Privacy Notice

Last updated October 1st, 2025

Notice Statement

The Company is committed to respecting your privacy and protecting your Personal Data, which is why we have implemented a privacy program and appointed a Privacy Officer.

The purpose of this Policy is to inform you of how the Company collects, uses, discloses, retain, manage, share and protect your Personal Data, and how You can exercise your rights with respect to your Personal Data or contact us if you have queries about Our management of your Personal Data.  

To provide you with a quality Service, we need to have access to certain Personal Data about you. We make sure that our employees manage this information with all the necessary discretion and diligence in compliance with the legal and regulatory requirements in force.

By downloading or using the Application or the Service, by accessing the Website or submitting Personal Data to Us, You accept the terms of this Notice, and consent to our collection, use, disclosure, communication, retention, and management of your Personal Data as described in this Policy.

Interpretation and Definitions

For the purposes of this Notice, the words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural:

Account means a unique account created for You to access our Service or parts of our Service.

Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

Application refers to the Solfium application provided by the Company.

Company (referred to as either the "Company", "We", "Us" or "Our" in this Notice) refers to Solfium Inc., a Canadian corporation with an address 2200 – 1250 René-Lévesque Boulevard West, Montreal, QC, H3B 4W8. 

Device means any device that can access the Application or Website, such as a computer, a cellphone or a digital tablet.

Notice means this Privacy Notice, as modified from time to time in accordance with its terms.

Personal Data means any information about an identifiable individual, or information that, taken alone or combined with other data, allows an individual to be identified.

Privacy Officer means the individual appointed by the Company’s senior management to manage the Company’s privacy compliance program, as further described in this Notice.

Service refers to the solar energy, energy storage, and e-mobility solutions and related services made available by the Company through the Application, the Website or otherwise, including the purchase of photovoltaic systems.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website means the Company’s website at https://solfium.com/ or such other website as the Company may maintain from time to time.

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Compliance with Laws

We respect the privacy of all individuals who provide Personal Data to Us. The Company is bound by the privacy and Personal Data protection legislation of the jurisdictions in which it operations, including the Personal Information Protection and Electronic Documents Act (Canada), Ley Federal de Protección de Datos Personales en Posesión de los Particulares (Mexico) and all other applicable federal, state or provincial privacy laws. Where a requirement of any applicable legislation is inconsistent with this Notice, that legislative requirement will apply.

Collecting and Using Your Personal Data

Types of Data Collected

Identification Information

While downloading or installing Our Application or using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

-       Email address;

-       First name and last name;

-       Phone number;

-       Address, State, Province, ZIP/Postal code, City.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We may collect certain information automatically, including, but not limited to, the type of mobile Device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

To the extent where the Company allows You to create an account and log in to use the Service through Third-party Social Media Services, including:

·       Google

·       Facebook

·       Instagram

·       Twitter

·       LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Notice.

Information from Third-Party Social Media Services

To the extent where the Company allows You to create an account and log in to use the Service through Third-party Social Media Services, including:

·       Google

·       Facebook

·       Instagram

·       Twitter

·       LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Notice.

Information Collected while Using the Service

While using the Application or Service, in order to provide features of our Service, We may collect:

·       Information regarding your location;

·       Information regarding your house or building for which you are considering solar energy;

·       Information regarding your budget, photovoltaic systems or other equipment or services purchased, other considerations, parameters and information communicated through the Service or related to past or current orders or requests;

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain Our Service, including to monitor the usage of our Service, register you as the owner of a purchased photovoltaic system, as applicable.

To manage Your Account: to manage Your registration as a user of the Application or Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service, including the management of certain technical features of Your purchased photovoltaic system, as applicable..

To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

To answer Your queries or complaints: To attend and manage Your queries or complaints to Us.

For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience, to compile information on environmental, social and governance (ESG) standards or for purposes necessary or incidental to the provision of goods and services to You.

We may share or disclose the whole or part of your Personal Data in the following situations and with the following persons:

·       With Service Providers: We may share Your Personal Data with Service Providers to provide the Service (including the delivery and installation of photovoltaic systems purchased through the Service) monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, for payment processing, to contact You.

