Exclusive Wealth Capital

Effective Date: April 2026

1. Introduction

Exclusive Wealth Capital Inc. (“Exclusive Wealth Capital,” “Exclusive Wealth,” “we,” “us,” or “our”) respects the privacy of visitors to our website and the individuals with whom we interact in the course of our business. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information.

This Privacy Policy applies to personal information collected through this website and through our offline interactions with prospective and existing counterparties, investors, advisors, service providers, and other individuals.

2. Application of Canadian Privacy Law

We are committed to compliance with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Personal Information Protection Act (British Columbia) (“BC PIPA”), Canada’s Anti-Spam Legislation (“CASL”), and applicable provincial and international privacy laws.

3. Personal Information We Collect

We may collect the following categories of personal information:

• Identifying information — name, title, employer or affiliated organization, business or personal contact details (email address, telephone number, mailing address).
• Professional and financial information — investment experience, accreditation status, source of wealth and source of funds, regulatory and licensing status, beneficial-ownership information, and information required for know-your-client (“KYC”) and anti-money-laundering (“AML”) purposes.
• Communications — the content and metadata of inquiries, emails, calls, and meetings with us.
• Technical information — IP address, device identifiers, browser type, referring URL, pages viewed, time spent on the site, and similar information collected through cookies, web beacons, and analytics tools.
• Marketing preferences — subscription preferences and any consent or unsubscribe instructions.
  
  

We do not knowingly collect personal information from individuals under the age of majority in their jurisdiction.

4. How We Collect Personal Information

We collect personal information:

• Directly from you, when you submit an inquiry, register interest, attend a meeting, or correspond with us.
• From your employer, agent, advisor, or representative, where they interact with us on your behalf.
• From third-party service providers, including KYC/AML, sanctions screening, identity verification, and reference-check providers.
• Automatically, through cookies and analytics technologies, when you visit our website.
• From publicly available sources, where permitted by law.
  
  

5. Purposes for Which We Use Personal Information

We use personal information for the following purposes:

• Responding to inquiries and conducting initial counterparty suitability, eligibility, and strategic-fit reviews.
• Conducting KYC, AML, sanctions, and beneficial-ownership screening.
• Negotiating, executing, and administering mandates, transactions, financings, fund investments, and capital commitments.
• Communicating with counterparties, investors, advisors, and service providers.
• Operating, maintaining, securing, and improving our website and our business.
• Complying with applicable laws, regulations, and legal process, and responding to lawful requests from regulators, courts, and other authorities.
• Marketing our services to qualifying recipients in accordance with applicable law and your consent preferences.
• Establishing, exercising, or defending legal claims.
  
  

We rely primarily on consent as the basis for collecting, using, and disclosing personal information. In certain circumstances we may also rely on legal obligation, legitimate business interests, or other lawful bases permitted under applicable law.

6. Sharing and Disclosure

We may share personal information with:

• Our affiliates and personnel who require access for the purposes set out above.
• Our service providers, including legal, tax, accounting, audit, IT, hosting, analytics, KYC/AML, identity verification, and similar providers.
• Counterparties, co-investors, lenders, advisors, brokers, and other parties involved in a particular mandate, transaction, or relationship, subject to confidentiality undertakings.
• Regulators, government authorities, courts, and law-enforcement agencies, where required or permitted by law.
• A successor entity in connection with a merger, sale, financing, restructuring, or similar corporate transaction.
  
  

We do not sell personal information.

7. International Transfers and Storage

Personal information may be processed and stored in Canada and in other jurisdictions, including the United Kingdom, the European Economic Area, the United States, and any other jurisdiction in which we, our affiliates, or our service providers operate. While in another jurisdiction, personal information may be subject to the laws of that jurisdiction and accessible to courts, regulators, and law-enforcement authorities.

We take reasonable steps to ensure that personal information transferred to a third party for processing is subject to comparable privacy protections.

8. Cookies and Similar Technologies

Our website uses cookies, web beacons, and similar technologies to operate the site, remember preferences, analyze traffic, and improve user experience. You may disable cookies through your browser settings; however, certain features of the site may not function properly if cookies are disabled.

9. Commercial Electronic Messages

We comply with CASL when sending commercial electronic messages. Where required, we will obtain your express or implied consent before sending commercial electronic messages, identify ourselves as the sender, and provide an unsubscribe mechanism in each message. You may withdraw your consent to receive commercial electronic messages from us at any time using the unsubscribe mechanism in any such message or by contacting us as described below.

10. Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to comply with applicable legal, regulatory, audit, tax, and recordkeeping requirements, and to establish, exercise, or defend legal claims. Retention periods may extend beyond the conclusion of a relationship where required.

11. Security

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

12. Your Rights

Subject to applicable law, you may:

• Request access to the personal information we hold about you.
• Request correction of inaccurate or incomplete personal information.
• Withdraw your consent to our collection, use, or disclosure of your personal information, subject to legal and contractual restrictions and reasonable notice.
• Request information about our privacy practices.
• Make a complaint to our Privacy Officer or to a privacy regulator.
  
  

To exercise any of these rights, please contact our Privacy Officer using the contact details below. We may verify your identity before responding and may decline a request as permitted by law.

If you are dissatisfied with our response, you may make a complaint to the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or the Office of the Information and Privacy Commissioner for British Columbia (www.oipc.bc.ca).

13. Children’s Privacy

Our website and services are not directed at children, and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take reasonable steps to delete it.

14. Third-Party Websites

Our website may contain links to third-party websites. This Privacy Policy does not apply to those websites, and we are not responsible for their privacy practices.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The current version will be posted on our website with an updated effective date. Material changes may be communicated separately to active counterparties and investors.

16. Contact — Privacy Officer

Questions, complaints, or requests relating to this Privacy Policy or our handling of personal information should be directed to:

Privacy Officer

Exclusive Wealth Capital

355 Burrard St Suite #660,

Vancouver,

BC V6C 2G8

Email: info@exclusivewealth.com