Privacy Policy

1. Who We Are

CAPFLOW INC. is a Canadian business funding intermediary that assists businesses in exploring financing and revenue-based funding solutions through third-party funding providers.

CAPFLOW is not a bank. Funding decisions, eligibility requirements and contractual terms are determined by the applicable funding provider.

We handle personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), where applicable, and relevant provincial private-sector privacy legislation.

2. Information We Collect

Depending on your interaction with CAPFLOW, we may collect the following categories of information:

Business and Contact Information

• Business name and operating name
• Business address and contact details
• Owner, director and representative names
• Telephone numbers and email addresses
• Industry, business activity and time in business
• Business ownership and organizational details

Financial and Application Information

• Requested funding amount and intended use
• Business revenue and cash flow information
• Business bank statements and transaction history
• Existing financing and repayment obligations
• Financial statements and other supporting documents
• Credit-related information, where authorized

Identity and Verification Information

Where reasonably necessary, we or an authorized funding provider may request identification, beneficial ownership information or other documentation to verify identity, prevent fraud and satisfy applicable legal or underwriting requirements.

Website and Technical Information

We may collect information such as IP address, browser type, device information, pages visited, referral sources and interactions with our website, subject to applicable consent and privacy requirements.

3. How We Collect Information

We may obtain information:

• Directly from you through our website or application forms
• Through email, telephone or other communications
• From authorized business representatives
• Through secure document or banking-data services you choose to use
• From funding providers, verification services or other lawful sources, where permitted
• Through website analytics and advertising technologies, subject to applicable requirements

If you provide information about another individual, you must have appropriate authority to provide it.

4. How We Use Personal Information

CAPFLOW collects and uses personal information for purposes reasonably connected with providing its services, including:

• Receiving and reviewing funding inquiries
• Assessing potential eligibility and funding options
• Preparing and submitting applications to authorized funding providers
• Communicating about applications, offers and documentation
• Verifying identity, business details and financial information
• Detecting and preventing fraud or misuse
• Maintaining business records and resolving disputes
• Complying with applicable legal obligations
• Maintaining, securing and improving our website and services
• Sending promotional communications where legally permitted

We do not use personal information for materially different purposes without providing any notice or obtaining any consent required by law.

5. Consent and Your Choices

We obtain consent where required by applicable law. The form of consent depends on the nature, sensitivity and intended use of the information. Sensitive financial information may require express consent.

Submitting a funding inquiry authorizes CAPFLOW to process information for the purposes explained at the time of collection. Where required, separate authorization will be obtained for credit inquiries, financial account access, disclosure to funding providers or other activities requiring specific consent.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit our ability to process or continue an application.

Consent to receive marketing communications is separate from the information needed to respond to or process a funding inquiry.

6. When We Share Information

To provide business funding services, CAPFLOW may disclose relevant information to third parties, including:

• Funding providers and financing partners involved in evaluating an authorized application
• Identity, fraud prevention and verification providers
• Authorized bank-data connectivity and document-processing providers
• Technology, hosting, CRM and communications service providers acting on our behalf
• Professional advisers, auditors and legal representatives where necessary
• Regulators, courts or government authorities where required or permitted by law

We limit disclosures to information reasonably necessary for the relevant purpose and apply appropriate contractual or other safeguards when engaging service providers.

Funding providers receiving an application may process information under their own privacy policies and legal obligations. We encourage applicants to review those policies before entering into an agreement.

CAPFLOW does not sell personal information to unrelated third parties for their independent marketing purposes without the consent required by law.

7. Credit Checks and Financial Verification

Funding applications may require credit assessment, bank statement verification, identity verification or other financial due diligence.

Where a personal or business credit inquiry requires authorization, we or the relevant provider will obtain that authorization before the inquiry is conducted.

If you connect a bank account through an authorized financial-data service, the service may collect and transmit information according to its own terms, privacy policy and your authorization.

CAPFLOW does not guarantee approval or funding. Decisions may be made by independent funding providers using their own underwriting processes.

Where a decision is based exclusively on automated processing of personal information, applicable laws may provide additional rights to information, explanation or review.

8. Cookies, Analytics and Advertising

Our website may use cookies and similar technologies for website functionality, security, analytics and advertising.

These technologies may help us understand website usage, measure advertising performance and improve the experience of visitors.

Depending on the technologies enabled, advertising partners may receive information about website interactions or device identifiers. We do not intentionally transmit bank statements or application financial details to advertising platforms for advertising purposes.

Where consent is required for non-essential tracking, we will provide an appropriate choice before enabling those technologies. You may also manage cookies through your browser settings.

If we use technologies that identify, locate or profile individuals, we will provide any additional notices and activation choices required by law.

9. Information Storage and Security

We use administrative, technical and organizational safeguards appropriate to the sensitivity of information under our control. These may include access restrictions, secure transmission, authentication measures, staff procedures and service-provider safeguards.

No electronic system can guarantee absolute security. If a privacy incident occurs, we will assess, document and report or notify affected parties and regulators where required by applicable law.

Information may be processed or stored in Canada or other jurisdictions by authorized service providers. Where information is transferred outside Canada, we will comply with applicable assessment, notice and protection requirements.

10. Retention and Disposal

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, meet applicable legal obligations, maintain appropriate business records, or address disputes and legitimate compliance requirements.

Retention periods may vary according to the type of information and the nature of the business relationship.

When information is no longer required, we securely destroy or anonymize it, as appropriate and in accordance with applicable law.

11. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Withdraw consent where permitted
• Request information about how your data is used or disclosed
• Request deletion or cessation of certain uses where legally available
• Request portability of eligible computerized information where applicable
• Raise a concern or file a privacy complaint

We may need to verify your identity before responding. We will respond within the timelines required by applicable law and explain any legally permitted refusal.

12. Email, SMS and Marketing Communications

CAPFLOW may contact you regarding an application, requested information, funding-related documentation or other service communications.

Promotional emails or text messages are sent only where permitted under Canada’s Anti-Spam Legislation (CASL) and other applicable laws.

Where required, marketing messages identify the sender, provide the prescribed contact information and include a functioning unsubscribe method.

You may withdraw marketing consent at any time. We will process unsubscribe requests in accordance with applicable legal deadlines.

13. Third-Party Websites and Services

Our website may contain links to third-party websites, applications, funding providers or external services.

Those organizations may maintain independent privacy policies. CAPFLOW is not responsible for their independent privacy practices, although we remain responsible for our own handling of information and applicable service-provider obligations.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, information practices, technology or legal requirements.

The effective date displayed at the top of this page indicates when the policy was last updated. Where required by law, we will provide additional notice or obtain consent before implementing material changes.

15. Contact, Privacy Requests and Complaints

For questions, access or correction requests, withdrawal of consent, or complaints concerning personal information, contact CAPFLOW’s designated privacy officer.

If you are dissatisfied with our response, you may have the right to submit a complaint to the Office of the Privacy Commissioner of Canada, or another applicable provincial privacy regulator.