We've Got Your Back
Updated August 7th, 2026
PRIVACY AND COOKIE POLICY
This Privacy and Cookie Policy (“Policy”) describes the personal information that Western Wealth Capital Management Ltd. and its affiliates (collectively, “WWC”, “we”, “our” or “us”) collect from or about you when you access or use our website, any secure investor portal operated by or on behalf of WWC, inquire about, invest in or hold investments sponsored, managed or administered by WWC or its affiliates, or otherwise use our products, services or investment opportunities (collectively, the “Services”). It also describes how we collect, use, disclose, retain, store, transfer and otherwise process that information, and to whom we may disclose it. “Personal Information” means information about an identifiable individual or any other information that constitutes personal information, personal data or similar information under applicable privacy or data protection legislation.
Please read this Policy carefully. If you do not agree with this Policy, you should not access or use our Website, any Portal or the Services, or provide Personal Information to us. This Policy should be read together with the Website Terms of Use and any agreement governing your use of a Portal or your investment with WWC that expressly incorporates or refers to this Policy. Where the Website uses a cookies banner or preference management tool, that banner or tool forms part of WWC’s approach to obtaining and managing Cookie preferences.
We may amend, supplement, replace or otherwise modify this Policy from time to time. The then-current version of this Policy will be posted on our Website together with the date on which it becomes effective. We may, but are not obligated to, provide notice of amendments through the Website, the Portal, by electronic mail or by any other means that we consider appropriate. Unless otherwise stated, amendments become effective when posted. Your continued access to or use of the Website, the Portal or the Services following the effective date of an amended Policy constitutes your acknowledgement of the amended Policy to the fullest extent permitted by applicable law. Nothing in this paragraph limits any rights that you may have under applicable privacy or data protection legislation.
Collection of Information
What Information is Collected and How?
Generally, we collect Personal Information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information), and only where we have a legal basis to do so. In most cases, we collect Personal Information directly from you when you interact with us in connection with our Website, any Portal, the Services, our properties, investments, investment opportunities or any other products or services that we offer. As a general rule, we collect Personal Information directly from you. However, in some cases, we may collect Personal Information from third parties including, without limitation, your financial adviser, exempt market dealer, registered dealer, registered plan custodian, financial institution, service providers or our affiliates. We will use reasonable means to satisfy ourselves that any third party providing us with Personal Information has the legal authority to do so. Personal Information will always be collected using means that are fair and lawful. We will not knowingly collect or use Personal Information without an appropriate legal basis, except where permitted or required by applicable law or regulatory requirements.
Information collected in connection with your use of the Website, any Portal or the Services may include your name, email address, residential and mailing address, telephone numbers and other contact information; date of birth; social insurance number; social security number; passport information and other government-issued identification; tax identification numbers; banking and financial information; real estate holdings; credit reports; employment and business information; investment experience, objectives and suitability information; information regarding investments, subscriptions, beneficial ownership and amounts invested by you from time to time; business relationship information, including information relating to your agreements, preferences, advisers, authorized representatives and decision-makers; communications with WWC; Portal account information; Portal authentication, login and document-access activity; IP addresses; browser, device and operating system information; Cookie identifiers; and any other Personal Information that you voluntarily provide through requests for information, subscription applications, the Website, the Portal or otherwise in connection with the Services.
Information Collected through Automated Means
Device Information: We may collect certain technical and usage information relating to your access to or use of the Website, any Portal or the Services, including the Internet Protocol (IP) address of your computer or device, your Internet service provider (ISP), browser type and version, operating system, device identifiers, language settings, referring webpages, pages visited, date and time of access, session duration and other technical information generated through your interaction with the Website or the Portal. We use this information for purposes including operating and administering the Website and the Portal, authentication, cybersecurity, fraud detection, troubleshooting, system administration, improving the Website and the Services, monitoring and analyzing usage, compiling statistics regarding Website and Portal activity, and complying with legal and regulatory requirements. Where reasonably possible, we use aggregated or de-identified information for analytical purposes.
Cookies: “Cookies” are small text files that are placed on your computer by websites that you visit. They are used to identify you to the web server, and will tell the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system. Session cookies expire when you close your browser. Persistent cookies remain on your device until they are deleted or expire.
