Privacy Policy

MERCHANT GROWTH PRIVACY POLICY

Effective Date: July 7, 2026

Merchant Growth Ltd. ("Merchant Growth", "we", "our" or "us") is committed to protecting the privacy, confidentiality and security of the personal information entrusted to us. We recognize that maintaining the trust of our customers, applicants and business partners requires responsible stewardship of personal information.

This Privacy Policy describes how Merchant Growth collects, uses, discloses, stores, protects and retains personal information in connection with our website, products and services. It also explains your privacy rights and the choices available to you regarding your personal information.

This Privacy Policy applies to:

our website located at www.merchantgrowth.com (the "Site");
applications for financing and related products or services;
products and services provided by Merchant Growth; and
communications and other interactions you have with Merchant Growth.

Merchant Growth collects, uses and discloses personal information in accordance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial privacy legislation, and other laws governing our business.

Scope and Definitions

This Privacy Policy applies to Merchant Growth Ltd., its subsidiaries, affiliates and authorized service providers acting on our behalf. For purposes of this Privacy Policy:

"Personal Information" means information about an identifiable individual or information that could reasonably be used, alone or in combination with other information, to identify an individual. Personal Information does not include information that has been anonymized in accordance with applicable law.

"Service Provider" means a third party that provides products or services to Merchant Growth and processes Personal Information solely on Merchant Growth's behalf and in accordance with our instructions.

"You" means:

a visitor to our Site;
an applicant for financing;
a current or former customer;
a guarantor;
a reference;
a beneficial owner;
a director, officer or shareholder of an applicant or customer;
an employee or representative of a business applicant or customer; or
any other individual whose Personal Information we collect in connection with our business.

Collection of Personal Information

Merchant Growth collects, uses and discloses Personal Information with your knowledge and consent, except where otherwise permitted or required by applicable law. By applying for our products or services, using our Site, communicating with Merchant Growth or otherwise providing Personal Information to us, you consent to the collection, use, disclosure and retention of your Personal Information as described in this Privacy Policy.

We collect only the Personal Information reasonably necessary to:

evaluate financing applications;
verify identity;
provide and administer our products and services;
detect and prevent fraud, financial crime and unauthorized activity;
comply with legal and regulatory obligations;
communicate with you;
improve our products, services and customer experience;
manage our business operations; and
protect Merchant Growth, our customers and the public.

Depending on our relationship with you, the Personal Information we collect may include:

Contact and Identification Information, including your name, residential and business address, telephone number, email address, date of birth, Social Insurance Number (where authorized or required by law), driver's licence or other government-issued identification.
Financial Information, including banking information, payment information, financial statements, sales history, revenue information, transaction history and other information relevant to evaluating financing applications or administering your account.
Credit Information, including consumer and commercial credit reports, credit scores, payment history and information obtained from credit reporting agencies.
Business Information, including business ownership, legal structure, directors, officers, shareholders, beneficial ownership information, licences, registrations and operational information.
Relationship Information, including financing history, account history, communications with Merchant Growth, customer service interactions and preferences.
Identity Verification and Compliance Information, including information collected for fraud prevention, anti-money laundering, sanctions screening, know-your-customer ("KYC") and other legal or regulatory compliance purposes.
Technical Information, including Internet Protocol (“IP”) address, browser information, device identifiers, website usage information and other information collected through your use of our Site.
Information You Voluntarily Provide, including information submitted through applications, forms, surveys, correspondence, customer support inquiries and other communications with Merchant Growth.

Where you provide Personal Information about another individual, including a guarantor, reference, landlord, director, officer, shareholder, employee or other third party, you represent that you have the authority and all necessary consents to provide that information and authorize Merchant Growth to collect, use and disclose it in accordance with this Privacy Policy.

Sources of Personal Information

Merchant Growth may collect Personal Information from a variety of sources, including:

directly from you;
credit reporting agencies;
financial institutions;
payment processors;
identity verification providers;
fraud detection providers;
publicly available sources where permitted by law;
references, guarantors and business contacts you identify;
government agencies and regulatory authorities where authorized or required by law;
Service Providers acting on our behalf;
business partners where you have consented to such collection; and
other third parties where permitted or required by law.

