Privacy Policy

Last updated: December 1, 2025

2.0 Capital Partners Ltd. (“2CP”, “we”, “us”, or “our”) is committed to protecting the privacy and confidentiality of personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation. This Privacy Policy explains how we collect, use, disclose, safeguard, and retain personal information when individuals interact with our website or engage with us as clients or prospective clients.

1. What Information We Collect

We may collect personal information when you:

  • Complete subscription, KYC, or suitability documentation

  • Contact us through our website, email, or phone

  • Engage in transactions or communicate with us regarding investments

  • Provide information required under securities or AML/ATF laws

Information collected may include:

  • Name, address, email, phone number

  • Date of birth, occupation, employer, financial information

  • Identification documents and beneficial ownership information

  • Banking information for transactions and distributions

  • Investment history and preferences

We collect only the information necessary to provide our services and meet legal or regulatory requirements. Collection purposes are also disclosed in onboarding documents, including account forms and Relationship Disclosure Information (RDI).

2. How We Use Personal Information

We use personal information to:

  • Assess suitability and meet KYC, AML/ATF, and regulatory requirements

  • Administer investments, accounts, and transactions

  • Communicate about investments, Firm updates, and regulatory notices

  • Provide requested information or respond to inquiries

We do not sell personal information, and any use for a new purpose will require your express consent unless required by law.

3. Disclosure of Personal Information

We may disclose personal information to:

  • Regulatory bodies such as the OSC, FINTRAC, or CRA

  • Affiliates and other financial service providers (e.g., banks involved in facilitating transactions)

  • Service providers that support our operations (e.g., custodians, auditors, technology vendors, legal counsel, tax preparation, accounting)

  • Other parties where disclosure is required or permitted by law

2CP remains responsible for Client Information transferred to third parties and requires these parties, through contractual agreements, to protect personal information and use it only for authorized purposes.

4. Consent

Your knowledge and consent are required for the collection, use, and disclosure of your personal information.

  • Consent is generally express (written or electronic) and may be provided through account opening forms, subscription agreements, RDI documents, or this Privacy Policy.

  • Withdrawal of consent: You may withdraw your consent at any time, subject to reasonable notice and any legal or contractual restrictions. We will inform you of the implications of withdrawing your consent.

5. Data Retention

We retain personal information for at least seven (7) years following the termination of the client relationship, or longer if mandated by securities laws or other legal requirements. When no longer required, information is securely destroyed or anonymized in a manner commensurate with its sensitivity.

6. How We Protect Information

We use administrative, technical, and physical safeguards, including:

  • Technological Measures: Encryption, secure storage, and multi-factor authentication.

  • Organizational Measures: Restricted, role-based access for personnel on a "need-to-know" basis.

  • Physical Measures: Locking filing cabinets and restricting office access.

Third-party service providers are contractually required to maintain equivalent safeguards.

7. Access and Corrections

You have the right to request access to and correction of the personal information we hold about you by contacting the Chief Compliance Officer (CCO) in writing. We aim to respond to access requests within 30 days. Where necessary, this period may be extended, and you will be notified of the reason for the extension.

Limitations on Access: Access may be withheld where permitted by law, including if it would:

  • Be protected by solicitor-client privilege.

  • Reveal confidential commercial information.

  • Threaten the life or security of another individual.

  • Have been generated in the course of a formal dispute resolution process.

Costs: We reserve the right to charge reasonable costs for processing access requests and will notify you of any approximate charges beforehand for your approval.

8. Cookies, Website Analytics, and Online Tracking

Our website may collect limited technical information such as browser type, device type, and pages visited. We do not currently use cookies for advertising, profiling, or tracking, and we do not sell or share website usage data. If analytics tools are added in the future, this Policy will be updated.

9. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for their privacy practices. We encourage users to review those policies before providing personal information.

10. Breach Notification

If a privacy breach occurs that is determined to pose a real risk of significant harm to an individual, we will:

  • Notify affected individuals as soon as feasible (unless prohibited by law).

  • Notify the Office of the Privacy Commissioner of Canada (OPC) promptly.

  • Take immediate steps to mitigate and remedy the breach.

11. Changes to this Policy

We may update this Privacy Policy from time to time. The most recent version will always be posted on our website with the effective date.

12. Contact Information

For questions or requests regarding this Privacy Policy or your personal information, please contact the CCO as the first point of contact.

CCO and Privacy Officer
Vikram Rajagopalan
Email: vikram@2cp.ca
Phone: 647-629-1644