Privacy Policy

Peloton Capital Management Inc. (“PCM”, “we”, “us”, or “our”) is committed to protecting the privacy of individuals whose personal information we collect in the course of our business. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in accordance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA).

This Privacy Policy applies to personal information we collect, use or disclose when you:

  • Use our website, located at https://www.pelotoncapitalmanagement.com/ (the “website”)

  • Submit your personal information to us

  • Apply for a job with us

  • Authorize us to obtain personal information from other sources, or

  • Interact with us in any other way (by telephone, email and in person)

By accessing our website, providing us with your personal information, or engaging with our services, you acknowledge and accept this Privacy Policy.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE OR PROVIDE US YOUR PERSONAL INFORMATION.

1. Information We Collect: We may collect personal information such as:

  • Name, contact details, and identification numbers

  • Financial and investment-related information

  • Tax residency and compliance data

  • Communication preferences

  • Website usage data (via cookies and analytics tools)

We collect this information directly from individuals, through subscription documents, communications, and third-party service providers.

2. Use of Personal Information: PCM uses personal information to:

  • Evaluate and manage investments

  • Comply with legal, regulatory, and tax obligations

  • Communicate with investors and stakeholders

  • Prevent fraud and ensure security

  • Maintain internal records and reporting

3. Disclosure of Personal Information: We do not sell personal information to third parties. We may share personal information with:

  • Fund administrators, legal and accounting advisors

  • Regulatory and tax authorities

  • Service providers under strict confidentiality obligations

In addition, PCM may also disclose information to:

  • Third parties in connection with a potential business transaction (such as a merger, sale of all or part of its business, transfer of assets, bankruptcy, or similar event), or as part of completing such a transaction

  • Any third party required to comply with legal obligations, enforce our policies, protect our or others’ rights, interests, property or safety, and prevent, investigate or otherwise address any other harmful, unauthorized, fraudulent or illegal activity

  • Anyone else to whom you authorize us to disclose it

4. Cross-Border Transfers: Personal information may be transferred outside of Canada or the investor’s jurisdiction of residence. PCM ensures such transfers are protected by appropriate safeguards and contractual obligations.

5. Data Retention and Security: PCM retains personal information only as long as necessary and securely destroys it when no longer required. We implement physical, technical, and administrative safeguards to protect against unauthorized access, loss, or misuse.

6. Investor Rights: Individuals have the right to:

  • Access and correct their personal information

  • Withdraw consent (subject to legal or contractual limitations)

  • Request deletion or portability of their data

  • File complaints with PCM or applicable privacy regulators

7. Cookie Policy: PCM’s website uses cookies to enhance user experience and analyze traffic. Users can manage cookie preferences through their browser settings. Disabling cookies may affect website functionality.

8. Fonts: This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:

  • Information about your browser, network, or device

  • Your IP address

9. Changes to This Policy: We may update this Privacy Policy periodically. The latest version will always be available on our website.

10. Contact us: Requests can be directed to our Chief Financial Officer at:

Peloton Capital Management Inc., 8 King Street East, Suite 1100, Toronto, ON, M5C 1B5

E: info@pelotoncapitalmanagement.com

T: 647-951-5232

This Privacy Policy was last updated : August 2025