When We Collect Personal Information

Merchant Growth may collect Personal Information:

before a business relationship begins, including when you contact us or submit an application;
while evaluating your eligibility for products or services;
throughout our business relationship with you;
after repayment or closure of an account where reasonably necessary for legal, regulatory, operational or legitimate business purposes; and
whenever otherwise permitted or required by applicable law.

Children's Privacy

Merchant Growth's products and services are intended for businesses and adults and are not directed to individuals under the age of majority. We do not knowingly collect Personal Information directly from children. If we become aware that we have inadvertently collected Personal Information directly from a child contrary to applicable law, we will take reasonable steps to delete that information.

Use of Personal Information

Merchant Growth may use Personal Information to:

evaluate financing applications;
determine eligibility for products and services;
verify identity;
detect, investigate and prevent fraud, financial crime, money laundering, sanctions violations and other unlawful activity;
establish, administer, service and collect accounts;
communicate with applicants and customers regarding products, services and accounts;
provide customer support;
maintain accurate business records;
comply with legal, regulatory, tax, accounting and audit requirements;
manage operational, legal and credit risk;
improve our products, services and customer experience;
conduct internal business analytics and reporting;
develop and enhance products, services and business processes;
market products and services where permitted by law and in accordance with your communication preferences;
establish, exercise or defend legal claims;
protect Merchant Growth, our customers and the public against unauthorized activity; and
carry out any other purpose for which consent has been obtained or that is otherwise permitted or required by law.

Merchant Growth may also create aggregated or de-identified information that no longer identifies an individual. Such information may be used for business analytics, statistical reporting, product development, operational improvements, underwriting model development, artificial intelligence evaluation and other lawful business purposes.

Artificial Intelligence and Automated Processing

Merchant Growth may use artificial intelligence ("AI"), machine learning and other automated technologies to assist in providing, administering and improving our products and services.

These technologies may be used for purposes including:

document review and summarization;
fraud detection and prevention;
identity verification;
underwriting support;
risk assessment;
customer service;
quality assurance;
software development;
operational efficiency;
regulatory compliance;
internal reporting and analytics; and
improving our products and services.

Authorized Merchant Growth personnel may use approved AI-enabled software tools to assist with internal business functions, including analyzing information, drafting documents, summarizing materials, responding to customer inquiries and supporting operational decision-making.

Where AI services are provided by third-party vendors, Merchant Growth requires those providers to maintain appropriate contractual privacy, confidentiality and security protections and to process Personal Information only for authorized business purposes consistent with applicable law.

Where commercially available and technically feasible, Merchant Growth configures AI services so that Personal Information is not used to train publicly available artificial intelligence models.

Automated technologies may assist Merchant Growth in evaluating financing applications, detecting fraud, monitoring accounts and supporting operational decisions. Depending on the circumstances, important decisions may also involve appropriate human review.

Merchant Growth does not make decisions based solely on automated processing where prohibited by applicable law.

Use of Credit Information

Because Merchant Growth provides financing products and services, credit information is fundamental to our ability to evaluate applications, manage risk and administer customer accounts.

Merchant Growth may obtain, use, update and disclose credit information before, during and after our business relationship for purposes including:

evaluating applications;
monitoring existing accounts;
fraud detection;
portfolio risk management;
collections;
complying with legal and regulatory obligations; and
improving our underwriting and risk assessment models.

Where permitted by applicable law, Merchant Growth may continue to obtain updated credit information after the conclusion of our business relationship for the legitimate business purposes described in this Privacy Policy.

If you have questions regarding our collection or use of credit information, please contact Merchant Growth using the contact information provided at the end of this Privacy Policy.

Use of Your Email Address and Communications

Merchant Growth may use your email address, telephone number and other contact information to communicate with you regarding your application, account, products, services and our business relationship.

These communications may include:

application status updates;
requests for additional information;
account servicing communications;
payment reminders;
security notifications;
fraud alerts;
legal or regulatory notices;
transactional SMS messages;
funding notifications;
customer support communications; and
information regarding products or services that may be relevant to your business.

Where required by applicable law, Merchant Growth will obtain your consent before sending commercial electronic messages. Every marketing communication will include a simple method for you to unsubscribe or otherwise withdraw your consent.

Merchant Growth may use third-party service providers to deliver emails, SMS messages and other communications on our behalf. These providers process Personal Information solely to provide services to Merchant Growth and are contractually required to protect the confidentiality and security of your Personal Information.

