Last Updated: June 19, 2025

UPGC Inc. (“UPGC”, “we”, “our”, or “us”) is a Canadian federally incorporated company based in Ontario, Canada. We are committed to protecting your privacy and ensuring that your personal information is handled in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”). This Privacy Policy explains how we collect, use, disclose, and safeguard personal information obtained through our website (the “Site”) and any related services (collectively, the “Services”).

By accessing or using our Site or Services, you agree to the terms of this Privacy Policy.

1. Collection of Personal Information

UPGC is committed to protecting your privacy and collects both personal and non-personal information in the course of providing our services.

Personal information refers to data that identifies you or could reasonably be linked to you. This may include, but is not limited to, your name, email address, phone number, or IP address when combined with other identifying information.

We also collect certain technical and usage-related information that does not directly identify you, such as details about your internet connection, the device you use to access our website, and your interactions with the site. If we combine this data with your personal information, we will treat the combined data as personal information under this policy.

UPGC retains personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required to meet legal, regulatory, or contractual obligations.

2. Disclosure of Personal Information

We do not sell your personal information. We may share your personal information in the following situations:

a) Third-Party Service Providers – We may share personal information with third parties performing services on our behalf, such as:

· Website and event platform providers

· Payment processors

· Email or communication service providers

· Analytics and advertising technology providers

These third parties are bound by confidentiality obligations and may use personal information only to perform specific services.

b) Legal Requirements – We may disclose your personal information where required or authorized by law, including:

· To comply with subpoenas, legal orders, or government requests

· To investigate or prevent fraud or security threats

· To protect our legal rights or enforce our terms

c) International Transfers Some of our service providers may be located outside Canada, including in the United States or Europe. When we transfer your personal information internationally, we ensure that appropriate safeguards are in place to protect it in accordance with Canadian privacy laws.

3. Consent

By using our Services or providing personal information to us, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

You may withdraw your consent at any time by contacting us (see Section 10). Please note that withdrawal of consent may affect our ability to provide certain services.

4. Access and Correction

You may request access to your personal information or ask us to correct inaccurate or incomplete information by contacting us in writing. We will respond within a reasonable time and in accordance with applicable law.

5. Retention and Secure Destruction

We retain personal information only as long as necessary for the identified purposes or as required by law. When information is no longer required, we securely destroy it through methods such as:

· Cross-cut shredding for paper records

· Secure deletion or physical destruction of digital storage media

Retention periods vary based on legal, operational, and contractual obligations.

6. Security Measures

We take reasonable physical, administrative, and technical safeguards to protect your personal information from loss, theft, unauthorized access, disclosure, or modification. However, no method of transmission over the Internet is completely secure. If a security breach occurs, we will notify affected individuals in accordance with applicable laws.

7. Cookies and Website Analytics

Our Site may use cookies, pixels, and similar technologies to enhance user experience, track usage, and improve our Services. Third-party analytics tools, such as Google Analytics, may collect usage data (IP address, browser type, page interactions). You may configure your browser settings to block cookies; however, some features of the Site may not function properly.

8. Children’s Privacy

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children without parental consent. If you believe we have collected such information, please contact us immediately.

9. Your Rights and Contacting Us

You have the right to:

· Access your personal information

· Correct inaccurate information

· Withdraw consent to the use or sharing of your data

· File a complaint with the Office of the Privacy Commissioner of Canada

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us:

UPGC Inc.

191 Creditview Rd., Suite 300

Vaughan, ON L4L 9T1

Email: UPGC.Communications@nullUPGC.com

Phone: 1.855.887.8742

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last Updated” date. If the changes materially affect your rights, we will notify you through the Site or other means.

We encourage you to review this page periodically to stay informed about our privacy practices.