·       For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

·       With Affiliates: We may share Your information with Our Affiliates (which currently include Solfium Mexico, Sociedad Anónima de Capital Variable (S.A. de C.V.) and Solfium Spain Sociedad Limitada), in which case we will require those Affiliates to fully comply with this Notice.

·       With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

·       With other users: when You share Personal Data or otherwise interact with other users through the Service, including installers of a purchased photovoltaic system such information may be viewed by such other users and may be publicly distributed outside the Application or Service.

·       With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

Limit to Collection, Use and Disclosure of Personal Data

We strive to limit the collection of Personal Data to that which is strictly required to fulfill the purposes for which it is collected. In certain circumstances, We may need to collect Personal Data and sensitive information to comply with Our legal obligations, such as foreign sanctions law. Rest assured that We will not disclose or use Your Personal Data for any purpose other than as stated in this Notice unless you consent to such disclosure, or the disclosure is required or permitted by law.

We may use your Personal Data if it is necessary to prevent or lessen a serious threat to public health or public safety or if the use of the information is necessary for law enforcement or for the conduct of proceedings before any court or tribunal.

Retention of Your Personal Data

We will retain Your Personal Data only for as long as is necessary for the purposes set out in this Notice. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

After such time, any Personal Data held by us will be destroyed, deleted or anonymized in accordance with applicable Personal Data protection laws.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's or its Affiliates’ operating offices in Canada, Mexico or Spain and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Notice followed by Your submission of such Personal Data represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Notice and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data. Where required under Personal Data protection laws, the Company will complete an assessment prior to any international transfer of Personal Data outside of the Jurisdiction.

Your Rights Regarding your Personal Data

Depending on applicable laws, You might have the right to obtain access to, rectification or erasure of your Personal Data, the right to withdraw your consent (if any), and the right not to be discriminated against. You may have additional rights, namely, the right to be informed of a decision based exclusively on an automated processing automated decision (if any), the right to restrict and to object to the use and processing of your Personal Data by Us, and the right to data portability by receiving a copy of all Personal Data that We have about You in a structured, commonly used and machine-readable format.

To exercise any of these rights (to the extent available), please submit Your request to Us by writing to the Privacy Officer as set forth in this Notice. Depending on the right being exercised, We will inform You of the procedure to follow, the processing time (delay of response) and the information needed. We will endeavor to process Your request within 30 days from the date your request is received. We will inform You if this timeframe is not achievable and extend this timeframe as permitted as applicable law.

We may charge a fee to cover the costs of meeting your request if your request is unfounded or excessive.

Unless we are required or permitted by law to refuse to do so, We will, on request, provide You with details of the Personal Data we have collected about You or update and rectify Your Personal Data in accordance with your request. Where we are also required by the applicable law to provide further information about the use or disclosure of your Personal Data, we will do so upon Your request.

If we do not agree to provide You with access to, or to rectify or erase, Your Personal Data as requested or otherwise meet your requests, we will notify You accordingly. Where appropriate, we will provide You with the reason(s) for our decision and the mechanisms available to complain about the refusal. If the rejection relates to a request to change Your Personal Data, you may make a statement about the requested change, and we will attach this to your record.

In some circumstances, and subject always to legal obligations to the contrary, we may not be in a position to grant access to Your Personal Data or otherwise meet your requests with respect to your Personal Data, including when:

-       your Personal Data is not retrievable;

-       the request is frivolous or vexatious; or

-       providing access or otherwise meeting your request is reasonably likely to pose a serious threat to the safety of an individual or the public; is likely to impact unreasonably on the privacy of others; or is otherwise unlawful.

Security of Your Personal Data

We have security measures in place designed to protect Your Personal Data. We strive to apply the necessary and appropriate security measures to ensure the confidentiality of the Personal Data in its possession or control. The standard security measures we use will depend on the type of information collected. In doing so, we follow generally accepted industry standards.