To improve our communications and customer experience, Merchant Growth may monitor delivery rates, email opens, click-through rates and other engagement metrics associated with our communications.

Disclosure of Personal Information

Merchant Growth does not sell or rent your Personal Information. Merchant Growth does not share your mobile telephone number, SMS/text messaging opt-in information, or SMS/text messaging consent with third parties or affiliates for their own marketing or promotional purposes. SMS/text messaging originator opt-in data and consent will not be sold, rented or otherwise shared except as necessary to provide messaging services on Merchant Growth's behalf or where required by law. We disclose Personal Information only where reasonably necessary to provide our products and services, operate our business, comply with legal or regulatory obligations, protect our legitimate business interests, or where otherwise permitted or required by applicable law.

Depending on the circumstances, Merchant Growth may disclose Personal Information to the following categories of recipients.

Service Providers

Merchant Growth may disclose Personal Information to trusted third-party Service Providers that perform services on our behalf.

These services may include:

cloud hosting and infrastructure;
information technology services;
payment processing;
banking and payment networks;
customer relationship management systems;
fraud detection and prevention;
identity verification;
anti-money laundering and sanctions screening;
cybersecurity services;
website hosting;
communications services;
document management;
analytics and business intelligence;
artificial intelligence and machine learning services;
legal, accounting and audit services;
insurance providers;
collection agencies;
business consulting services;
data processing services; and
other operational support services reasonably necessary to operate our business.

Merchant Growth requires its Service Providers to protect Personal Information through contractual confidentiality, privacy and security obligations appropriate to the sensitivity of the information.

Our Service Providers are authorized to use Personal Information only for the purpose of providing services to Merchant Growth or as otherwise permitted by law.

Credit Reporting Agencies and Financial Institutions

Merchant Growth may disclose Personal Information to:

consumer reporting agencies;
commercial credit bureaus;
financial institutions;
payment processors;
payment networks;
financing sources;
investors or participants in financing transactions where disclosure is reasonably necessary;
collection agencies; and
other organizations involved in providing, administering or collecting financial products and services.

Merchant Growth may also obtain information from these organizations to evaluate applications, administer accounts, detect fraud, collect outstanding obligations and comply with applicable legal and regulatory requirements.

Business Partners

Merchant Growth may work with third-party organizations to offer products or services that may complement our financing products. Where Merchant Growth shares Personal Information with a third party for that organization's own marketing or business purposes, we will obtain your consent where required by applicable law. Notwithstanding anything else in this Privacy Policy, Merchant Growth will not disclose your mobile telephone number, SMS/text messaging opt-in information or SMS/text messaging consent to third parties or affiliates for their own marketing or promotional purposes.

At the time consent is requested, Merchant Growth will identify:

the third party;
the Personal Information to be shared;
the purpose of the disclosure; and
any choices available to you regarding that disclosure.

You may withdraw your consent at any time, subject to legal or contractual restrictions.

Corporate Transactions

Merchant Growth may disclose Personal Information in connection with:

a merger;
acquisition;
financing;
participation or securitization transaction;
sale of assets;
corporate restructuring;
insolvency proceeding; or
other similar business transaction,

provided that appropriate confidentiality obligations are maintained and the recipient is required to protect Personal Information in a manner consistent with applicable law.

Legal and Regulatory Requirements

Merchant Growth may disclose Personal Information where required or permitted by law, including:

to comply with court orders, subpoenas or other legal processes;
to respond to lawful requests from regulators, law enforcement agencies or government authorities;
to comply with anti-money laundering, sanctions, tax or other regulatory obligations;
to investigate or prevent fraud, financial crime or other unlawful activity;
to establish, exercise or defend legal claims; or
where otherwise permitted or required by applicable law.

Protecting Rights and Security

Merchant Growth may disclose Personal Information where reasonably necessary to:

protect Merchant Growth, our customers or the public;
protect the security of our products, services or systems;
investigate suspected fraud or unauthorized activity;
enforce our agreements;
collect amounts owing;
protect our legal rights or property; or
prevent actual or suspected harm to individuals or property.

Artificial Intelligence Service Providers

Merchant Growth may use third-party providers of artificial intelligence and machine learning technologies to support internal business operations. These technologies may assist Merchant Growth with activities such as:

document review;
information summarization;
operational analysis;
fraud detection;
software development;
customer service support;
quality assurance;
regulatory compliance;
business reporting; and
internal productivity.

