Last updated: January 2026

Upside Financial Technologies Inc. ("Upside, “we," "us," or "our") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit our website at upside.financial (the "Website") or use our treasury management and cash optimization services (the "Services").

As a Canadian financial technology company, we are subject to applicable federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws.

1. About Our Services: Upside Financial Technologies Inc. is a financial technology company that provides treasury management and cash optimization solutions for businesses. We are not a bank, trust company, or investment adviser. Our Services are delivered through partnerships with licensed service providers, including Bold Wealth Inc., a registered investment adviser, and National Bank Independent Network (NBIN), which provides custody and banking services.

2. Information We Collect

2.1 Information You Provide Directly: We may collect the following information when you interact with us:
• Contact Information: Name, email address, phone number, and business address
• Business Information: Company name, title, industry, and business requirements
• Onboarding Information: Information submitted through our client onboarding form, including details necessary for suitability assessments conducted by our investment adviser partner
• Financial Information: Information necessary to provide our treasury management services, including bank account details and transaction data
• Communications: Records of correspondence and inquiries you send to us
• Account Credentials: Username, password, and security questions for client portal access

2.2 Information Collected Automatically: When you visit our Website, we may automatically collect:
• Device Information: IP address, browser type, operating system, and device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, and referral sources
• Cookies and Similar Technologies: Information collected through cookies, web beacons, log files, and similar tracking technologies as described in Section 8 below

3. How We Use Your Information: We use the information we collect for the following purposes:
• Service Delivery: To provide, maintain, and improve our treasury management and cash optimization services
• Client Onboarding: To process your application, conduct suitability assessments in coordination with our investment adviser partner, and establish your account
• Client Relationship Management: To communicate with you about your account, respond to inquiries, and provide customer support
• Security and Compliance: To protect against fraud, unauthorized transactions, and other security threats, and to comply with legal and regulatory requirements
• Analytics and Improvement: To analyze usage patterns and improve our Website, client portal, and Services
• Marketing Communications: To send you information about our services, with your consent where required
• Legal Obligations: To comply with applicable laws, regulations, and legal processes

4. How We Share Your Information: We may share your personal information in the following circumstances:

4.1 Service Providers and Partners: We work with trusted third parties to deliver our Services. This includes Bold Wealth Inc., a registered investment adviser that conducts suitability assessments and provides portfolio management services, and National Bank Independent Network (NBIN), which provides custody and banking services. These partners are contractually bound to protect your information and use it only for the purposes for which it was disclosed.

4.2 Legal Requirements: We may disclose your information when required by law, court order, or regulatory authority, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

4.3 Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

4.4 With Your Consent: We may share your information for other purposes with your express consent.

5. Data Security: We implement robust security measures to protect your personal information, including encryption, access controls, secure data storage, and regular security assessments. As a financial technology company, we maintain security standards consistent with industry best practices and regulatory requirements. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

6. Data Retention: We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. The retention period may vary depending on the context of the processing and our legal obligations. Financial records are typically retained for a minimum of seven years in accordance with applicable regulations.

7. Your Rights and Choices: Under Canadian privacy law, you have the following rights:

• Access: You may request access to the personal information we hold about you
• Correction: You may request that we correct any inaccurate or incomplete information
• Withdrawal of Consent: You may withdraw your consent to certain processing activities, subject to legal or contractual restrictions
• Complaint: You may file a complaint with the Office of the Privacy Commissioner of Canada or applicable provincial privacy commissioner

To exercise these rights, please contact us using the information provided below.

8. Cookies and Tracking Technologies: We use cookies and similar tracking technologies to enhance your experience on our Website. Cookies are small text files stored on your device that help us analyze website traffic and customize content. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. We use the following types of cookies:

• Functional Cookies: Required for basic Website functionality and to remember your preferences
• Analytical Cookies: Help us understand how visitors interact with our Website, including data on content accessed and time spent on the Website
• Targeting Cookies: Used to deliver relevant content and track campaign effectiveness

You can control cookie preferences through your browser settings. However, disabling cookies may affect Website functionality and your ability to access certain features, including the client portal. Because of the manner in which we offer our Services, we cannot provide them to customers who do not permit our use of cookies or whose browsers are set to reject cookies. We may also use log files to track actions occurring on the Website and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. Web beacons, tags, and pixels are electronic files used to record information about how you browse the Website.

9. Third-Party Links: Our Website may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to read the privacy policy of every website you visit.

10. Children's Privacy: Our Services are intended for businesses and are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take steps to delete that information promptly.

11. Changes to This Privacy Policy: We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will post the updated policy on our Website with a revised effective date. We encourage you to review this policy periodically. Your continued use of our Website or Services after any changes constitutes your acceptance of the updated policy.

12. Contact Us: If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your privacy rights, please contact us at start@upside.financial