We and our service providers may use Cookies and similar technologies to operate, administer, maintain, secure and improve the Website, any Portal and the Services, including to:
When you use our website a banner informs you of the use of cookies, seeks your express consent to their use, and provides a direct link to this information page. Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use the website or the Services, but your ability to access certain features and functions may be affected. To find out more about cookies, including how to see what cookies have been set and how to manage and remove them, please visit AboutCookies.org or All_About_Cookies.org.
WWC may engage third-party analytics providers, including Google Analytics or similar services, to assist us in understanding how the Website and the Portal are used, improving the Services and measuring the effectiveness of our communications. Such providers may use Cookies or similar technologies as described in this Policy.
HubSpot: WWC may use third-party communications and marketing service providers, including HubSpot or similar service providers, to distribute newsletters, updates, event invitations and other communications to individuals who have requested or consented to receive them, where required by applicable law. These service providers may process Personal Information on WWC’s behalf in accordance with their contractual obligations and applicable privacy laws.
Social Media and Third-Party Features: The Website or the Services may include links to, integrations with, or content made available through third-party social media platforms or other third-party services, including LinkedIn, Facebook or similar platforms. These features may collect technical information such as your IP address, browser information or information regarding your interaction with the applicable feature, and may use Cookies or similar technologies to function properly. Your interactions with any third-party social media platform or other third-party service are governed by the terms of use and privacy policy of the applicable third party, not by this Policy. WWC does not control and is not responsible for the privacy practices, content or security of any third-party social media platform or service.
Purpose – Why We Collect, Use and Disclose Information
We will identify the purposes for which we collect Personal Information before or at the time it is collected, or as otherwise permitted or required by applicable law. We collect, use, disclose, retain, store, transfer and otherwise process Personal Information only where reasonably necessary for the identified purposes, where permitted or required by applicable law, or where we otherwise have an appropriate legal basis to do so. Except as described in this Policy or as otherwise permitted or required by applicable law, we will not use or disclose Personal Information for a purpose that is materially different from the purpose for which it was collected without an appropriate legal basis or any consent required by applicable law. Personal Information may be processed for the following business purposes:
Where Personal Information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.
Legal Basis for the Use of Your Personal Information
We will only collect, use, disclose, retain, store, transfer or otherwise process Personal Information where we have an appropriate legal basis to do so under applicable law. Depending upon the circumstances, that legal basis may include one or more of the following:
Disclosure to Third Parties
WWC does not sell Personal Information. Except as described in this Policy or as otherwise permitted or required by applicable law, we will disclose Personal Information only where reasonably necessary for the purposes described in this Policy, to provide the Services, to administer investments or investment opportunities, to comply with legal or regulatory obligations, to protect our legal rights or legitimate business interests, or with your consent where required by applicable law.
In the course of providing the Website, the Portal, the Services and administering our investment opportunities, WWC may disclose Personal Information to third-party service providers performing services on our behalf. Such service providers may include, without limitation, website and Portal providers; cloud hosting providers; payment processors; financial institutions; registered plan custodians; fund administrators; property managers; credit reporting agencies; identity verification providers; document execution and document management providers; data storage providers; technology providers; communications providers; legal counsel; accountants; auditors; tax advisors; insurers; exempt market dealers; broker-dealers; consultants; and other professional advisors. We disclose only the Personal Information that is reasonably necessary for the applicable purpose and require service providers, where appropriate, to protect Personal Information through contractual confidentiality, privacy and security obligations appropriate to the nature of the services they provide. We may also disclose Personal Information where permitted or required by applicable law, including in response to legal process, regulatory requirements or governmental requests, or where reasonably necessary to establish, exercise or defend legal claims or protect the rights, property or safety of WWC, our investors or others.
