#Privacy policy

Last update: October 9, 2025

##Definitions

In this Privacy Policy of Innovations Laylah inc ("Laylah"), the company operating (i) the website available at the following address: www.laylah.ca; (ii) the User Center Application; and (iii) the Platform.

The User Center Application is an application for Consumers created and marketed by Laylah to facilitate communications with their Advisors using the Platform.

The Platform is an application for financial advisers, created and marketed by Laylah.

Personal Information refers to information that allows a person to be identified, directly or indirectly. This excludes Business Contact Information, except where privacy laws deem such information to be Personal Information. De-identified information within the meaning of the law is not Personal Information.

Business Contact Information is information relating to the performance of a function within an organization, such as an individual's name, title and function, as well as the address, e-mail address and telephone number of the individual's place of work. By "the performance of a function", we mean that this information must have been collected, used or disclosed for the purpose of communicating with the individual in the course of his or her employment, business or profession.

Customer means a customer of Laylah who is a business or other organization and who is not a Consumer. An End User is an employee of Laylah's Customer, including but not limited to an Advisor.

Consumer means the individual whose data is uploaded or entered on (i) the Platform by the End User; or (ii) by the Consumer himself via the User Center Application.

Advisor(s) means professionals, persons or companies in the financial sector, including in particular your financial security advisor(s), mutual fund representative(s), portfolio/wealth manager(s) and/or members of their team(s).

Customer Personal Information means Personal Information entrusted to Laylah by the Customer and may include Personal Information of the Customer's End Users in connection with the Platform and/or Personal Information of Consumers uploaded or entered into the User Center Application by such Consumer. Such information may include, but is not limited to: name, postal address, email address, date of birth, gender, telephone number, insurance policy information, completed transactions including investment information and other related documents.

End User means an employee of Laylah's Customer who directly uses the Platform or who shares documents, messages, contracts to be signed, forms to be filled in or other information via the User Center Application as part of his work.

##Scope and application

This Policy applies to Laylah Customers, to End Users and, where applicable, to Consumers. It also applies to Customer Personal Information that has been entrusted to Laylah for the purpose of providing contracted services, including Customer Personal Information in the possession of Laylah's service providers. If you are a Consumer as defined in this Policy, please carefully read the following section: "Our Commitments to Consumers". We also recommend that you read the Privacy Policy of the Customer with whom you do business directly.

Laylah's employees, subcontractors and agents must comply with the Privacy Policy if they have access to Personal Information or Customer Personal Information in the course of their duties.

##Privacy Program

In order to protect Personal Information, including Customer Personal Information, we have implemented policies, practices and procedures relating to the management of Personal Information in our possession or custody.

These internal policies and procedures govern the collection, use, disclosure, retention and destruction of Personal Information, as well as the handling of complaints, information security and data governance. These policies and practices also set out the framework for implementing privacy impact assessments, and for preventing and responding to potential privacy incidents. All these policies and practices have been approved by our Privacy Officer.

The collection of (i) Customer Personal Information through our Platform; or (ii) Consumer Personal Information through the User Center Application or website, complies with the requirements of this program.

Privacy Officer

Laylah's senior management has delegated the management of the privacy program to the Privacy Officer. The duties of the Privacy Officer are to internally manage and monitor Laylah's privacy program.

It is the Privacy Officer who approves and implements the privacy policies and procedures, ensures their proper functioning and reports to Laylah's senior management on the effectiveness of the program.

The Privacy Officer is also responsible for providing the necessary support in the event of a question, complaint or request relating to the protection of Personal Information. For more information, please consult the "Contact us" section.

##Consent

With regard to the use of the Platform, Laylah does not have any direct business relationship with Consumers. For this reason, we require that our Customers and End Users ensure that they have obtained all mandatory consents from Consumers. This requirement also applies to the Personal Information of minors, which may be entered on the Platform. In particular, Consumers should have consented to their Personal Information, and that of their dependent children, being managed by Laylah in accordance with this Privacy Policy.

We also require our Customers to provide legally required notices to End Users and Consumers and to ensure that the use, collection or communication of Personal Information between Laylah and the Customer is authorized.

In connection with the use of the User Center Application or the Website, we obtain the Personal Information we need directly from you for example, when you create an account, use our services or communicate with us. Your Personal Information may also be collected via cookies as permitted by law or if we have obtained the necessary consent.

##Collection and use

Laylah obtains ownership of the Customer's Personal Information when the Customer imports End User and Consumer data into the Platform. In parallel, data import may also result in the collection of Personal Information for Laylah for specific purposes, listed below, including when Consumers create an account to use the User Center Application or when communicating with Laylah via the website.

When we develop and improve our products, we make sure to limit the fields of collection of Personal Information to what is strictly necessary for the execution of our contracts, to allow the Customer to achieve its objectives and when applicable to Consumers, to properly use the User Center Application.

