or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy (the “Policy”) describes our practices regarding the collection, use, disclosure, and protection of personal information and outlines the choices available to you with respect to that information.

This Policy applies to individuals who visit or interact with our website at www.inovia.vc and any other website operated by us or one of our funds where this Policy is posted or referenced (collectively, the “Websites”), or who otherwise contact us or interact with us, whether for informational purposes, to receive our communications, or to apply for a professional opportunity with us.

Definition of “Personal Information”

In this Policy, “personal information” means any information that can be used, either alone or in combination with other information, to identify an individual. This includes information such as your name, email address, or any other contact details. It may also include other types of more technical information, but only when this information can identify you as an individual, such as your IP address and details about how you use our Websites.

Personal Information We Collect

The personal information we collect about you depends on the nature of your interactions with us (e.g., if you are a visitor of the Websites, a newsletter subscriber, etc.). Below is a description of the personal information we may collect about you:

Communication information. When you communicate with a member of our team via email or telephone, sign up to receive our newsletters and other communications, or provide us with your information in any other way, we may collect your contact information (such as your name and email address), the contents of the messages you share with us, and any other information that you choose to provide.

Technical information. When you visit our Websites, we automatically collect information from your devices (computers, mobile phones, tablets, etc.), including information about how you interact with our Websites. This information includes your IP address, the domain used to access our Websites, browser version, operating system type and version, device settings, the pages you visit and the time spent on each page, the websites you came from to access our Websites, and the date and time of your visit. See the “Cookies and Similar Technologies” section below for more information on how we use cookies to collect your personal information.

Location information. Through standard tracking mechanisms, general location information (e.g., country and city) may be inferred from your IP address and stored in the analytics captured for our Websites.

Cookies and similar technologies. We collect information when you access our Websites where cookies and other technologies are present. This information includes the frequency and duration of your activities, the pages you visited, the sites you used before accessing our Websites and where you went next, and whether you engaged with specific content. See the “Cookies and Similar Technologies” section below for more information.

How We Use Your Personal Information

We may use your personal information to operate our business, manage our Websites, and mitigate commercial risks. More specifically, we may use your personal information for the following purposes:

• Providing and managing our Websites. We may use your personal information to provide, maintain, improve, and develop relevant features and content for our Websites;
• Research and innovation. We may use your personal information to conduct research and support innovation;
• Analytics. We may use your personal information to create analytics and reports regarding the use of and trends within our Websites, including showing trends regarding general preferences and information on user experiences. These analytics and reports may include aggregate or de-identified information;
• Communications. We may use your personal information to maintain our list of contacts and send you information regarding Inovia and funds managed by Inovia. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email or by contacting us using the contact information provided below; and
• Security and legal compliance. We may use your personal information to detect and defend against fraudulent, abusive, or unlawful activity, or as otherwise required or permitted by applicable law.

We may also modify or aggregate your personal information to generate anonymized data that cannot reasonably be associated with you, directly or indirectly. We may use such anonymized data to conduct research and analytics, identify usage trends, make improvements to the Websites, and develop new offerings.

We limit our collection and use of personal information to what is necessary to fulfill the purposes identified above. We will not use your personal information for purposes other than those for which it was collected, unless we obtain your consent or are otherwise authorized by law.

How We Share Your Personal Information

We do not sell or rent your personal information. We do not share your personal information with third parties without your consent, except as set forth below or as otherwise required or permitted by applicable law.

With Your Consent. We will share information with third parties when we have your prior consent to do so.

Service providers. We may share your personal information with third-party service providers who perform services on our behalf, such as websites hosting and maintenance, analytics, email communications, database management, and data storage. We protect personal information disclosed to service providers by contractual agreements requiring that those service providers adhere to confidentiality and security obligations and process personal information only for purposes authorized by us.