Certain of our subsidiaries, affiliates, investment vehicles, service providers and other persons to whom we disclose Personal Information under this Policy may collect, access, use, store, transfer or otherwise process Personal Information outside Canada or the United States, including in jurisdictions in which WWC, its affiliates or those service providers operate or provide services. As a result, Personal Information may be subject to the laws of those jurisdictions, including lawful access by courts, regulatory authorities, law enforcement agencies or governmental authorities. Where required by applicable law, WWC will implement contractual, organizational or other safeguards that are reasonably appropriate for the transfer or processing of Personal Information across jurisdictions.
WWC may collect, use or disclose Personal Information without your knowledge or consent where permitted or required by applicable law in connection with a proposed, contemplated or completed business transaction, including an acquisition, disposition, merger, amalgamation, reorganization, financing, securitization, corporate restructuring, sale of assets or similar transaction. Where required by applicable law, WWC will take reasonable steps to ensure that Personal Information disclosed in connection with such a transaction remains protected and is used only for purposes relating to the transaction or as otherwise permitted or required by applicable law.
Safeguards – How Information is Protected
WWC has implemented reasonable physical, organizational, contractual and technological safeguards designed to protect Personal Information in its custody or under its control against loss, theft and unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. The nature of the safeguards depends upon the sensitivity of the Personal Information and the purposes for which it is collected, used, disclosed or otherwise processed. Such safeguards may include user authentication, passwords, encryption where appropriate, secure websites and communications, role-based access controls, secure electronic storage, cybersecurity monitoring, confidentiality obligations and restricting access to those employees, contractors and service providers who require access to perform their duties. When Personal Information is no longer required, WWC will take reasonable steps to securely destroy, erase, anonymize or otherwise dispose of it in accordance with its records management practices and applicable law. Residual copies may remain in backup or disaster recovery systems until overwritten or deleted in the ordinary course.
Although WWC uses reasonable safeguards designed to protect Personal Information, no method of transmitting information over the Internet or storing electronic information can be guaranteed to be completely secure. Accordingly, WWC cannot guarantee the absolute security of Personal Information. Except to the extent required by applicable law, WWC disclaims liability for unauthorized access to, interception of or loss of Personal Information resulting from events beyond its reasonable control.
Accuracy / Access / Portability
WWC takes reasonable steps to maintain Personal Information in its custody or under its control in a form that is as accurate, complete and current as is reasonably necessary for the purposes for which it is used. Individuals may request access to their Personal Information by contacting the Privacy Officer using the contact information set out in this Policy. Subject to applicable law, individuals may also request correction of inaccurate Personal Information or, where required by applicable law, request that certain Personal Information be provided in a commonly used electronic format. WWC may require sufficient information to verify the identity and authority of the person making the request before responding
Your rights to access, correct, delete, restrict or otherwise request the processing of Personal Information are subject to applicable law and are not absolute. WWC may deny or limit a request where permitted or required by applicable law, including where the information is subject to legal privilege, contains confidential information relating to another person, is required to comply with legal or regulatory obligations, is required for the establishment, exercise or defence of legal claims, or has been retained in accordance with applicable records retention requirements. Where appropriate, WWC may instead supplement or annotate Personal Information rather than replacing or deleting it.
Requests relating to Personal Information should be submitted in writing to the Privacy Officer. WWC will respond within the time required by applicable law
Third Party Content and Links to other Websites
The Website, the Portal and the Services may contain links to, integrations with, or content provided by third-party websites, applications, platforms or services. Such links and content are provided solely as a convenience and do not constitute an endorsement by WWC of the applicable third party or its products or services. WWC does not control and is not responsible for the availability, content, security, privacy practices or terms of use of any third-party website, application, platform or service. Your access to and use of any third-party website or service is entirely at your own risk and is governed by the applicable third party’s terms and privacy policy. This Policy applies only to the Website, the Portal and the Services operated by or on behalf of WWC.
Applicable Law
This Policy is intended to comply with the privacy and data protection laws applicable to WWC’s collection, use, disclosure and other processing of Personal Information. This Policy will be governed by and interpreted in accordance with the laws applicable in the Province of British Columbia and the federal laws of Canada applicable therein, except to the extent that mandatory privacy or data protection laws of another jurisdiction apply. Nothing in this Policy limits any rights or remedies available to an individual under applicable privacy or data protection legislation
Privacy Officer and Complaints
WWC is responsible for Personal Information in its custody or under its control and has implemented policies, procedures and governance measures designed to protect Personal Information and to promote compliance with applicable privacy and data protection laws. WWC is committed to maintaining the accuracy, confidentiality and security of Personal Information and to making information regarding its privacy practices reasonably available to individuals upon request.
