Privacy Policy

Effective Date: April 7, 2026

De Roy Capital (“we,” “us,” or “our“) is a private family-owned capital investment firm based in Canada. Our website (the “Site“) provides general information about our firm, our investment philosophy, and related educational or news content. We do not offer financial services, products, advice, or client accounts through this Site, and we do not solicit or accept investments via the Site.

We are committed to protecting the privacy of visitors to our Site. This Privacy Policy explains our practices regarding any personal information in connection with the Site, in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and its 10 fair information principles, as well as general privacy standards recognized internationally.

1. Scope of This Policy

This Privacy Policy applies to your use of the De Roy Capital website and any associated pages or subdomains. It does not apply to any offline activities, third-party websites linked from our Site, or any future client portals or private extranets (which would be governed by separate agreements).

We do not collect, use, or disclose personal information through the Site in the course of commercial activities that would trigger extensive obligations under PIPEDA. Our Site is purely informational.

2. Personal Information We Collect

We do not knowingly collect personal information from visitors to our Site in the ordinary course of browsing.

• No voluntary submission required: You can access and browse all publicly available content on the Site without providing any personal information (such as name, email address, phone number, or financial details).
• Technical and usage information: Like most websites, our Site may automatically log certain non-identifying technical data, including:
  • IP address (which may be partially masked or anonymized)
  • Browser type and version
  • Operating system
  • Pages visited, date and time of visit, and time spent on pages
  • Referring website (if any)

This technical data is collected in aggregate or anonymized form and cannot reasonably be used to identify you as an individual. It helps us understand Site usage, improve performance, and maintain security. It is not linked to any personally identifiable information.

We do not use cookies, tracking pixels, web beacons, or similar technologies for profiling, advertising, or behavioral tracking on the Site. If we ever implement such tools in the future, we will update this Policy and obtain any required consent.

We do not collect sensitive personal information (e.g., financial details, health information, or government identifiers) through the Site.

3. How We Use Any Information

Any technical or aggregate data we log is used solely for legitimate internal purposes, such as:

• Maintaining and improving the functionality and security of the Site
• Analyzing overall usage trends (without identifying individuals)
• Complying with legal obligations

We do not use any information for marketing, advertising, or selling to third parties.

4. Sharing or Disclosure of Information

We do not sell, rent, or otherwise disclose personal information to third parties for commercial purposes.

We may disclose technical or aggregate data (which does not identify individuals) to:

• Service providers who assist with hosting, maintenance, or security of the Site (under strict confidentiality agreements)
• Legal authorities if required by applicable law (e.g., court order or regulatory request)

If any personal information were ever collected in the future (e.g., via a contact form), it would only be shared with third parties where necessary for the identified purpose and with appropriate safeguards.

5. International Transfers

Our Site is hosted in North America. Any processing occurs in compliance with Canadian law. If data is transferred outside Canada, we would ensure appropriate safeguards (e.g., contractual clauses) consistent with PIPEDA requirements.

We cannot control or guarantee the practices of third-party websites linked from our Site. We encourage you to review their privacy policies.

6. Data Retention

We retain technical logs only as long as reasonably necessary for the purposes described or as required by law. Once no longer needed, such data is securely deleted or anonymized.

7. Security Safeguards

We take reasonable physical, organizational, and technological measures to protect any information associated with the Site from unauthorized access, use, disclosure, or destruction. However, no internet transmission or electronic storage method is 100% secure. We cannot guarantee absolute security and are not responsible for any breaches caused by factors beyond our reasonable control.

8. Children’s Privacy

Our Site is not directed at children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will delete it promptly.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The “Last Updated” date at the top will be revised accordingly. We encourage you to review this Policy periodically. Continued use of the Site after changes constitutes acceptance of the updated Policy.

We will notify users of material changes in a prominent manner (e.g., via a notice on the Site).

10. Governing Law

This Privacy Policy is governed by the laws of Canada and the applicable province/territory, particularly PIPEDA where it applies. By using the Site, you agree that any disputes will be resolved under Canadian jurisdiction.