Privacy Notice (pre-launch)

1. Who we are

STATEREUM FINANCE LTD. (“STATEREUM”, “we”, “us” or “our”) is responsible for the collection, use, disclosure and protection of personal information under its control, as described in this Privacy Notice.

Corporate details

• Corporate number: 1001717826
• Address: 2544 Weston Road, Unit 937, North York, Ontario, M9N 2A6, Canada
• Website: statereum.io
• Privacy Officer contact: dpo@statereum.io

This Notice applies to personal information that we collect in connection with pre-launch marketing and promotion of STATEREUM’s planned platform. The platform and its services are not currently available. The website interface is made available solely for informational and demonstration purposes and does not enable persons or entities in Canada to access, open, fund, or use the service. This Notice describes our current marketing-related processing only.

2. Information we collect

Depending on how you interact with us, we may collect:

• your name;
• email address, telephone number and other electronic contact details;
• country, province or territory, language preference and other location or preference information you provide;
• company name, job title, professional role and business contact details;
• information in your enquiry, correspondence, survey response or other message to us;
• marketing preferences and evidence of consent or withdrawal of consent, including the date and time, source and version of the consent request, choices made, and the minimum technical information reasonably necessary to demonstrate compliance; and
• online identifiers and online activity information, such as IP address, cookie or device identifiers, browser and device information, advertising identifiers, pages viewed, referral source, interactions with our advertisements, and email-delivery, opening and click information, where you permit the relevant technology or where permitted by law.

We may collect this information directly from you through our website, waitlist, contact forms, newsletters, surveys, events, calls, emails, text messages, instant-messaging or social-media channels, or advertisements and lead forms on third-party platforms. We may also receive business-contact information from your organisation, professional or business networks, publicly available sources, referral sources, and marketing platforms, where permitted by applicable law. You may request information about the source of personal information that we collected from another enterprise.

We do not knowingly collect personal information from persons under 18. Our marketing is not directed to persons under 18. If you believe that a person under 18 has provided us with personal information, please contact us.

3. Marketing purposes and consent

We collect, use and disclose your personal information only for marketing purposes, namely to plan, create, measure, deliver and improve marketing and promotional communications about STATEREUM and the future launch, development, availability, features, content, events, news, education, offers and updates relating to our planned platform.

Marketing may be delivered through email, SMS or other text messages, telephone, instant messaging, social-media messages, postal mail, online and social-media advertising, retargeting, push notifications, in-product messages if and when available, or any other legally permitted communication channel.

We obtain consent where required by applicable privacy law. For commercial electronic messages, including marketing emails and text messages, we will seek express consent unless another basis is permitted under Canada’s Anti-Spam Legislation (CASL). A request for consent will clearly identify STATEREUM, describe the purpose of the consent, provide contact information and explain how consent may be withdrawn.

You may refuse the optional consent described below and still submit a general enquiry or join the waitlist. We will not make your access to those pre-launch interactions conditional on consent to optional marketing disclosures.

4. Marketing service providers

We may disclose the minimum personal information necessary to service providers that process it to support our marketing activities. These categories include:

• website, hosting, form, consent-management and technical-support providers;
• customer relationship management, contact-database and marketing-automation providers;
• email, SMS, push-notification, telephone and messaging service providers;
• advertising, social-media, campaign-management, audience-management, measurement and retargeting platforms;
• analytics, attribution, survey and customer-insight providers; and
• marketing, creative, communications and event agencies.

Personal information is currently processed in Canada. We will update this Notice before making any material change to these processing arrangements.

We do not sell personal information or disclose it to independent third parties for their own marketing.

5. Cookies, pixels and similar technologies

We and our marketing service providers may use cookies, pixels, software development kits, web beacons and similar technologies on our website, in advertisements and in marketing messages. These technologies may collect the online identifiers and activity information described in Section 2.

We use these technologies only for marketing purposes: to operate and measure marketing forms and campaigns; understand audience engagement; limit the repetition of advertising; measure conversions; build or use marketing audiences; deliver or measure interest-based advertising; and assess and improve our marketing communications.

We will provide a consent-management mechanism for non-essential cookies and similar technologies. You can refuse or withdraw consent for non-essential technologies through cookie preferences, where available. Essential technologies used strictly to provide the website or record your privacy choices may remain active where permitted by law. We will provide additional information in the cookie banner or settings tool about the technologies, providers and retention periods in use.

6. Your choices

Marketing communications. You may withdraw your consent to marketing at any time. For email marketing, you may reply to any marketing email with the word “Unsubscribe” or send an email to dpo@statereum.io with the subject line “Unsubscribe”. For text-message marketing, you may reply “STOP” or use the opt-out instruction in the message. For telephone marketing, you may tell the caller that you do not wish to receive further marketing calls or contact dpo@statereum.io. We will give effect to a CASL unsubscribe request without delay and no later than 10 business days after it is sent.

Every commercial electronic message that we send will identify STATEREUM, provide valid contact information and state the relevant unsubscribe instruction. The electronic address used for an unsubscribe request will remain valid for at least 60 days after the message is sent.

Cookies and interest-based advertising. You may withdraw consent through cookie preferences, where available, and may also use the relevant browser or device settings. Withdrawing cookie consent will not automatically unsubscribe you from emails or other marketing communications.

7. Retention and security

We retain marketing contact information for 24 months after the date we obtain consent or, if later, your last meaningful marketing interaction with us, unless you withdraw consent earlier or a longer period is required or permitted by law. At the end of that period, we will delete or de-identify the information, or seek a new consent where appropriate.

We retain a minimal suppression record — such as your email address, telephone number and the fact and date of your opt-out — for as long as reasonably necessary to honour your request, prevent further marketing and demonstrate compliance. We periodically review suppression records and securely delete or de-identify them when no longer needed.

We retain evidence of consent and compliance activity for at least three years after the last relevant marketing communication or withdrawal of consent, unless a longer retention period is necessary in connection with a legal claim, investigation or legal obligation.

We use safeguards appropriate to the sensitivity of the information, including access controls, contractual confidentiality requirements and measures designed to protect personal information from loss, theft and unauthorised access, use, disclosure, copying, modification or disposal.

8. Access, correction and complaints

Subject to applicable law and limited exceptions, you may request access to, or correction of, personal information that we hold about you. You may also withdraw consent as described in Section 6. To make a request, ask a question or submit a privacy complaint, contact our Privacy Officer at dpo@statereum.io. We may request information necessary to verify your identity before responding.

For requests governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), we will respond with due diligence and ordinarily no later than 30 days after receiving a request, subject to any lawful extension. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada or, where applicable, the relevant provincial privacy regulator.

Québec residents may have additional rights under Québec privacy law. In particular, they may request access to and rectification of their personal information and, where the statutory conditions are met, cessation of dissemination or de-indexing. The contact information of STATEREUM’s person in charge of the protection of personal information is set out in Section 1.

9. Legal information and updates

This Notice is intended to comply with applicable Canadian privacy law, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and, where applicable, provincial privacy legislation. For Québec, the Act respecting the protection of personal information in the private sector applies to relevant activities.

We may amend this Notice to reflect changes to our marketing practices, technology, service providers or legal obligations. We will publish the updated Notice at statereum.io and revise the effective date. Where required, we will provide additional notice or obtain consent before a material change takes effect.