Merchant Growth requires AI service providers that process Personal Information on our behalf to maintain appropriate contractual privacy, confidentiality and security protections. Where commercially available and technically feasible, Merchant Growth configures AI services so that Personal Information is not used to train publicly available artificial intelligence models. Merchant Growth does not intentionally disclose Personal Information to publicly available generative artificial intelligence services for the purpose of training publicly available AI models.

De-Identified and Aggregated Information

Merchant Growth may create information that has been aggregated or de-identified so that it no longer identifies an individual. Merchant Growth may use and disclose such information for purposes including:

business analytics;
operational reporting;
statistical analysis;
product development;
underwriting model development;
artificial intelligence evaluation;
fraud prevention;
research;
service improvements; and
other lawful business purposes.

Information that has been de-identified or anonymized in accordance with applicable law is not considered Personal Information for the purposes of this Privacy Policy.

International Processing of Personal Information

Merchant Growth and our Service Providers may collect, access, store or process Personal Information in jurisdictions outside your province or territory of residence, including outside Canada. Merchant Growth conducts appropriate due diligence when selecting Service Providers that process Personal Information outside Canada.

As a result, Personal Information may be subject to the laws of those jurisdictions and may be accessible to courts, regulators, law enforcement agencies or national security authorities in accordance with applicable law.

Merchant Growth requires Service Providers that process Personal Information on our behalf to implement administrative, technical and organizational safeguards appropriate to the sensitivity of the Personal Information, regardless of where it is processed.

Retention of Personal Information

Merchant Growth retains Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable legal, regulatory, tax, accounting and operational requirements, resolve disputes and enforce our legal rights.

Retention periods vary depending on:

the nature of the Personal Information;
the purposes for which it was collected;
applicable legal or regulatory requirements;
contractual obligations; and
legitimate business needs.

When Personal Information is no longer required, Merchant Growth will securely delete, destroy or irreversibly anonymize the information using methods appropriate to the sensitivity of the information.

You should not assume that Personal Information will be deleted immediately following repayment of a financing product, closure of an account or withdrawal of an application.

Information Collected Through Our Site

When you visit our Site, Merchant Growth and our Service Providers may automatically collect certain technical information regarding your device and your interaction with our Site. This information may include:

Internet Protocol (IP) address;
browser type and version;
operating system;
device identifiers;
language preferences;
referring websites;
pages viewed;
links clicked;
date and time of visits;
session information;
diagnostic information; and
other information relating to your use of our Site.

We use this information to:

operate and maintain our Site;
authenticate users;
protect the security of our systems;
diagnose technical issues;
understand how visitors use our Site;
improve website performance and functionality;
detect fraud and unauthorized activity;
improve our products and services; and
comply with legal and regulatory obligations.

Unless combined with other information that identifies you, this technical information generally does not identify you personally.

Where you voluntarily provide Personal Information through online applications, contact forms, surveys or other communications, that information will be collected and used in accordance with this Privacy Policy.

Cookies and Similar Technologies

Merchant Growth and our Service Providers use cookies, pixels, web beacons, local storage and similar technologies to improve the operation, security and functionality of our Site. These technologies may be used to:

remember your preferences;
authenticate users;
maintain security;
personalize your experience;
analyze website traffic;
understand visitor behaviour;
measure the effectiveness of communications and advertising;
prevent fraud; and
improve our products and services.

Some cookies are necessary for the operation and security of the Site and cannot be disabled. Where required by applicable law, Merchant Growth will obtain your consent before using non-essential cookies or similar technologies. Most web browsers allow you to control or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality of portions of the Site.

Analytics and Advertising Technologies

Merchant Growth may use third-party analytics and advertising technologies to better understand how visitors interact with our Site and to improve our products, services and marketing activities. These technologies may collect information regarding your interactions with our Site and, in some cases, other websites or online services. Merchant Growth uses this information to:

evaluate website performance;
improve user experience;
measure the effectiveness of advertising campaigns;
better understand customer needs;
improve our products and services; and
support fraud prevention and security.

Where required by applicable law, Merchant Growth will obtain any required consent before deploying non-essential analytics or advertising technologies.