Legal and compliance purposes. We may disclose your personal information: (i) to any governmental authority as part of an investigation to determine our compliance with applicable laws, rules, and regulations; (ii) in response to a court order, subpoena, or other lawful judicial or administrative proceedings; (iii) to protect the rights, property, or personal safety of Inovia, its users, or the public; or (iv) as otherwise required or permitted by law.

Business transactions. We may share your personal information with relevant third parties in connection with a business transaction to facilitate or enable any corporate or commercial transaction involving Inovia, to the extent permitted by applicable law.

We may also share anonymized information, which can no longer be used to identify you, directly or indirectly, with third parties, such as analytics providers, to generate analytics and reports, identify usage trends, and improve our Websites.

How We Protect Your Personal Information

We maintain physical, technical, and administrative safeguards that are appropriate to the sensitivity of the personal information we hold. These safeguards are designed to protect your personal information from loss and unauthorized access, collection, use, disclosure, or modification. We implement the following measures to protect your personal information, including:

• Internal policies and procedures that define the roles and responsibilities of our employees, representatives, and service providers throughout the life cycle of personal information and limit their access to that information on a “need-to-know” basis;
• Physical, electronic, and procedural safeguards that comply with relevant standards to protect personal information;
• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, endpoint detection and response, and similar measures;
• A designated Privacy Officer to monitor our compliance with applicable privacy laws;
• Procedures for receiving, investigating, and responding to complaints or inquiries about our information handling practices; and
• Contractual protections to ensure that service providers with whom we share personal information maintain adequate protections and security standards.

Retention of Personal Information

We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as needed to comply with our legal and regulatory obligations. When personal information is no longer necessary for these purposes, we will securely destroy or anonymize it in accordance with our internal policies.

Cookies and Similar Technologies

We use cookies, web beacons (including pixels and tags), and similar technologies on our Websites that collect certain information about you by automated means. We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner includes IP address, device identifiers, device type, device characteristics (such as operating system), the pages you visited on our Websites, the date and time of your visit, the referring URLs you came from, and other information about your online activities.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device. Note, however, that without cookies, you may not be able to use all of the features of our Websites.

Cross-Border Transfers

We may transfer your personal information to our service providers who may process it outside of Quebec or Canada, including in the United States. When your personal information is used or stored in a jurisdiction other than where you reside, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

Your Privacy Rights

Depending on where you reside, you may have the following rights with respect to your personal information:

• Right to information. You have the right to ask us about our processing of your personal information, including about the categories of persons who have access to your personal information within our organization and the applicable retention period.
• Right to access. You have the right to access the personal information we hold about you. Depending on the laws applicable in the province or territory in which you reside, you also have the right to ask us to communicate to you the personal information you have provided us in a structured, commonly used technological format, as well as to a third party upon your request.
• Rectification/correction. You have the right to request that any incomplete, outdated, or inaccurate personal information that we process about you is amended.
• Withdrawing consent. If we rely on your consent to process your personal information, you have the right to withdraw consent at any time, to the extent permitted by law and our contractual obligations. However, you understand that in such a case, you may no longer be able to benefit from our services.
• Automated decision-making. Where we render a decision based exclusively on automated processing of your personal information, you may have the right to obtain details related to the processing of your personal information to render the decision, including to obtain the reasons and the principal factors and parameters that led to the decision.
• Right to de-indexing. If you are a resident of Quebec, you may have the right to request that any hyperlink attached to your name that provides access to information be de-indexed, where the dissemination of such information contravenes the law or a court order.

To exercise any of your privacy rights, please contact us using the information provided in the “Contact Us” section below.

Changes To This Privacy Policy

This Policy may be amended from time to time. We recommend that you periodically review this Policy as it may be updated or revised. If we make material changes to this Policy, we will take reasonable steps to notify you of those changes, including by posting the revised Policy on our Websites with adequate notice.

Contact Us

If you have any questions regarding this Policy or our processing of your personal information, or if you wish to exercise any of your privacy rights, please contact our Privacy Officer at: