Effective Date: 2025-11-24
Governing Jurisdiction: Province of Ontario, Canada

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1. DEFINITIONS

1.1 “TL Holdings” means TL Holdings Inc., its subsidiaries, affiliates, divisions, directors, officers, employees, contractors, agents, and successors.
1.2 “Website” means all web pages, portals, platforms, and digital resources operated by TL Holdings at [insert domain].
1.3 “User” means any individual or entity accessing, using, or interacting with the Website, including clients, investors, applicants, scholarship recipients, or any person submitting information.
1.4 “Personal Information” means information about an identifiable individual as defined under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario law.
1.5 “Processing” means the collection, storage, use, disclosure, transfer, retention, destruction, or any operation performed on Personal Information.
1.6 “Third Parties” includes service providers, contractors, analytics platforms, financial institutions, legal advisors, and technical vendors engaged by TL Holdings.
1.7 “Consent” includes express or implied consent, as recognized under Canadian privacy law, and is deemed to exist whenever the User continues to use the Website after publication of this Policy.
1.8 “Applicable Law” means PIPEDA, the Ontario Consumer Protection Act, the Canada Anti-Spam Legislation (CASL), and any other privacy or data-handling regulation binding upon TL Holdings.

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2. SCOPE AND APPLICATION

2.1 This Policy governs all Processing of Personal Information by TL Holdings arising from:
(a) use of the Website;
(b) submissions through contact forms, applications, legal agreements, onboarding processes, and investment inquiries;
(c) communications with TL Holdings by email, text, portal, or other channels;
(d) analytics, tracking, or automated data collection technologies; and
(e) any interaction where Personal Information is reasonably supplied, inferred, or obtained.

2.2 This Policy forms an integral and binding component of all agreements, applications, contracts, and Website use involving TL Holdings.

2.3 TL Holdings reserves unilateral discretion to modify this Policy at any time without prior notice. Continued Website use constitutes acceptance.

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3. CATEGORIES OF INFORMATION COLLECTED

3.1 Personal Identification Information
(a) Name, address, email address, phone number.
(b) Employment information, educational history, and business affiliation.

3.2 Financial and Transactional Data
(a) Bank information, billing details, account numbers.
(b) Investment-related data, business valuation information, or materials submitted for funding consideration.
(c) Scholarship, ISA, or contract-related financial disclosures.

3.3 Technical and Device Information
(a) IP address, browser type, device identifiers, operating system.
(b) Cookies, session data, behavioral analytics, click-path tracking.
(c) Location approximations derived from technical metadata.

3.4 Communications Data
Emails, messages, form submissions, agreements transmitted via the Website.

3.5 Third-Party Data
Information lawfully provided by affiliates, partners, or vendors, including identity verification services, analytics tools, and fraud-prevention systems.

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4. PURPOSES OF COLLECTION AND USE

TL Holdings processes Personal Information strictly for the following purposes:

4.1 Operational Purposes
(a) Administering Website functionality.
(b) Enabling user accounts, client intake, contract execution, and communications.

4.2 Business and Investment Evaluation
(a) Assessing business proposals, investment inquiries, PIC membership applications, or partnership opportunities.
(b) Conducting due diligence and risk assessment.

4.3 Legal and Compliance Requirements
(a) Satisfying obligations under Applicable Law.
(b) Enforcing TL Holdings’ agreements, policies, and rights.
(c) Preventing fraud, misconduct, or prohibited activities.

4.4 Analytics and Optimization
(a) Improving Website performance and user experience.
(b) Conducting internal analysis, performance monitoring, and strategic planning.

4.5 Marketing and Communications
(a) Sending updates, notices, or communications as permitted by CASL.
(b) Administering newsletters, announcements, or promotional materials (opt-out available).

4.6 Any Other Purpose for Which Consent Has Been Obtained
Including implied consent inferred by continued use of Website features.

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5. DISCLOSURE OF PERSONAL INFORMATION

5.1 TL Holdings may disclose Personal Information to the following recipients:

(a) Service Providers: IT firms, hosting platforms, data-storage providers, analytics vendors, legal counsel, accountants, and payment processors.
(b) Affiliates and Subsidiaries: For shared operations, business optimization, or contractual performance.
(c) Regulatory or Legal Authorities: Where required by subpoena, warrant, court order, or lawful request.
(d) Business Partners: When evaluating or executing investments, contracts, or joint ventures with the User.
(e) Transaction Counterparties: In the event of merger, acquisition, consolidation, asset transfer, or corporate restructuring.

5.2 Disclosures will occur strictly under the principles of necessity and proportionality as required by Applicable Law.

5.3 TL Holdings does not sell Personal Information to unrelated third parties.

 

6. INTERNATIONAL TRANSFERS

6.1 Personal Information may be transmitted, stored, or processed outside Ontario or Canada where different privacy standards may apply.

6.2 TL Holdings maintains commercially reasonable contractual safeguards with foreign processors to ensure privacy protections remain comparable to PIPEDA.

 

7. DATA RETENTION

7.1 TL Holdings retains Personal Information only as long as necessary to fulfill the purposes set out in Section 4, subject to statutory or contractual obligations.

7.2 Upon expiry of retention periods, TL Holdings may:
(a) securely destroy the information;
(b) anonymize it for internal analytics; or
(c) retain it further where required by law, contract, or legitimate business interest.

 

8. USER RIGHTS

Subject to Applicable Law, Users may exercise the following rights:

8.1 Access: Request information regarding the Personal Information held by TL Holdings.
8.2 Correction: Request correction of inaccurate or incomplete data.
8.3 Withdrawal of Consent: Withdraw consent subject to contractual limitations and legal requirements.
8.4 Complaint: File complaints with the Office of the Privacy Commissioner of Canada.

All requests must be submitted in writing to the contact listed in Section 12.

 

9. SECURITY SAFEGUARDS

9.1 TL Holdings implements administrative, technical, and physical safeguards proportionate to the sensitivity of the data, including:
(a) encryption, access-controlled systems, secure servers;
(b) restricted employee access;
(c) contractual obligations for Third Parties.

9.2 No method of transmission or storage is completely secure; TL Holdings disclaims liability for breaches beyond its reasonable control.

 

10. COOKIES AND AUTOMATED TECHNOLOGIES

10.1 The Website uses cookies, tracking technologies, and analytics tools to monitor usage patterns.
10.2 Users may disable cookies through browser settings, though Website functionality may be impaired.

 

11. MINORS

11.1 The Website is not intended for individuals under the age of 16 without parental or guardian consent.
11.2 TL Holdings does not knowingly collect Personal Information from minors without lawful authorization.

 

12. CONTACT INFORMATION

All inquiries, access requests, complaints, or withdrawal of consent requests must be directed to:

Privacy Officer — TL Holdings
Email: gmtintheforest@gmail.com
Address: 9582 O'Dwyer's Rd.
Attention: Privacy Compliance

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13. INTERPRETATION AND ENFORCEABILITY

13.1 This Policy is governed exclusively by the laws of the Province of Ontario and the laws of Canada applicable therein.
13.2 Any dispute arising under this Policy will be adjudicated solely in the courts of Ontario.
13.3 If any provision of this Policy is deemed invalid, the remaining provisions shall remain in full force.
13.4 This Policy is intended to be interpreted broadly to maximize TL Holdings’ discretion, flexibility, and control while maintaining compliance with Applicable Law.