1. INTRODUCTION AND SCOPE

ESTEPONA CAPITAL INC. ("Company", "we", "us" or "our") is committed to protecting the privacy and confidentiality of your personal information. This Privacy Policy ("Policy") describes how we collect, use, disclose, store and protect personal information when you visit our website, engage our services, submit an application or otherwise interact with us. This Policy applies to all personal information collected by the Company. By using our website or services, you consent to the practices described herein.

2. INFORMATION WE COLLECT

We collect personal information that you voluntarily provide, including but not limited to: name, contact information (email, telephone, postal address), financial information where relevant to services, employment information when you submit an application, and communications with us. We may also collect technical data such as IP address, browser type, device type and pages visited.

3. PURPOSE AND LEGAL BASIS

We process personal information for: providing and improving our services; responding to enquiries; processing applications; complying with legal and regulatory obligations (including KYC/AML); managing risk and security; and communicating with you. Processing is based on consent, contractual necessity, legal obligation or legitimate interests as permitted by applicable data protection law.

4. DISCLOSURE OF INFORMATION

We may disclose personal information to: service providers who assist in our operations (e.g. hosting, communication); regulatory or legal authorities when required by law; and other parties with your consent. We do not sell, rent or trade personal information to third parties for their marketing purposes.

5. DATA RETENTION

We retain personal information only as long as necessary for the purposes described in this Policy or as required by applicable law. When information is no longer needed, it is securely deleted, destroyed or anonymised.

6. SECURITY MEASURES

We implement appropriate technical, administrative and physical safeguards to protect personal information against unauthorised access, alteration, disclosure or destruction. No method of transmission over the Internet is fully secure; we cannot guarantee absolute security.

7. YOUR RIGHTS

Depending on your jurisdiction, you may have rights to: access, correct, delete or restrict processing of your personal data; data portability; object to processing; withdraw consent; and lodge a complaint with a supervisory authority. To exercise these rights, please contact us using the details below. We will respond within the timeframes required by applicable law.

8. COOKIES AND TRACKING

Our website may use cookies and similar technologies for essential functionality, analytics and to improve user experience. You may manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

9. INTERNATIONAL TRANSFERS

We operate in Canada, the United States and Australia. Your information may be transferred to and processed in these jurisdictions. We implement appropriate safeguards for cross-border transfers as required by applicable law.

10. CHILDREN'S PRIVACY

Our website and services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us immediately.

11. CHANGES TO THIS POLICY

We may update this Policy from time to time. Material changes will be posted on this page with an updated "Last Updated" date. Your continued use after such changes constitutes acceptance of the revised Policy.

12. CONTACT

For privacy-related enquiries or to exercise your rights, contact us at: ESTEPONA CAPITAL INC., Email: info@estepona.ca, or via our contact form.