Similarly, we require our Customers to limit the sharing of Personal Information to that which is necessary to achieve their purposes when using the Platform.

The following are the purposes for which Laylah collects and uses Personal Information and Customer Personal Information to provide its Services:

  • To establish and maintain a commercial relationship with our Customers;
  • To consolidate the Customer's or End-User's Personal Information scattered over several accounts in the Platform via data sources and integrations selected by the Customer or End-User;
  • To develop, improve, promote or supply products and services to our Customers, including for diagnosing technical problems or improving functionality;
  • To investigate and resolve incidents;
  • To support our Customers in requests to exercise the rights of End Users or Consumers or to resolve disputes;
  • For any other purpose permitted by law, in particular to respond to requests from police authorities or governments.

Laylah collects and uses Personal Information for the following purposes:

  • To maintain and improve the operation and security of the Website, Platform and User Center Application;
  • To validate the creation and authentication of an account when a Consumer connects to the User Center Application;
  • To enable Consumers to communicate with their Advisors via the User Center Application;
  • To collect and respond to Consumers' comments and requests in connection with the Website and the User Center Application;
  • To meet contractual, legal and regulatory requirements;
  • For research and statistical purposes;
  • To manage and administer the Customer's user account;
  • To contact you if you use our online forms;
  • To prevent and detect suspicious or fraudulent activities or activities in breach of our terms of use;
  • To investigate and resolve incidents;
  • For any other purpose permitted by law, in particular to respond to requests from law enforcement authorities or governments.

In the event that the Consumer, the End-User or the Customer refuses to provide the information necessary to open and administer his or her user or customer account or withdraws his or her consent to the use or disclosure of his or her Personal Information or the Customer's Personal Information, Laylah may be unable to provide the Consumer, End-User or Customer with the products and services subscribed to and may be obliged to terminate its relationship with the Consumer with respect to the use of the User Center Application or its relationship business with the Customer or End-User with respect to the use of the Platform. You may contact us as indicated in the section "Contact us" to submit any request in this regard.

##Communication and transfer of personal information

Laylah only discloses or transfers Personal Information where required or permitted by the Customer Agreement (i.e. Customer Personal Information) or otherwise required or permitted by applicable law.

Laylah may from time to time need to share Personal Information with its subcontractors or agents to help us make available all the features and functionalities of our Platform, User Center Application and website (maintenance, analysis, legal requirement, fraud detection, marketing and development). They will only have access to Personal Information that is necessary to perform these tasks on our behalf and they are required not to disclose or use it for any other purpose.

Please note that these subcontractors or agents may be located in Canada or in other jurisdictions or countries. Please be aware that we have contractual agreements with these subcontractors to ensure the security of the data we entrust to them and that we conduct privacy impact assessments before disclosing any Personal Information outside the province of Quebec. Although the Personal Information we transmit is protected by appropriate security measures, Personal Information may be made available to foreign government agencies under applicable laws. If you have any further questions on this subject, please contact us.

##Conservation

Laylah has established retention periods for Personal Information in its custody. Laylah will not retain Personal Information longer than is necessary or relevant for the identified purposes, unless otherwise required by contracts entered into with the Customer in connection with the use of the Platform or by legal or regulatory requirements. Once these periods have expired, Laylah will return or destroy the Personal Information in accordance with applicable laws and where applicable, the contract with the Customer for the use of the Platform, and/or its internal policies for the management of Personal Information.

##Safety measures

Laylah makes the security of the Personal Information it collects, uses and maintains a priority. Accordingly, Laylah ensures that security safeguards appropriate to the sensitivity of the data are in place to protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction.

To the extent possible and applicable within the scope of our services, Laylah implements, maintains and monitors technical and administrative measures to help protect the security, integrity, availability and confidentiality of the Personal Information we collect or have in our custody.

##Accuracy

Laylah relies on (i) the Consumer with respect to the User Center Application or the Website; and (ii) the Customer and the End-User with respect to the Platform, to ensure the ongoing accuracy of the Personal Information that Laylah collects, uses and retains for the aforementioned purposes.

##Incident management

Laylah's Privacy Program includes incident detection and response practices and procedures designed to facilitate prompt reporting to the Consumer where applicable and to the Customer of incidents involving Personal Information.

With respect to the Platform, since the Customer's Personal Information belongs to the Customer, the Customer is generally responsible for the management and follow-up of security or privacy incidents with Consumers. In accordance with the contracts entered into with the Customer in relation to the use of the Platform, Laylah will provide reasonable assistance to support Customers in investigating the incident and complying with their obligations, for example in relation to notifications to affected individuals (including End Users and Consumers) and reporting the incident to the relevant privacy commissioners or other relevant parties.