Appropriate physical, technical, and/or administrative safeguards and security measures have been put in place and are maintained to prevent:

-       Any accidental or unlawful destruction;

-       Accidental loss;

-       Unauthorized disclosure;

-       Unauthorized modification;

-       Unauthorized access; or

-       Any illegal treatment.

In terms of system security, here are some of the things we do to protect Your Personal Data:

-       We use firewalls, standard software protection programs, password access protections and secure servers;

-       We regularly review our security arrangements to ensure We are taking reasonable and technically feasible steps available at the time to protect Your Personal Data; and

-       We take reasonable steps to destroy, erase or permanently anonymize Personal Data as soon as practicable if it is no longer requit¡red, as described in this Notice.

We also make our employees, contractors and Service Providers aware of the importance of protection Personal Data, and care is used in the disposal or destruction of Personal Data, to prevent unauthorized parties from gaining access to the Personal Data.

It should be noted, however, that no method of transmission over the Internet, or method of electronic storage is 100% secure or error-free. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. You provide information to Us via the Internet at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorized access to, your Personal Data where the security of information is not within our control. We encourage you to be cautious when using the Internet.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website or Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You may opt-out of certain Google Analytics features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Advertising

We may use Service Providers to show advertisements to You to help support and maintain Our Service.

Google AdSense & DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Payments

We use third-party services for payment processing (e.g. payment processors) regarding purchases made through the Service.

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your Personal Data is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

dLocal

Their Privacy Hub can be accessed at https://www.dlocal.com/legal/privacy-hub/

Santander

Their Privacy Policy can be viewed at https://www.santanderbank.com/online-privacy-policy

Scotiabank

Their Privacy Policy can be accessed at https://www.scotiabank.com/ca/en/about/contact-us/privacy/privacy-agreement.html

Children's Privacy

Our Service does not address anyone under the age of 14. We do not knowingly collect Personal Data from anyone under the age of 14. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 14 without verification of parental consent, We take steps to remove that information from Our servers.

Links to Other Websites

Our Application, Website or Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Cookies and Similar Technologies

The Website and Application use cookies and similar technologies (such as pixels and local storage) to improve your experience, understand how our Service is used, and support certain features.

Cookies are small text files placed on your Device when you visit a website or use an app. They allow us to recognize your browser or device and store certain information. We use the following types of cookies:

·       Essential cookies – Necessary for the operation of Our Website / Application (e.g., security, session management, enabling core features).

·       Performance and analytics cookies – Help us understand how visitors use our Service so we can improve functionality and user experience.

·       Functionality cookies – Remember Your preferences and choices (such as language or region).

·       Advertising/targeting cookies – May be used to deliver relevant ads or measure the effectiveness of advertising campaigns (only if applicable).

You can control or disable cookies through your browser or device settings. Please note that some features of our services may not function properly if you disable essential cookies.

Changes to this Notice

We reserve the right to modify this Notice at any time, so please review it frequently. Changes to this Notice will be published by posting an updated Notice on this page and are effective upon posting.

If we update this Notice in a material way, we will notify you by sending you a notice on the Application and website or by e-mail. However, in all other circumstances, the posting of a new version of the Notice on our Application and website or your continued use of the Application, Website or Service will suffice as notice and consent to the Notice changes.

Privacy Officer and Contact Information

Our senior management has delegated the management of Our privacy compliance program to the Privacy Officer. The Privacy Officer is responsible for the internal management and oversight of Our privacy compliance program.

The Privacy Officer is responsible for advising the Company on Personal Data protection matters, approving and implementing privacy policies and procedures, ensuring that they are functioning properly, and reporting to our senior management on the effectiveness of the program.

The Privacy Officer also acts as a first point of contact with individuals whose Personal Data we collect, use or process and Personal Data protection authorities regarding Personal Data protection matters. It is also the responsibility of the Privacy Officer to provide You with the necessary support in the event of a question, complaint or request relating to the protection Personal Data.

If you have any questions about this Notice, You can each the Privacy Officer as follows:

·       By email: privacy@solfium.com

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