Merchant Growth does not disclose mobile telephone numbers, SMS/text messaging opt-in information or SMS/text messaging consent to advertising, analytics or marketing partners for their own marketing purposes.

Links to Third-Party Websites

Our Site may contain links to websites operated by third parties for your convenience. Merchant Growth does not control and is not responsible for the privacy practices, content or security of third-party websites. We encourage you to review the privacy policies of any third-party websites that you visit before providing Personal Information.

Social Media Features

Our Site may include social media features, plugins or widgets provided by third-party platforms. These features may collect information regarding your interaction with our Site and are governed by the privacy policies of the organizations providing those services. Merchant Growth is not responsible for the privacy practices of third-party social media platforms.

Security Safeguards

Merchant Growth maintains administrative, technical and physical safeguards designed to protect Personal Information against unauthorized access, collection, use, disclosure, modification, loss and destruction. Our safeguards include, where appropriate:

encryption of Personal Information in transit and at rest;
multi-factor authentication;
role-based access controls;
employee confidentiality obligations;
employee privacy and information security training;
cybersecurity monitoring;
security logging;
vulnerability management;
secure software development practices;
vendor due diligence;
contractual privacy and confidentiality obligations with Service Providers;
physical security controls; and
periodic review of our privacy and information security program.

Merchant Growth regularly reviews and updates its privacy and security practices to address evolving legal requirements, technological developments and emerging security risks.

Although no method of transmitting or storing information can be guaranteed to be completely secure, Merchant Growth uses safeguards appropriate to the sensitivity of the Personal Information under our control.

If Merchant Growth becomes aware of a breach of security involving Personal Information, we will investigate the matter promptly and respond in accordance with applicable law, including any required notifications to affected individuals and regulators.

Accuracy of Personal Information

Merchant Growth takes reasonable steps, appropriate to the purposes for which Personal Information is used, to ensure that such information is as accurate, complete and up to date as reasonably necessary. We encourage you to notify us promptly if your Personal Information changes or if you believe information we hold about you is inaccurate or incomplete.

Access, Correction and Your Privacy Rights

Subject to applicable law, you may request:

access to the Personal Information Merchant Growth holds about you;
correction of inaccurate or incomplete Personal Information;
information regarding how your Personal Information has been collected, used or disclosed;
withdrawal of your consent where processing is based on consent, subject to legal and contractual limitations;
information regarding Merchant Growth's use of automated decision-making technologies where required by applicable law; and
any other rights available under applicable privacy legislation.

Merchant Growth may request information necessary to verify your identity before responding to your request.

We will respond to requests within the timeframes required by applicable law.

Withdrawing Your Consent

You may withdraw your consent to the collection, use or disclosure of your Personal Information at any time by contacting Merchant Growth using the contact information provided below. Withdrawal of consent does not affect the lawfulness of processing that occurred before consent was withdrawn. Merchant Growth may continue to collect, use or disclose Personal Information where permitted or required by law, including where necessary to:

administer existing accounts;
comply with legal or regulatory obligations;
maintain the integrity of credit reporting systems;
detect or prevent fraud or other unlawful activity;
collect outstanding obligations; or
establish, exercise or defend legal claims.

If you withdraw consent for Personal Information that is necessary for Merchant Growth to provide products or services, we may no longer be able to provide those products or services.

Changes to this Privacy Policy

Merchant Growth may update this Privacy Policy from time to time to reflect changes in our business practices, technology, legal requirements or regulatory guidance. When material changes are made, Merchant Growth will publish an updated version of this Privacy Policy on our Site and update the Effective Date shown above.

Where required by applicable law, Merchant Growth will obtain your consent to material changes affecting the collection, use or disclosure of your Personal Information.

Your continued use of our products, services or Site following the effective date of an updated Privacy Policy signifies your acknowledgement of the revised Privacy Policy, except where applicable law requires additional consent.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, request access to or correction of your Personal Information, withdraw your consent where applicable, or have concerns regarding Merchant Growth's collection, use or disclosure of Personal Information, please contact us:

Merchant Growth Ltd.
200 – 171 Water St,
Vancouver, BC V6B 1A7

Telephone: (866) 240-3694

Email: clients@merchantgrowth.com

Privacy inquiries will be directed to the individual responsible for Merchant Growth's compliance with applicable privacy legislation.