Privacy Policy

Last updated: November 2025

This Privacy Policy explains how Valesbury Holdings Inc. (“Valesbury”, “we”, “us”, “our”) collects, uses, discloses, and protects personal information when you visit our website at valesbury.com or otherwise interact with us as a prospective partner, operator, or contact.

Valesbury is a governance-first technology holding company. We operate this website primarily for informational and relationship-building purposes; it is not a consumer platform and does not offer direct products to the general public.

1. Who we are and how to contact us

Valesbury Holdings Inc. is a company formed under the laws of Québec, Canada. For most processing activities covered by this Policy, Valesbury acts as a “controller” (or equivalent concept under applicable law), meaning we determine the purposes and means of processing your personal information.

If you have questions about this Policy or our handling of personal information, you can contact us through our Contact page.

2. Scope of this Policy

This Privacy Policy applies to:

• Visitors to our website at www.valesbury.com.
• Individuals who contact us by email or through any contact details presented on this site.
• Prospective partners, operators, and collaborators who engage with Valesbury in early-stage discussions.

This Policy does not apply to portfolio companies or products in which Valesbury holds an interest (for example, consumer applications or operating subsidiaries). Those businesses maintain their own privacy policies and terms, which govern the collection and use of personal information in connection with their services.

3. Personal information we collect

We collect only limited personal information, consistent with operating a corporate informational website and maintaining professional relationships.

3.1 Information you provide to us

We may receive personal information when you choose to contact us or otherwise interact with Valesbury, including:

• Identification and contact details – such as your name, email address, organization, role, and any other details you provide in communications.
• Relationship and context information – including the nature of your inquiry, your interests in partnering, investing, or collaborating, and any background you choose to share.
• Other information you volunteer – such as feedback, proposals, or attachments you send to us.

3.2 Information collected automatically

When you visit our website, we and our service providers may automatically collect certain technical information to operate the site securely and understand aggregate usage. This may include:

• Device and browser information – such as IP address, browser type and version, operating system, and basic device information.
• Usage data – such as pages visited, date and time of visit, referring URLs, and general interaction patterns.
• Security and log data – error logs, access logs, and other information necessary to detect and investigate unusual or potentially malicious activity.

We use this information to maintain and improve our website, for security, and to understand high-level interest in Valesbury’s activities.

3.3 Cookies and similar technologies

Our website may use cookies or similar technologies to maintain basic functionality and gather aggregate analytics, such as:

• Essential cookies – necessary for core site functionality and security.
• Preference or functional cookies – to remember basic settings where applicable.
• Analytics cookies – to understand aggregate visit patterns (for example, which pages are most viewed over time).

We do not use cookies for cross-site behavioural advertising or for building advertising profiles. You can usually configure your browser to refuse cookies or alert you when a cookie is being set. If you disable essential cookies, parts of the site may not work as intended.

4. How we use personal information

We only use personal information for limited, legitimate purposes consistent with operating a corporate holdings and governance-focused business. These purposes may include:

• Communications – responding to your inquiries, scheduling calls, and maintaining contact with you as a potential partner, operator, or collaborator.
• Relationship management – maintaining records of interactions to evaluate and manage potential or existing relationships.
• Website operation and improvement – operating, maintaining, securing, and improving our website.
• Analytics – understanding aggregate interest in Valesbury’s focus areas and content.
• Legal and compliance – complying with applicable laws, regulations, or requests from competent authorities, and enforcing our rights.

5. Legal bases for processing (where applicable)

For individuals in the European Union, United Kingdom, and other jurisdictions with similar laws, our processing of personal information may rely on one or more of the following legal bases:

• Legitimate interests – such as operating our website, responding to inquiries, maintaining relationships, ensuring security, and understanding usage, provided these interests are not overridden by your rights and freedoms.
• Consent – where you choose to provide information or opt into specific communications. You may withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
• Legal obligations – where we must process or retain information to comply with applicable laws or regulatory requirements.

6. How we share personal information

We do not sell personal information.

We may share personal information only in the following limited circumstances:

• Service providers – third parties that support our website hosting, email infrastructure, security, analytics, and related operations. These providers are engaged under contracts that require them to protect personal information and use it only to provide the contracted services.
• Professional advisors – lawyers, accountants, auditors, or other professional advisors, under appropriate confidentiality obligations.
• Corporate transactions – in connection with a potential or completed merger, acquisition, reorganization, or other business transaction involving Valesbury. If such a transaction occurs, any successor entity will be required to handle personal information in a manner consistent with this Policy or provide appropriate notice and choices.
• Legal and regulatory requirements – where we believe in good faith that disclosure is reasonably necessary to comply with a legal obligation, respond to legal process or requests from authorities, or protect the rights, property, or safety of Valesbury, our stakeholders, or others.

7. International data transfers

Valesbury is based in Canada, and our website may be hosted or supported by providers located in other jurisdictions, such as the United States or the European Union. This means your personal information may be transferred to and processed in countries that may have different data protection laws than those in your home jurisdiction.

Where required by law, we implement appropriate safeguards for international transfers, such as Standard Contractual Clauses or equivalent mechanisms, and assess the level of protection afforded to personal information in the destination country.

8. Data security

We use reasonable and appropriate technical and organizational measures to protect personal information against loss, misuse, and unauthorized access, including encryption in transit, restricted access, and security monitoring appropriate for a corporate informational website.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we work to safeguard personal information, we cannot guarantee absolute security.

9. Data retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy or as required by law. In practice, this generally means:

• Contact and correspondence records – kept for as long as the relationship or discussion remains relevant, and for a reasonable period thereafter for reference and record-keeping, unless you request deletion and no legal obligation requires retention.
• Technical logs and security records – kept for a limited period (for example, several months) to monitor for security issues and maintain system integrity.
• Regulatory and legal records – retained as required by applicable laws, such as corporate or tax regulations.

10. Your rights and choices

Depending on applicable law and your location, you may have rights in relation to your personal information. These may include:

• The right to request access to personal information we hold about you.
• The right to request correction of inaccurate or incomplete personal information.
• The right to request deletion of personal information, in appropriate circumstances.
• The right to object to or request restriction of certain types of processing.
• The right to withdraw consent where processing is based on consent.
• The right to data portability, where provided by law and technically feasible.

To exercise these rights, please use our Contact page. We may need to verify your identity before responding. In some cases, we may be unable to fully comply with your request (for example, if we are required to retain certain information for legal, regulatory, or security reasons), but we will explain our reasoning where permitted by law.

If you are located in a jurisdiction that provides a right to complain to a data protection authority, you may also have the right to contact that authority if you are dissatisfied with our handling of your personal information.

11. Children’s privacy

This website is intended for adults in a professional or business context. It is not directed to children, and we do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take appropriate steps to delete it.

12. Links to other websites

Our website may contain links to websites or content provided by third parties. We are not responsible for the privacy practices or content of those third-party sites. We encourage you to review the privacy policies of any site you visit.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the law, or our operations. When we do, we will update the “Last updated” date at the top of this page.

Where required by law, we will provide additional notice of significant changes (for example, via a prominent notice on our website). Your continued use of this site after changes take effect indicates your acceptance of the updated Policy.

14. Contact

If you have any questions or requests concerning this Privacy Policy or our handling of personal information, please use our Contact page.