INTRODUCTION

Algo Grande ("we," "our," or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website algo-grande.com and when you opt-in to receive SMS communications from us.

INFORMATION WE COLLECT

Information You Provide to Us

We collect information that you voluntarily provide to us, including:

• Contact information such as your name, email address, phone number, and mailing address

• Communication preferences including your opt-in consent to receive SMS messages and marketing communications

• Inquiry information, meaning any information you provide when contacting us or requesting information about investment opportunities

SMS Program Information

When you opt-in to our SMS program, we collect:

• Your mobile phone number

• Your consent to receive SMS messages

• Message interaction data such as delivery status and opt-out requests

Automatically Collected Information

When you visit our website, we may automatically collect:

• Your IP address

• Browser type and version

• Device information

• Pages visited and time spent on pages

• Referring website addresses

HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Send you SMS messages about investment opportunities, company updates, and market insights that you have opted-in to receive

• Respond to your inquiries and provide customer support

• Send you information about companies we represent and related investment materials

• Improve our website and services

• Comply with legal obligations and enforce our policies

• Analyze website usage and trends

SMS COMMUNICATIONS

Message Frequency

Message frequency varies depending on market activity and investment opportunities. You may receive recurring messages per month.

Opt-Out Instructions

You can opt-out of SMS messages at any time by replying STOP to any message you receive from us. You will receive a confirmation message that you have been unsubscribed. After opting out, you will no longer receive SMS messages from us unless you re-opt-in.

Help Information

For help or more information, reply HELP to any SMS message or contact us at info@algo-grande.com.

Message and Data Rates

Message and data rates may apply depending on your mobile carrier plan. Please contact your mobile carrier for details about your specific plan.

Carrier Liability

Carriers are not liable for delayed or undelivered messages.

HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We may share your information with:

• Service providers who assist us with SMS delivery, website hosting, and analytics

• Companies we represent when investment opportunities are relevant to your expressed interests

• Legal or regulatory authorities when required by law

• Business partners in connection with a merger, acquisition, or sale of assets

DATA SECURITY

We implement reasonable security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the internet or electronic storage is 100% secure.

DATA RETENTION

We retain your personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The following general retention periods apply:

• Contact and inquiry information: Retained for up to 7 years from the date of last interaction, in line with applicable business and regulatory record-keeping requirements

• SMS opt-in records and consent logs: Retained for a minimum of 4 years from the date of consent or withdrawal, to demonstrate compliance with applicable telecommunications and anti-spam laws

• Website usage and analytics data: Retained for up to 26 months, after which it is anonymized or deleted

• Legal and compliance records: Retained for as long as required under applicable law, which may exceed the periods above

When personal information is no longer required, we securely delete or anonymize it. Where deletion is not immediately possible (for example, because data is stored in backup archives), we isolate it from further processing until deletion can occur.

YOUR RIGHTS AND CHOICES

You have the right to:

• Access the personal information we hold about you

• Correct inaccurate or incomplete information

• Request deletion of your personal information subject to legal retention requirements

• Opt-out of SMS communications at any time by replying STOP

• Opt-out of email communications by clicking the unsubscribe link in our emails

To exercise any of these rights, please contact us using the details in the Contact Us section below. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to improve your browsing experience, analyze site traffic, and understand how visitors interact with our content. By continuing to use our website, you consent to our use of cookies as described in this section.

Types of Cookies We Use

• Strictly necessary cookies: Required for the website to function properly. These cannot be disabled.

• Analytics cookies: Used to collect information about how visitors use our site, including pages visited, time spent, and referring sources. We use this information to improve our website and services. These cookies do not collect personally identifiable information directly.

• Functionality cookies: Allow the website to remember choices you make and provide enhanced features.

• Marketing and targeting cookies: Used to deliver relevant content and track the effectiveness of our communications. These may be set by us or by third-party providers whose services we use.

Third-Party Analytics and Tracking

We may use third-party analytics services (such as Google Analytics or similar providers) that place cookies on your device to collect information about your use of our website. These providers may process your data on our behalf and are contractually bound to use it only as directed by us. Where required by law, we obtain your consent before placing non-essential cookies.

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website. For more information on managing cookies, visit your browser's help documentation.

CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on our website and revising the Last Updated date. Continued use of our services after changes are posted constitutes acceptance of the updated policy.

CONTACT US

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Algo Grande Email: info@algo-grande.com Phone: +1 (236) 836-4182 Address: Suite 1507 – 1030 West Georgia Street, Vancouver, BC, Canada, V6E 2Y3

ADDITIONAL INFORMATION FOR SPECIFIC JURISDICTIONS

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your information, and the right to opt-out of the sale of personal information. We do not sell personal information.

Canadian Residents

We comply with Canada's Anti-Spam Legislation (CASL). You have provided express consent to receive commercial electronic messages from us, and you may withdraw that consent at any time.

European Economic Area (EEA), United Kingdom, and Switzerland Residents

If you are located in the EEA, United Kingdom, or Switzerland, the following additional terms apply to our processing of your personal data under the General Data Protection Regulation (GDPR) and equivalent local laws.

Legal Bases for Processing

We rely on the following legal bases to process your personal data:

• Consent (Article 6(1)(a) GDPR): Where you have given us clear consent, for example to send you SMS messages or marketing communications, or to place non-essential cookies on your device. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

• Legitimate interests (Article 6(1)(f) GDPR): Where processing is necessary for our legitimate business interests, such as improving our services, preventing fraud, and maintaining the security of our systems, provided those interests are not overridden by your rights and interests.

• Legal obligation (Article 6(1)(c) GDPR): Where processing is necessary to comply with a legal obligation to which we are subject.

• Contract (Article 6(1)(b) GDPR): Where processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.

International Data Transfers

Algo Grande is based in Canada, which the European Commission has recognized as providing an adequate level of data protection for commercial organizations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA). Where we transfer your personal data to other third parties located outside the EEA or the UK, we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office

• Transfers to countries recognized by the European Commission or the UK as providing an adequate level of protection

You may request a copy of the relevant transfer safeguards by contacting us using the details in the Contact Us section.

Your Rights Under GDPR

In addition to the rights set out above, if you are in the EEA, UK, or Switzerland, you have the following rights under applicable data protection law:

• Right of access: You may request a copy of the personal data we hold about you.

• Right to rectification: You may ask us to correct inaccurate or incomplete personal data.

• Right to erasure: You may ask us to delete your personal data where there is no compelling reason for us to continue processing it.

• Right to restriction of processing: You may ask us to restrict processing of your personal data in certain circumstances.

• Right to data portability: You may request that we provide your personal data to you or to another controller in a structured, commonly used, machine-readable format.

• Right to object: You may object to our processing of your personal data where we rely on legitimate interests as our legal basis. You also have the right to object to processing for direct marketing purposes at any time.

• Rights related to automated decision-making: We do not currently make decisions about you based solely on automated processing that produce legal or similarly significant effects.

To exercise any of these rights, please contact us at info@algo-grande.com. We will respond to your request within one month. This period may be extended by a further two months where necessary, in which case we will inform you.

Right to Lodge a Complaint

If you are located in the EEA, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities and their contact details is available at: https://edpb.europa.eu/about-edpb/board/members_en

If you are located in the United Kingdom, you may contact the Information Commissioner's Office (ICO) at https://ico.org.uk or by calling 0303 123 1113.

We would, however, appreciate the opportunity to address your concerns before you contact a supervisory authority. Please reach out to us first using the contact details in the Contact Us section.

Processor Categories

We engage the following categories of data processors to assist with our operations. All processors are contractually bound to process personal data only on our instructions and in accordance with applicable data protection law:

• SMS delivery providers: Process your mobile phone number and message content to deliver SMS communications on our behalf

• Website hosting providers: Store and serve our website content and may process IP addresses and technical usage data

• Analytics providers: Process anonymized or pseudonymized website usage data to help us understand and improve site performance

• Email service providers: Process your email address and communication preferences to deliver email communications

• IT support and security providers: May access personal data incidentally as part of providing technical support and maintaining system security

You may request a current list of our processors by contacting us at info@algo-grande.com.

EU/UK Representative

Algo Grande is established in Canada and does not currently have a designated representative in the European Union or the United Kingdom under Article 27 of the GDPR. We are assessing our obligations in this regard as our activities in those regions develop. In the meantime, you may contact us directly at info@algo-grande.com for any data protection matters.