TORONTO BUSINESS DEVELOPMENT CENTRE

PRIVACY POLICY

Effective Date: February 20, 2026


1. Introduction

Toronto Business Development Centre (“TBDC”, “we”, “us” or “our”) is committed to respecting and protecting the privacy and personal data of individuals in accordance with applicable data protection laws.

This Privacy Policy explains how we collect, use, disclose, store, transfer and otherwise process personal data in connection with:

  • Applications to and participation in TBDC programs and initiatives, including European programs
  • Communications with TBDC
  • Access to and use of our website and digital platforms
  • Our institutional, operational, compliance and governance activities

This Policy is intended to comply with Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”), the EU ePrivacy Directive, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), and applicable Canadian provincial privacy legislation.

Where processing is subject to the GDPR, this Policy also describes the legal bases on which we process personal data and the rights available to data subjects under that framework.


2. Identity of the Data Controller

For the purposes of applicable data protection legislation, including the GDPR, TBDC acts as the data controller in respect of personal data processed through its programs, application portals, digital services and institutional operations.

TBDC may be contacted at:

TORONTO BUSINESS DEVELOPMENT CENTRE
111 Peter Street, 9th Floor, Suite 902
Toronto, Ontario M5V 2H1
Canada
Email: info@TBDC.com


3. Scope of Application

This Policy applies to personal data collected directly from individuals, obtained through online forms and digital platforms, received in connection with program participation, gathered during due diligence or compliance procedures, or otherwise processed in the course of TBDC’s activities.

The Policy applies irrespective of the geographic location of the individual whose data is processed.


4. Categories of Personal Data We Process

Depending on your interaction with TBDC, we may process personal data including identification and contact information such as your name, date of birth, nationality, address, email address and telephone number.

We may also process professional and application-related information, including curriculum vitae, educational background, employment history, company information and supporting documentation submitted as part of an application or program participation.

In certain circumstances, we may process financial and compliance-related information, including banking details, payment records, source of funds documentation, beneficial ownership information and identification documents where required by law.

Technical information such as IP address, browser type, device identifiers and website interaction data may also be processed when you access our digital platforms.

Where special categories of personal data are processed, such processing will occur strictly in accordance with applicable legal requirements and safeguards.


5. How We Collect Personal Data

We collect personal data directly from you when you submit application forms, communicate with us, participate in programs or interact with our website.

We may also receive personal data from sponsors, funding bodies, regulatory authorities, professional advisers, or publicly available sources where necessary and lawful.


Where the GDPR applies, we process personal data on one or more of the following bases:

  • Processing is necessary for the performance of a contract or to take steps prior to entering into a contract
  • Processing is necessary to comply with a legal obligation
  • Processing is necessary for legitimate interests pursued by TBDC, provided such interests are not overridden by the rights and freedoms of the data subject
  • Consent has been provided
  • Processing is necessary for the establishment, exercise or defence of legal claims

Under Canadian law, personal information is collected, used and disclosed with knowledge and consent, except where otherwise permitted or required by law.

Where processing is based on consent, consent may be withdrawn at any time, subject to legal or contractual restrictions.


7. Purposes of Processing

We process personal data for the purposes of:

  • Evaluating and administering applications
  • Delivering and managing program participation
  • Conducting due diligence and regulatory compliance reviews
  • Communicating with applicants and participants
  • Processing payments
  • Preventing fraud and safeguarding institutional integrity
  • Maintaining governance and audit records
  • Complying with legal and contractual obligations
  • Improving our services and digital platforms

TBDC does not sell personal data.


8. Disclosure of Personal Data

Personal data may be disclosed where necessary to:

  • Governmental or regulatory authorities
  • Sponsors and funding bodies
  • Professional advisers including legal counsel and auditors
  • Financial institutions
  • Insurers
  • Third-party service providers such as cloud hosting and IT providers

Personal data may also be disclosed in connection with institutional restructuring or reorganization.

All third-party recipients are subject to contractual or statutory obligations to protect personal data and maintain appropriate confidentiality.


