Introduction and Scope

Neverex Never ("we," "us," or "our") operates from 16 Green Mountain Rd, Penticton, BC V2A 8X1, Canada, and is committed to protecting your personal information in accordance with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website at neverexnever.vip, use our investment confidence services, or interact with us in any capacity.

By using our services or providing us with your personal information, you consent to the collection, use, and disclosure of your information as described in this policy. If you do not agree with any part of this policy, please do not use our services or provide us with your personal information.

Information We Collect

How We Collect Information

We collect information directly from you when you:

• Complete online forms or applications on our website
• Contact us by phone, email, or through our contact forms
• Sign up for our investment confidence programs
• Participate in surveys, webinars, or educational events
• Subscribe to our newsletters or marketing communications

We may also collect information indirectly through automated technologies, third-party service providers, or publicly available sources where permitted by law.

How We Use Your Information

Primary Business Purposes

We use your personal information to provide and improve our investment confidence services, including:

• Assessing your suitability for our programs and services
• Providing personalized investment education and guidance
• Processing applications and managing client relationships
• Sending educational content, market updates, and service communications
• Conducting research to improve our services and develop new offerings

Legal and Compliance Purposes

We may use your information to:

• Comply with Canadian securities regulations and tax requirements
• Meet anti-money laundering and know-your-client obligations
• Respond to legal requests from regulatory authorities
• Protect against fraud, unauthorized access, and other security threats
• Enforce our terms of service and protect our legal rights

Marketing and Communications

With your consent, we may use your information to send you marketing communications about our services, educational resources, and industry insights. You can opt out of marketing communications at any time through the unsubscribe links in our emails or by contacting us directly.

Information Sharing and Disclosure

Service Providers and Business Partners

We may share your information with trusted third-party service providers who help us operate our business, including:

• Technology providers for website hosting, data storage, and security
• Payment processors for handling transactions and billing
• Marketing platforms for email campaigns and customer communications
• Professional advisors including lawyers, accountants, and consultants

Legal Requirements

We may disclose your information when required by law, including:

• In response to court orders, subpoenas, or other legal processes
• To comply with regulatory investigations or requests
• When necessary to protect our rights, property, or safety
• To prevent fraud or other illegal activities

Business Transfers

In the event of a merger, acquisition, or sale of our business assets, your personal information may be transferred to the new entity, subject to the same privacy protections outlined in this policy.

Important: We do not sell, rent, or trade your personal information to third parties for their marketing purposes without your explicit consent.

Your Privacy Rights

How to Exercise Your Rights

To exercise any of these rights, contact our Privacy Officer:

• Email: [email protected] with "Privacy Request" in the subject line
• Phone: +1 506 459 7219
• Mail: Privacy Officer, 16 Green Mountain Rd, Penticton, BC V2A 8X1, Canada

We will respond to your request within 30 days. In some cases, we may extend this period by an additional 30 days if the request is complex or we receive multiple requests. We will notify you if an extension is needed.

Identity Verification

To protect your privacy, we may ask you to verify your identity before processing requests that involve accessing or modifying your personal information. This may include providing government-issued identification or answering security questions about your account.

Data Security and Protection

Technical Safeguards

We implement industry-standard security measures to protect your personal information:

• Encryption of data in transit and at rest using advanced encryption protocols
• Secure servers hosted in certified data centers with physical security controls
• Regular security audits and vulnerability assessments
• Multi-factor authentication for employee access to sensitive systems
• Firewalls and intrusion detection systems to prevent unauthorized access

Administrative Safeguards

Our team follows strict policies and procedures:

• Regular privacy and security training for all employees
• Access controls that limit employee access to information on a need-to-know basis
• Background checks for employees with access to sensitive information
• Incident response procedures for handling potential security breaches

Data Breach Notification

In the unlikely event of a data breach that poses a real risk of significant harm, we will notify affected individuals and relevant authorities as required by Canadian law, typically within 72 hours of discovering the breach.

Data Retention and Deletion

Secure Deletion Procedures

When we delete your personal information, we use secure deletion methods to ensure the data cannot be recovered. This includes overwriting digital files multiple times and physically destroying any paper records containing personal information.

Some information may be retained longer if required by law or to resolve disputes, but it will be stored securely and used only for those specific purposes.

International Data Transfers

While we primarily store and process your information within Canada, some of our service providers may operate outside of Canada, including in the United States. When we transfer your personal information outside of Canada, we ensure appropriate safeguards are in place:

• We only work with service providers that have adequate privacy protections
• We use contractual clauses that require foreign service providers to protect your information
• We conduct due diligence on the privacy laws and practices in other countries
• We monitor and audit our service providers' compliance with our privacy requirements

You have the right to know when your information is transferred outside Canada and to understand the protections that apply in those jurisdictions.

Cookies and Tracking Technologies

Types of Cookies We Use

• Essential Cookies: Required for basic website functionality and security
• Performance Cookies: Help us understand how visitors use our website
• Preference Cookies: Remember your settings and preferences
• Marketing Cookies: Used to deliver relevant advertisements (with your consent)

Managing Cookies

You can control cookies through your browser settings. However, please note that disabling certain cookies may affect the functionality of our website. Most browsers allow you to:

• View and delete existing cookies
• Block cookies from specific websites
• Block all cookies (though this may break website functionality)
• Delete all cookies when you close your browser

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make significant changes, we will:

• Post the updated policy on our website with a new "Last Updated" date
• Send email notifications to active clients about material changes
• Provide prominent notice on our website for at least 30 days
• Obtain your consent for changes that significantly expand how we use your information

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Your continued use of our services after we post changes constitutes your acceptance of the updated policy.