This Website Privacy Policy (the “Policy”) explains how Origin Innovations Inc. (“Origin Innovations”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal information in connection with our public website and any investor-facing pages, portals, forms, and contact channels we operate (collectively, the “Website”). This Policy applies to personal information handled by Origin Innovations in Canada and is designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable Canadian privacy laws. By using the Website or submitting personal information to us, you agree to the practices described below.
1. Accountability and Contact
Origin Innovations is responsible for personal information under its control and has appointed a Privacy Officer to oversee compliance with this Policy and applicable laws.
Privacy Officer: Elizabeth Musyj
Email: [email protected]
Mailing Address: 420 Kildare Road, Suite 102, Windsor, Ontario, N8Y 3G4
2. Personal Information We Collect
The personal information we collect depends on how you interact with the Website. We collect information that you provide directly to us and information collected automatically from your device.
Information you provide directly may include:
• Identity and contact details (e.g., name, email address, phone number).
• Professional information (e.g., employer, role/title, professional accreditations).
• Communications and submissions (e.g., messages sent through web forms or email).
• Investor-related information (see Section 5) if you request access to our investor portal or begin onboarding.
Information collected automatically may include:
• Technical and usage data (e.g., IP address, device and browser type, pages viewed, timestamps, referring URLs).
• Cookie information and similar technologies as described in Section 6.
3. How We Use Personal Information (Purposes and Legal Grounds)
We use personal information for the following purposes and legal grounds, as permitted by PIPEDA:
• Providing and improving the Website, responding to inquiries, and operating our business (consent and reasonable purposes).
• Website security, fraud prevention, abuse detection, and network monitoring (reasonable purposes).
• Managing marketing communications where permitted (consent or as otherwise allowed by law).
• Meeting legal, regulatory, and compliance obligations, including securities laws and record-keeping (legal obligations).
• Any additional purposes that we disclose to you at the time of collection and for which we obtain your consent when required.
4. Disclosures to Service Providers and Other Parties
We may disclose personal information to trusted service providers that support our Website and operations (e.g., hosting, analytics, communications, document management, IT security). We require service providers to protect personal information and to use it only for the services they provide to us. We may also disclose information as required or permitted by law (e.g., to regulators, law enforcement, or in connection with legal proceedings), or in the context of a business transaction (e.g., financing, merger, or asset sale) subject to appropriate safeguards.
5. Investor Onboarding, Eligibility, and AML/KYC
If you request information about investing, apply to invest, or access our investor portal, we may collect information to assess eligibility and comply with anti‑money‑laundering (AML), anti‑terrorist financing, and securities law obligations. This may include government‑issued identification, date of birth, residency and tax status, professional accreditations, employment information, financial details, and results of sanctions/PEP screening. We retain such records for the periods required by law and our regulators, and then securely delete or anonymize them.
6. Cookies, Analytics and Cross‑Border Transfers
We use essential cookies to operate the Website. With your consent, we may also use non‑essential cookies (e.g., analytics) to understand Website usage. You can manage cookie preferences in your browser and via our cookie tools, if enabled, though disabling certain cookies may affect Website functionality.
Our service providers may process personal information in Canada, the United States, and other jurisdictions. When your information is processed outside Canada, it may be subject to the laws of those jurisdictions and accessible to courts, law enforcement, and regulators there. Regardless of location, we require service providers to protect your information consistent with this Policy.
7. Marketing Communications (CASL)
We send commercial electronic messages (such as newsletters or updates) only with your consent or as otherwise permitted by law. Every message includes an unsubscribe mechanism that takes effect without delay. You can also contact us to update your communication preferences at any time.
8. Security & Incident Response
We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, loss, or disclosure appropriate to the sensitivity of the information. We maintain incident response procedures and required records. Where a breach creates a real risk of significant harm, we will notify affected individuals and report to regulators as required by law.
9. Retention
We retain personal information only as long as necessary for the purposes set out in this Policy or as required by law. As a guideline: (i) general website inquiry records are retained for up to 24 months after the last interaction; (ii) marketing preferences are retained until you unsubscribe or your consent is otherwise withdrawn or expires; and (iii) investor and AML/KYC records are retained for at least 7 years after the end of the relationship or longer where required by law or regulators. After these periods, we securely delete or anonymize the information.
10. Your Rights
You may request access to or correction of your personal information and information about our use and disclosure of it. If we refuse a request, we will provide reasons, subject to legal limits. To exercise these rights, contact our Privacy Officer using the details in Section 1.
If you have concerns about our handling of personal information, you may file a complaint with us. You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada.
11. Automated Decision‑Making
We do not use personal information to make decisions that produce legal or similarly significant effects without human involvement.
12. Children’s Privacy
The Website is not directed to children under the age of 13, and we do not knowingly collect personal information from children. If you believe a child has provided personal information, please contact us so that we can delete it.
13. Accuracy
We rely on you to provide accurate, complete, and up‑to‑date personal information. Please inform us of any changes so that we can keep our records current.
14. Changes to this Policy
We may update this Policy from time to time to reflect changes to our practices or legal requirements. The updated Policy will be posted on the Website with a revised “Last Updated” date. Your continued use of the Website after an update signifies your acceptance of the changes.
15. How to Contact Us
Questions, requests, or complaints regarding this Policy or our privacy practices can be directed to our Privacy Officer:
Elizabeth Musyj, Privacy Officer
Email: [email protected]
Mailing Address: 420 Kildare Road, Suite 102, Windsor, Ontario, N8Y 3G4
We will respond promptly in accordance with applicable law.
Last Updated: September 26, 2025