##Access to information and similar rights

With respect to the Platform, Laylah does not in any way have a direct business relationship with the Consumer, Laylah will therefore generally refer requests for access to information, correction of Personal Information or other such requests from End Users or Consumers to the Customer, unless Laylah has contractually agreed to do so with the Customer, as part of its provision of services for the use of the Platform.

##Our commitments to Consumers

This section describes Laylah's Personal Information management practices when the Consumer ("you", "your") does business with one of our Customers who uses the Platform and uploads your data or when you use the User Center Application. This section also applies to visits to our website.

Please note that your visit to and use of our website, our Platform and the User Center Application are also governed by their applicable terms of use.

Transparency

Transparency about our Personal Information management practices is an integral part of our Privacy Program.

This Privacy Policy attempts to inform you as much as possible about the management practices of your Personal Information entrusted to us by our Customers when your data is imported into the Laylah Platform or by you directly when you use the User Center Application or our website. All Personal Information contained in the Platform and/or the Customer Space Application, whether yours or your dependent child's, may be collected, used and stored by Laylah to fulfill its contractual obligations and the purposes listed above.

Our Privacy Officer has been specifically appointed to help you with any privacy-related questions you may have.

Accountability

We assume our responsibilities under applicable law. With regard to the use of the Platform, our, accountability is limited to the services we provide directly to our Customers. Brokerage firms, brokers and other companies that retain our services remain accountable by law for the management of your Personal Information. We strongly recommend that you also read their privacy policy.

Limitation

When developing and updating our products, we always keep in mind our objective of reducing to a strict minimum the collection and use of your Personal Information for the operation and management of our Platform and/or, where applicable, our User Center Application or our website.

Similarly, if it is possible for us to use de-identified or anonymised information to achieve the purposes listed above, we will favour these methods.

We only keep your Personal Information for as long as a profile in your name is open and active on the Platform or the User Center Application. Upon deletion of your profile directly by you on the User Center Application or by our Customer on the Platform, Laylah will destroy your Personal Information, subject to retention periods imposed by its contracts, internal policies and applicable laws.

Security

We are aware of our role as custodian of your Personal Information and that of your dependent children and for this reason we attempt to implement the best reasonable security measures to maintain the security, integrity, availability and confidentiality of our Platform, the User Center Application and our website.

Access to Personal Information

For the User Center Application, you may at any time (i) access your profile and view your Personal Information; or (ii) directly modify or correct your Personal Information. On the Platform, Customers can access your profile and view your Personal Information at any time. It is also possible for them to modify or rectify this Personal Information, following a request from you. In the event that it is impossible for (i) you to use the User Center Application; or (ii) our Customers to modify certain Personal Information themselves or to consult it via the account, please contact our Privacy Officer.

##Cookies and other similar technologies

Our Website, User Center Application and Platform allow us to collect information about visitors and users through certain tracking technologies, such as cookies and pixels. This information may include, but is not limited to: IP address, web browser, operating system, click streams.

Connection cookies

Cookies are small data files that are commonly stored on your device when you use websites and online services. They are used for the efficient operation of websites and can provide information and help personalize services. Laylah collects Personal Information provided by cookies.

Pixels

Web beacons are tiny images that we can place in our web pages or emails. They can be used, for example, to anonymously obtain the number of times a particular page has been visited by an Internet user. As their name suggests, web beacons are invisible and any part of our sites, including the advertising messages displayed on them, may contain web beacons. Unlike cookies, invisible pixels are not placed on your computer.

Connection indicators and pixels

Laylah uses different types of cookies (collectively referred to as cookies here):

  • Performance and functionality cookies: These cookies help to personalise and improve the user experience. For example, they may remember your preferences so you don't have to re-enter information more than once, or they may remember your login details so you don't have to re-enter them each time you use the site. They enable us to understand your behaviour in order to improve our services and our sites.
  • Cookies for security purposes: These cookies help protect your accounts from unauthorised users. They help maintain session integrity and provide enhanced security, blocking unauthorized attempts to access your account.

Laylah mainly uses 2 types of cookies:

  • Session cookie: This cookie is stored for the duration of your visit to our sites, after which it is deleted from your device. It identifies you and is then deleted when you leave our sites.
  • Persistent cookies: This cookie is stored on your device until it expires and will be retrieved the next time you visit our sites. Our persistent cookies last for thirty (30) days.

Please note that the use of cookies only identifies you as a user and does not recognise you in any other way.

Deactivating cookies

You can prevent the personalisation functions of our sites by disabling cookies on your browser. You can do this by changing the settings on your browser or mobile device.

However, if you decide to refuse cookies, certain pages or sections of our sites may not be displayed correctly or certain functions may not be available.