9. International Transfers

Personal data may be transferred outside your country of residence, including transfers from the European Economic Area to Canada or other jurisdictions.

Where required, we implement appropriate safeguards for such transfers, including the use of European Commission Standard Contractual Clauses and contractual data protection commitments, together with appropriate technical and organizational measures.

Canada has been recognized by the European Commission as providing an adequate level of protection for commercial organizations subject to PIPEDA.


10. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including program administration, regulatory compliance, audit and governance requirements, and the defence of legal claims.

Once retention is no longer necessary, personal data is securely deleted, anonymized or destroyed in accordance with our internal retention policies.


11. Data Protection Impact Assessments

Where processing activities are likely to result in a high risk to the rights and freedoms of individuals, TBDC conducts a Data Protection Impact Assessment in accordance with Article 35 of the GDPR and applicable regulatory guidance.

Such assessments evaluate the necessity and proportionality of processing, identify risks to data subjects, and document mitigation and security measures.

Where required by law, TBDC will consult with the relevant supervisory authority before proceeding with high-risk processing.


12. Records of Processing Activities

TBDC maintains internal records of processing activities in accordance with Article 30 of the GDPR and Canadian accountability requirements, documenting categories of processing, purposes, retention periods and security measures.


13. Security Measures

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include:

  • Controlled access to systems
  • Secure hosting environments
  • Encryption where appropriate
  • Confidentiality obligations for personnel
  • Secure data destruction procedures

While reasonable safeguards are maintained, no method of transmission or storage can be guaranteed to be entirely secure.


14. Personal Data Breaches

In the event of a personal data breach, TBDC will assess the risk to individuals without undue delay.

Where required under the GDPR, we will notify the relevant supervisory authority within seventy-two hours of becoming aware of the breach and notify affected individuals where legally required.

Breach records are maintained in accordance with applicable EU and Canadian law.


15. Automated Decision-Making

TBDC does not engage in automated decision-making that produces legal or similarly significant effects without appropriate human oversight.


16. Your Rights

Where the GDPR applies, individuals have the right to:

  • Request access to their personal data
  • Seek rectification of inaccurate data
  • Request erasure
  • Restrict processing
  • Object to processing
  • Request data portability
  • Withdraw consent where applicable
  • Lodge a complaint with a competent supervisory authority

Under Canadian law, individuals have the right to request access to their personal information, request correction of inaccuracies and file a complaint with the Office of the Privacy Commissioner of Canada.

Requests should be submitted in writing to the Privacy Officer at the contact details below.


17. Children’s Data

TBDC does not knowingly collect personal data from individuals under the age of sixteen, or such other age as prescribed by applicable law, without appropriate parental or guardian consent.


18. Cookies and Digital Technologies

TBDC uses cookies and similar technologies to ensure proper functioning of its website, enhance user experience and analyze performance.

Non-essential cookies are deployed only with consent where required by EU ePrivacy legislation.

Users may manage cookie preferences through browser settings or consent management tools.


19. Third-Party Websites

TBDC’s website and digital platforms may contain links to third-party websites or services that are not operated or controlled by TBDC.

This Privacy Policy applies solely to personal data processed by TBDC.

We are not responsible for the privacy practices or content of third-party websites.

Individuals who access such websites are encouraged to review the privacy policies of those third parties before submitting personal data.


20. Governance and Accountability

TBDC designates a Privacy Officer responsible for oversight of compliance with this Policy.

The organization maintains internal privacy procedures, conducts periodic reviews of data protection practices, provides training to personnel and monitors third-party service providers to ensure adherence to data protection obligations.


21. Amendments

We may amend this Privacy Policy from time to time to reflect changes in legal requirements or operational practices.

The most current version will be published on our website with the updated effective date.


22. Contact Information

All privacy-related inquiries, data subject requests or complaints should be directed to:

TORONTO BUSINESS DEVELOPMENT CENTRE
c/o Privacy Officer
111 Peter Street, 9th Floor, Suite 902
Toronto, Ontario M5V 2H1
Canada
Email: info@tbdc.com

Individuals in the European Union may also lodge a complaint with the supervisory authority in their Member State of residence.