Privacy Policy | FLOWCAP

1. Who we are

FLOWCAP ("FLOWCAP", "we", "us") is a consulting company providing company assessment and strategic advisory services in relation to potential Reverse Takeover transactions. Our registered office is [registered address]. Questions about this policy may be directed to team@flowcap.cc.

We handle personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, and — where a visitor is located in the European Economic Area or the United Kingdom — the General Data Protection Regulation.

2. Information we collect

Information you provide. When you submit the confidential RTO assessment application, we collect the information entered in that form and any documents attached to it. This typically includes company details, contact details for the individual submitting the application, business and product descriptions, financial information, ownership and beneficial-owner information, and supporting corporate documents.

Information you send us directly. Correspondence sent to our email addresses, and any materials attached to it.

Technical information. Standard server log information generated when you visit the site, including IP address, browser type, pages requested and timestamps.

Analytics. If you accept optional analytics cookies, aggregated usage information about how the site is navigated. Analytics are not loaded unless you accept them.

Applications in progress. So that we can follow up on applications that are left unfinished, the answers entered in the assessment application are saved to our confidential assessment records as they are entered — not only when the application is submitted. A record is created once a company name or corporate email has been entered, and is updated as the application progresses. Documents are transmitted only when the application is submitted.

Information held in this way is treated as confidential business information on the same terms as a completed application, and is used only to assess the company and to contact you about the application. You may ask us to delete an unfinished application at any time by writing to team@flowcap.cc.

The RTO Readiness Score is processed entirely in your browser. Your answers and your score are not transmitted to us or stored on our servers. A local copy of an unfinished application is also kept in your browser's own storage so that you can resume it on the same device.

3. Why we use it

To assess whether a company falls within our current mandate
To conduct the preliminary screening and readiness review described on this site
To communicate with you about your application
Where you have specifically consented, to introduce a selected company to relevant professional market participants
To operate, secure and improve the website
To meet legal and regulatory obligations, including sanctions screening

Our lawful bases, where the GDPR applies, are the performance of steps taken at your request prior to entering a contract, our legitimate interests in assessing and responding to enquiries, your consent where we ask for it, and compliance with legal obligations.

4. Confidentiality of company materials

Materials submitted through the application are treated as confidential business information. Access is limited to the team members conducting the assessment. We do not sell, rent or trade company materials or contact information.

We do not disclose your materials to any third party — including legal counsel, auditors, dealers or investment firms — without your specific prior consent to that particular disclosure. Where an assessment progresses to introductions, you decide what is shared and with whom.

5. Disclosure to others

We may disclose personal information:

To service providers who host our website, process form submissions or provide email and scheduling services, under contractual confidentiality obligations and only as needed to provide those services
To professional advisers where necessary for the establishment or defence of legal claims
Where required by law, regulation, court order or a lawful request from a public authority
To a third party you have specifically asked or authorised us to contact

6. International transfers

Our service providers may process information outside Canada, including in the United States and the European Economic Area. Where information is transferred internationally we take steps to ensure a comparable level of protection, including contractual safeguards with those providers. Information processed in another country may be subject to lawful access requests by the authorities of that country.

7. Retention

We retain application materials only for as long as needed for the purpose described above and to meet legal or regulatory obligations. Where an application is declined and there is no ongoing relationship, materials are deleted or anonymised within [retention period]. Where a company is selected and an engagement follows, materials are retained for the duration of that engagement and for the period required afterwards.

You may request deletion of your materials at any time by writing to team@flowcap.cc.

8. Your rights

Subject to applicable law, you may request access to the personal information we hold about you, correction of inaccurate information, deletion, restriction of processing, and withdrawal of consent where processing is based on consent. Where the GDPR applies you also have the right to data portability and the right to lodge a complaint with a supervisory authority.

To exercise any of these rights, write to team@flowcap.cc. We may need to verify your identity before responding. In Canada you may also complain to the Office of the Privacy Commissioner of Canada.

9. Cookies

We use essential cookies and local storage necessary to operate the site, remember your cookie choice and save an unfinished application on your device. These cannot be disabled without affecting functionality.

Optional analytics cookies are used only if you accept them through the cookie notice. You may change your choice at any time by clearing your browser storage for this site, which will cause the notice to be shown again.

10. Security

The site is served over TLS. We apply access controls, limit access to application materials to the team members conducting an assessment, and review our arrangements with service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Please do not send confidential company materials by unencrypted email. Use the application form, which is the route our team monitors for company submissions.

11. Children

This website is directed at businesses and is not intended for individuals under the age of 18. We do not knowingly collect personal information from children.

12. Changes

We may update this policy from time to time. The version in force is the one published on this page, with the date shown above. Material changes will be indicated by updating that date.