Information We Collect

The Company collects personal information in two principal ways: directly from users who provide it voluntarily through website forms and communications, and automatically through the technical systems that support the operation of the website. The categories of information collected in each case are described in the sections below. The Company collects only the information that is necessary for the purposes identified in this policy and does not seek to collect sensitive personal information except where explicitly required and disclosed.

How We Use Your Information

Personal information collected by the Company is used only for the purposes identified at the time of collection or for purposes that are consistent with those identified purposes and permitted under applicable law. The Company does not use personal information for automated decision-making that produces legal or similarly significant effects for the user. The following list identifies the principal purposes for which personal information is processed.

• • To receive, read, and respond to inquiries submitted through the website contact form, including providing considered replies specific to the poster evaluation or market question described by the user.
• • To route and prioritise inquiries appropriately based on the subject category and priority level selected, ensuring that time-sensitive acquisition or auction deadline matters are addressed without unnecessary delay.
• • To maintain a record of correspondence for the purpose of providing consistent and accurate follow-up responses where an inquiry involves multiple exchanges over an extended period.
• • To analyse aggregated, anonymised website usage data for the purpose of identifying areas of the website that may benefit from structural or content improvements, without identifying individual users.
• • To comply with applicable legal obligations, including responding to lawful requests from regulatory authorities and retaining records in accordance with Canadian tax and corporate record-keeping requirements.
• • To detect, investigate, and address technical issues, security incidents, or misuse of the website, using log data and technical identifiers collected automatically during user sessions.
• • To maintain and improve the security and performance of the website, including through the use of third-party service providers who process technical data on behalf of the Company under contractual data-processing obligations.

Disclosure of Personal Information

The Company does not sell, rent, or trade personal information to third parties for their own commercial purposes. Personal information may be disclosed to third parties only in the limited circumstances described in this section. Each category of disclosure is subject to appropriate safeguards, including contractual obligations where third-party service providers are involved. The Company remains responsible for personal information disclosed to third parties acting on its behalf and takes reasonable steps to ensure that such parties handle information in a manner consistent with this policy.

Retention of Personal Information

The Company retains personal information only for as long as is necessary to fulfil the purposes for which it was collected or as required by applicable law. Retention periods vary depending on the category of information and the purpose for which it is held. The following section identifies the principal retention periods applied by the Company. At the end of the applicable retention period, personal information is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

• • Inquiry and correspondence records are retained for a period of up to three years from the date of the last communication, to support consistent follow-up and to maintain a record of the exchange.
• • Aggregated, anonymised analytics data derived from website usage is retained for up to thirteen months, in line with standard analytics platform data-retention practices, and is then deleted or further anonymised.
• • Email correspondence and contact form submissions are retained for the period necessary to respond fully to the inquiry and for a reasonable period thereafter in case of follow-up, not exceeding three years from the date of the final exchange.
• • Records required for compliance with Canadian tax and corporate record-keeping obligations are retained for the minimum period specified by the applicable legislation, which is generally six years from the end of the relevant fiscal year.
• • Where the user has consented to receiving communications from the Company, records of that consent and related communications are retained until consent is withdrawn, plus a reasonable period thereafter to demonstrate compliance.

Users may request early deletion of their personal information by contacting the Company using the details provided in the Contact section of this policy. Requests will be assessed against applicable legal retention obligations, and the Company will advise the user of any information that must be retained beyond the requested deletion date and the reasons for that requirement.

International Transfers of Personal Information

The Company is based in Canada and processes personal information primarily within Canada. However, some of the third-party service providers engaged by the Company to support website operations are located in other jurisdictions, including the United States and the European Union. Where personal information is transferred to a jurisdiction outside Canada, the Company takes steps to ensure that appropriate safeguards are in place to protect the information in a manner consistent with Canadian privacy law and, where applicable, the requirements of other relevant jurisdictions.

• • Contractual clauses that require recipient organisations in other jurisdictions to handle personal information in accordance with standards consistent with applicable Canadian privacy legislation and this policy.
• • Selection of service providers located in jurisdictions that have been assessed as providing an adequate level of personal data protection under applicable Canadian and international frameworks.
• • Where transfers involve the European Economic Area, the use of standard contractual clauses approved under the General Data Protection Regulation or equivalent mechanisms recognised by the relevant supervisory authority.
• • Periodic review of the safeguards applied to international transfers, including assessment of any changes in the legal environment of the recipient jurisdiction that may affect the adequacy of the protection provided.

Cookies and Tracking Technologies

The website uses cookies and similar tracking technologies to support its operation, analyse usage patterns, and, where applicable, deliver relevant content. A full description of the cookies used, the purposes they serve, and the controls available to users is provided in the Cookie Policy published separately on this website. Users who have not accepted non-essential cookies through the on-site consent tool will not have those cookies placed on their devices. Strictly necessary cookies, which are required for the basic operation of the website, are placed without consent in accordance with applicable law.

Users may withdraw consent to non-essential cookies at any time by accessing the cookie settings panel on this website or by adjusting browser-level cookie controls. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal and does not prevent access to the core content of the website.

Changes to This Policy

The Company reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or the Company's data-processing practices. Amendments will be published on this page with a revised effective date. Continued use of the website following publication of an amended policy constitutes acknowledgement of the changes made. Where changes are material, the Company will take reasonable steps to bring them to the attention of users, which may include a prominent notice on the website homepage for a reasonable period following the amendment.

• • A revised effective date will be displayed at the top of this page whenever the policy is updated, allowing users to identify when changes were most recently made.
• • Material changes to the purposes for which personal information is processed will be communicated through a prominent notice on the website, in addition to publication of the revised policy on this page.
• • Where changes affect the rights of users in a manner that requires fresh consent under applicable law, the Company will seek that consent before processing personal information for the new purpose.
• • Users who have submitted inquiries or correspondence are encouraged to review this policy periodically, as the retention and handling of their personal information is subject to the version of this policy in effect at the time of each interaction.

The most current version of this Privacy Policy is always available on this page. Users who wish to be informed of future changes are encouraged to review this page periodically rather than relying on direct notification, except in cases where applicable law requires the Company to provide direct notification of specific categories of change.