Privacy Policy

How Subtrade Capital Corp. handles personal information.

Draft — pending CCO review. This page is a working draft for Subtrade Capital Corp. It is not final legal advice. Richard Clark (Chief Compliance Officer) must review and approve before this is treated as the operative privacy policy. Alberta PIPA and CASL compliance remain open.

Overview

What this draft covers.

Subtrade Capital Corp. (“Subtrade,” “we,” “us”) collects personal and business information when you use this website, submit an application or inquiry, or deal with us as a borrower, guarantor, referral partner, or other counterparty.

This draft describes, in plain language, what we collect, why we use it, and who we may share it with. It will be finalized after CCO review.

Information we collect

  • Contact details (name, title, company, email, phone)
  • Application and deal information (project, location, bonded status, holdback amounts, invoice standing, revenue band, GSA status, and related descriptions)
  • Referral and partner details you provide
  • Technical data typical of website use (for example IP address, browser type, and pages visited), if and when analytics are enabled

How we use it

  • To assess eligibility and underwrite holdback advances
  • To contact you about your inquiry or application
  • To document security, servicing, and repayment
  • To operate, secure, and improve this website
  • To meet legal, regulatory, and audit obligations

Disclosure to third parties

We may disclose information, as needed to assess or fund a request, to:

  • Funding partners and warehouse or capital providers
  • Insurers and sureties (where relevant to a file)
  • Professional advisers (legal, accounting, compliance)
  • Service providers who process data on our behalf (for example hosting or form delivery)

We do not sell personal information.

Consent and contact

Where required, we rely on consent you provide (including through our application form) and on other lawful bases under applicable Alberta privacy law. Electronic marketing, if any, will be handled consistent with CASL once that program is defined.

To ask about access, correction, or this draft policy, use the Apply form and mark your message as a privacy request. A public privacy contact email will be published once confirmed.

Retention and security

We retain information as needed for underwriting, servicing, legal, and record-keeping purposes, then dispose of it in a secure manner. We use reasonable administrative and technical safeguards; no method of transmission or storage is perfectly secure.

Last updated: September 18, 2026 (draft). Status: pending CCO review.