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Privacy Policy

Effective date: August 6, 2026 · Last updated: August 6, 2026

Before this goes live: this is a standard-form privacy policy template, not a document reviewed for Innov8's specific facts. Innov8 collects accredited-investor verification data under Reg D and operates across Canada, Hong Kong, and South Africa — meaning PIPEDA, Hong Kong's PDPO, and South Africa's POPIA may all apply alongside U.S. securities-related recordkeeping rules. Have this reviewed and customized by counsel — including yourself — before publishing it as binding.

Contents

  1. 1. Scope
  2. 2. Information We Collect
  3. 3. How We Use Information
  4. 4. How We Share Information
  5. 5. Cookies & Tracking
  6. 6. Data Security
  7. 7. Data Retention
  8. 8. Your Rights
  9. 9. International Transfers
  10. 10. Children's Privacy
  11. 11. Changes to This Policy
  12. 12. Contact Us

1. Scope

This Privacy Policy explains how Innov8 Royalties ("Innov8," "we," "us," or "our") collects, uses, discloses, and safeguards information when you visit our website, communicate with us, or engage with us in connection with royalty financing, investment, or advisory services. It applies to visitors, prospective investors, resource company counterparties, and other individuals who interact with us.

This Policy does not apply to third-party websites we may link to, or to information you provide directly to unaffiliated service providers such as transfer agents, custodians, or broker-dealers, who maintain their own privacy practices.

2. Information We Collect

We collect information in the following ways:

  • Information you provide directly — name, email address, company, role, and any information you submit through our contact form, email, or in the course of a diligence, origination, or acquisition process.
  • Accredited investor verification information — where required under Regulation D or equivalent rules, we or our transfer agent may collect income, net worth, or professional-license information to verify accredited status. This category is handled under heightened confidentiality given its sensitivity.
  • Automatically collected information — IP address, browser type, device information, and pages visited, collected via standard web server logs and any analytics tools we may enable.
  • Information from third parties — due diligence providers, public company filings, and business partners may provide us information relevant to a transaction or relationship.

3. How We Use Information

We use the information we collect to:

  • Evaluate, structure, and administer royalty origination and acquisition transactions;
  • Verify accredited investor status and satisfy applicable securities law obligations;
  • Respond to inquiries and communicate about our services;
  • Maintain records required for regulatory, tax, and audit purposes;
  • Improve our website and understand how it is used;
  • Detect, prevent, and address fraud, security, or technical issues.

4. How We Share Information

We do not sell personal information. We may share information with:

  • Service providers — transfer agents, escrow agents, legal counsel, accountants, and compliance vendors who need the information to perform services on our behalf;
  • Counterparties — where necessary to structure or close a specific royalty transaction, and only to the extent relevant to that transaction;
  • Regulators and authorities — where required by applicable law, regulation, or legal process in Canada, Hong Kong, South Africa, or the United States;
  • Successors — in connection with a merger, financing, or sale of assets, subject to standard confidentiality protections.

5. Cookies & Tracking

Our website may use cookies or similar technologies for basic functionality and, if enabled, analytics. You can control cookies through your browser settings. Disabling cookies may affect certain site functionality but will not prevent you from contacting us.

6. Data Security

We use administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy, including to satisfy applicable legal, accounting, or regulatory recordkeeping requirements — which, for securities-related records, may extend several years beyond the end of a relationship.

8. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict the use of your personal information, or to object to certain processing. To exercise these rights, contact us using the details below. We will respond in accordance with applicable law, which may require us to verify your identity before acting on a request.

9. International Transfers

Innov8 operates across Canada, Hong Kong, and South Africa. Information may be transferred to, stored, and processed in any of these jurisdictions or others where our service providers operate. Where required, we will implement appropriate safeguards for cross-border transfers.

10. Children's Privacy

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

11. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date above reflects the most recent revision. Material changes will be reflected on this page.

12. Contact Us

Questions about this Privacy Policy or our data practices can be directed to:

info@levittassociates.com
Innov8 Royalties · Vaughan, Ontario, Canada