Links to websites

It is important to understand that this Privacy Policy does not apply to other third-party websites that may be accessed through links on our sites. We are in no way responsible for these third-party sites, their content or access to them. Consequently, any Personal Information that you transmit via these sites is subject to their privacy policies. It is your responsibility to read these policies to ensure the protection of your Personal Information.

##Contact us

Our Privacy Officer is available to answer any questions, requests or complaints regarding Laylah's privacy practices. Here is his contact information:

Privacy Officer Innovations Laylah inc. 401-1400 Maguire Ave. Quebec City, QC, G1T 1Z3 privacy@laylah.ca

If you are a Consumer, Laylah may direct your request to its Customer, if that is more appropriate (i.e. as part of your business relationship with your Advisor(s) and in connection with the use of the Platform).

In the event of a complaint about this Privacy Policy, our Privacy Officer will investigate the complaint and inform the complainant of the procedure to be followed. If the complaint is justified, the particular situation will be corrected and the complainant will be informed.

Laylah would like you to know that we are committed to responding promptly and accurately to all your questions and concerns about the privacy and security of Personal Information, as well as our privacy policies and practices.

Changes to this privacy policy

We revise this Policy from time to time to comply with applicable laws and our operations. If we update this Policy in a material way, we will notify you by sending you a notice either on our Platform, our Site, our User Center Application or by e-mail. However, in all other circumstances, the publication of a new version of the Policy on our Site or your continued use of the Site, the User Center Application or the Platform will suffice as notice and consent to the Policy changes.

##SCHEDULE A. CONSENT FORM TEMPLATE

Last update : [Date]

Financial advisor’s full name: [Name]

The purpose of this Consent Form (the "Form") is to obtain your consent for the financial advisor identified in the document to collect your Personal Information in connection with their use of Laylah. Laylah may then collect, process and store your Personal Information in accordance with the financial advisor’s instructions. We ask you to read this Form carefully in order to give your informed consent where appropriate.

If you do not consent to this Policy, your financial advisor will not be able to use Laylah as a decision support tool to establish your financial profile.

For more information about your Personal Information, how it is collected, how it is used, which third parties may have access to it, how it is stored, what security measures are in place or your rights, we invite you to consult our Privacy Policy before giving your consent.

PERSONAL INFORMATION COLLECTED, PROCESSED AND STORED

As otherwise more specifically described in our Privacy Policy, your financial advisor will be able to use your Personal Information in connection with his or her use of the Laylah solution.

This includes, but is not limited to, information collected during your meetings with your advisor such as your name, date of birth, language, e-mail address and telephone number, as well as information about your assets and liabilities.

YOUR CONSENT

By accepting this Consent Form, I indicate that :

  • I understand and agree that Laylah, through my financial advisor, may collect, use, communicate and store my Personal Information, including information concerning my identity, financial situation and financial history or concerning my personal situation, in order to provide my financial advisor with access to Laylah and its functionalities for wealth advising.
  • I understand that refusal to provide my consent will result in my financial advisor not being able to use the Laylah solution during my appointment, to assist him/her in his/her decision making.
  • I understand that the collection, use and disclosure of my Personal Information will be made in accordance with Laylah’s Privacy Policy which I have had the opportunity to review and understand.
  • More specifically, I understand and agree that :
    • Laylah will use my Personal Information for the following purposes:
      • To give financial advisors access to the Laylah solution, and otherwise enable them to use it as a wealth planning tool.
      • To identify and authenticate myself in order to manage my file, if applicable.
      • With my explicit consent, for any other purpose compatible with the use of the Laylah solution by my financial advisor.
      • Following the depersonalization of my Personal Information for the following purposes :
        • For product development purposes;
        • For verification of service quality;
        • To improve marketing materials; and
        • To manage services rendered and customer relations;
        • For data analysis purposes, including combining it with other information that may relate to me, but which does not directly identify me because it is de-identified (for example, to understand and demonstrate the use and usefulness of the solution);
        • And for the purposes of creating reports that are depersonalized, aggregated in a way that does not allow me to be identified, or anonymized.
    • Laylah will never disclose my Personal Information to a third party without my express consent, except as provided by applicable laws and Laylah’s Privacy Policy;
    • Laylah may store my Personal Information in jurisdictions other than my province, territory or country of residence, including in Canada, the United States and the province of Quebec.
    • I understand that I may exercise all of my rights under applicable law, including requesting access to my file if it exists or making a request to rectify any Personal Information contained therein, by contacting Laylah as provided in the Privacy Policy.

I understand that this consent is valid for the duration of my relationship with my financial advisor and that I may withdraw it at any time by contacting my financial advisor or Laylah directly as provided in the Privacy Policy.

I have read and understand this Consent Form and consent to the collection, use, disclosure and storage of my Personal Information by Laylah in connection with my financial advisor’s use of Laylah.

Signature : [Signature space]

Name : [Firstname & Lastname]

Date : [Date]