Our Commitment

ANGUS Capital Inc. is a private investment fund that acquires and consolidates small and medium-sized businesses. In the course of its business, it holds personal information regarding, among others, its employees and other individuals with whom it conducts business.

ANGUS Capital has established policies and practices governing the management of this information, from its collection to its destruction. This page outlines the key points. It is published in accordance with the Act respecting the protection of personal information in the private sector.

Who Is Responsible

Nicolas Pinto, co-founder and partner, is the person responsible for the protection of personal information at ANGUS Capital Inc. He approves the company’s policies on this matter, handles requests and complaints, and ensures compliance with the rules described below.

Contact Information:

Nicolas Pinto

1195 Wellington Street, Suite 603

Montreal, Quebec H3C 1W1

Phone: 1 877 596 0845

Email: [email protected]

How We Handle Personal Information

What We Collect. Before collecting any information, we determine the purposes for which it will be used, and we collect only what is necessary for those purposes. Information is collected directly from the individual concerned, unless the law permits it to be obtained otherwise.

How We Use the Information. The information is used only for the purposes for which it was collected. Any other use requires the individual’s consent, except as permitted by law. When consent is required, it is requested for each specific purpose, in plain and clear language, and presented separately from other information.

Who Has Access. Within the company, personal information is accessible only to those who need it to perform their duties.

How Long We Retain It. Information is retained for as long as necessary to fulfill the purposes for which it was collected, and is then destroyed or anonymized, subject to the retention periods required by law. Specific retention periods are established for each category of information, and compliance with these periods is reviewed annually.

Automated Decisions and Biometrics. ANGUS Capital does not make any decisions regarding an individual that are based solely on automated processing, and does not collect any biometric data.

Service Providers, Transactions, and Transfers Outside Quebec

ANGUS Capital does not sell or rent personal information.

Service Providers. When a service provider needs access to personal information to perform its duties, such duties are assigned in writing. The contract specifies the applicable safeguards, the prohibition on using the information for other purposes, and the obligation not to retain it after the assignment ends.

Business Transactions. In the course of evaluating or finalizing an acquisition, merger, or financing, personal information may be exchanged with the other party. A written agreement is entered into in advance; it stipulates that the information will be used solely to complete the transaction, that it will not be disclosed to third parties, that it will be protected, and that it will be destroyed if the transaction does not proceed. Once the transaction is completed and the information continues to be used, the individuals concerned are notified within a reasonable time.

Outside Quebec. Before disclosing information outside of Quebec, or entrusting its storage to a provider based there, ANGUS Capital conducts a Privacy Impact Assessment (PIA).

New Projects. Any proposed acquisition, development, or overhaul of an information system involving personal information is subject to a prior assessment (PIA), and the person responsible is involved from the outset.

Security and Incidents

ANGUS Capital implements reasonable security measures, taking into account the sensitivity of the information, its volume, and the medium on which it is stored. Access is restricted and reviewed periodically, and staff members are bound by confidentiality agreements and receive annual training on their obligations.

In the event of a privacy incident, ANGUS Capital immediately takes reasonable measures to mitigate the risk of harm and prevent a similar incident from recurring. If the incident poses a risk of serious harm, the Commission d’accès à l’information and the individuals concerned are promptly notified. All incidents are recorded in a log.

Your Rights

Any individual whose personal information is held by ANGUS Capital may:

• access that information and obtain a copy of it;

• have inaccurate, incomplete, or ambiguous information corrected, or have information deleted if its collection was not authorized;

• r receive, in a structured and commonly used technological format, the computerized information they have provided themselves, or have it transferred to another organization authorized to collect it (portability);

• withdraw their consent to the disclosure or use of their information;

• request the cessation of further dissemination of information.

How To Proceed. The request must be submitted in writing to the data controller, using the contact information provided above, by a person who can verify their identity. A written response will be provided no later than 30 days after receipt. Any denial will include a statement of reasons and indicate the available remedies as well as the deadlines for exercising them.

Personal information held by ANGUS Capital is stored in its computer systems and internal archives; an individual may access this information by submitting a request to the data protection officer.

Complaints and Updates

File A Complaint. Any person who believes that ANGUS Capital has failed to fulfill its obligations may file a complaint with the responsible manager, either in writing or verbally. The manager will acknowledge receipt within five business days, review the complaint, and provide written notice of the conclusion and the actions taken, no later than 30 days after receipt. If this deadline cannot be met, the complainant will be notified and provided with the expected response date.

Anyone dissatisfied with the response may contact the Commission d’accès à l’information du Québec. No adverse action will be taken against a person on the grounds that they filed a complaint in good faith.

Update. ANGUS Capital’s privacy policies are reviewed at least once a year and whenever a significant change occurs. Any changes to this page are posted here.

Effective June 1, 2023 · Last updated: October 26, 2026