WWC has designated a Privacy Officer who is responsible for overseeing WWC’s privacy management program, compliance with this Policy and applicable privacy legislation, and responding to questions, requests and complaints relating to the handling of Personal Information. Questions, requests or complaints regarding this Policy or WWC’s privacy practices should be directed to:
Privacy Officer
Western Wealth Capital,
201 – 2400 Dollarton Highway,
North Vancouver, BC V7H 0B3
email to privacy@westernwealthcapital.com.
WWC will review and respond to privacy complaints and inquiries in accordance with applicable law and its internal privacy procedures. Where appropriate, WWC may modify its policies, procedures or practices in response to complaints, operational requirements, changes in applicable law or regulatory guidance.
Individuals may also have the right to make a complaint to an applicable privacy or data protection regulator in the jurisdiction having authority over the matter.
Where applicable law requires notification of a security breach involving Personal Information, WWC will provide any required notifications to affected individuals and applicable regulatory authorities within the time required by applicable law.
Consent
Except where otherwise permitted or required by applicable law, WWC will obtain any consent required for the collection, use or disclosure of Personal Information. Depending upon the circumstances and applicable law, consent may be express or implied. WWC may also collect, use, disclose, retain, store, transfer or otherwise process Personal Information without consent where permitted or required by applicable law, including where necessary to perform or administer a contract, comply with legal or regulatory obligations, establish, exercise or defend legal claims, protect the rights, property or safety of WWC or others, prevent or investigate fraud or other unlawful activity, or for other purposes authorized by applicable law.
Where consent is required, WWC will take reasonable steps to ensure that the individual understands the nature, purpose and consequences of the collection, use or disclosure of the applicable Personal Information. Where required by applicable law, express consent will be obtained. In other circumstances, consent may be implied where permitted by applicable law and reasonable in the circumstances.
By providing Personal Information to WWC or by accessing or using the Website, the Portal or the Services, you acknowledge that WWC may collect, use, disclose, retain, store, transfer and otherwise process Personal Information as described in this Policy and as otherwise permitted or required by applicable law.
Subject to applicable law, you may withdraw any consent that you have provided by contacting the Privacy Officer in writing. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal and does not require WWC to cease any collection, use, disclosure or other processing that is permitted or required by applicable law. Withdrawal of consent may affect WWC’s ability to establish, administer or maintain investments, provide the Website, the Portal or the Services, communicate with you, or otherwise perform its contractual or legal obligations.
Retention of Personal Information
WWC retains Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to establish, administer and maintain investments and investor relationships, to comply with applicable legal, regulatory, accounting, tax and reporting requirements, to establish, exercise or defend legal claims, or as otherwise permitted or required by applicable law.
When Personal Information is no longer required for those purposes, WWC will take reasonable steps to securely destroy, erase, anonymize or otherwise dispose of it in accordance with its records management practices and applicable law. Residual copies of Personal Information may remain in backup or disaster recovery systems until overwritten or deleted in the ordinary course.
Individuals may request the deletion of their Personal Information by contacting the Privacy Officer. Such requests will be considered in accordance with applicable law. WWC may retain Personal Information where retention is required or permitted by applicable law or is reasonably necessary to fulfill contractual, legal, regulatory, accounting, tax, audit, records management or dispute resolution requirements.
Minors
The Website, the Portal and the Services are intended for use by individuals who have reached the age of majority in the jurisdiction in which they reside. WWC does not knowingly collect Personal Information directly from individuals who have not reached the age of majority through the Website or the Portal. Individuals who have not reached the age of majority should not provide Personal Information to WWC through the Website or the Portal without the involvement of a parent or legal guardian. If WWC becomes aware that Personal Information has been collected directly from an individual who has not reached the age of majority contrary to applicable law, WWC will take reasonable steps to delete that information in accordance with applicable law.