Everett & Co. ("Everett," "we," "us," or "our") is a venture studio that builds and operates technology companies across multiple sectors. This Privacy Policy describes how we collect, use, disclose, and protect information about individuals who interact with us through our website, ventures, products, and services (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this Policy. If you do not agree with its terms, please do not use our Services.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

• Contact and identity information (name, email address, phone number, job title)

• Account credentials if you register for a platform or service we operate

• Communications you send us, including inquiries, feedback, and support requests

• Business information shared in the context of partnership, investment, or client discussions

• Information submitted through forms, surveys, or applications on our platforms

1.2 Information Collected Automatically

When you use our Services, we and our service providers may automatically collect:

• Log data (IP address, browser type, pages visited, timestamps)

• Device and usage information (operating system, device identifiers, session data)

• Location information derived from your IP address

• Cookies and similar tracking technologies (see Section 5)

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Business partners, co-investors, and referral sources

• Publicly available sources (LinkedIn, company websites, press releases)

• Analytics providers and advertising networks

• Portfolio company platforms, where applicable and disclosed

2. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and improve our Services and ventures

• To communicate with you about our activities, investments, and portfolio companies

• To evaluate partnership, client, or investment opportunities

• To respond to inquiries and provide customer or operational support

• To send administrative notices, updates, and policy changes

• To send marketing communications where you have consented or where permitted by law

• To detect, prevent, and address fraud, security incidents, or illegal activity

• To comply with applicable legal and regulatory obligations

• To conduct analytics and improve our business operations

3. Legal Bases for Processing (Canada & GDPR)

Where applicable law requires a legal basis for processing personal information, we rely on the following:

• Consent — where you have given explicit consent to a specific use

• Contract — where processing is necessary to fulfill or negotiate a contract with you

• Legitimate interests — where processing serves our legitimate business interests and does not override your rights

• Legal obligation — where we are required to process your information under applicable law

For residents of the European Economic Area (EEA) or the United Kingdom, you may have the right to withdraw consent or object to processing based on legitimate interests.

4. Sharing Your Information

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

4.1 Within Everett & Co.

We may share information among our venture studio entities, portfolio companies, and operating teams to the extent necessary to provide integrated Services.

4.2 Service Providers

We share information with vendors and service providers who perform functions on our behalf (cloud infrastructure, analytics, email delivery, CRM platforms), subject to appropriate data processing agreements.

4.3 Business Transactions

If Everett & Co. or one of its ventures is involved in a merger, acquisition, financing, or asset sale, your information may be transferred as part of that transaction, subject to standard confidentiality protections.

4.4 Legal Requirements

We may disclose information to government authorities or third parties where required by law, court order, or to protect the rights, property, or safety of Everett, our users, or the public.

4.5 With Your Consent

We may share information with third parties when you have given explicit consent to do so.

5. Cookies and Tracking Technologies

Our websites and platforms may use cookies, pixel tags, and similar technologies to collect usage data and improve your experience. You can control cookie settings through your browser or our cookie preference tool where available.

We use the following types of cookies:

• Essential cookies — required for the Services to function

• Analytics cookies — help us understand how visitors interact with our sites

• Preference cookies — remember your settings and choices

• Marketing cookies — used to deliver relevant advertising where applicable

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we delete or anonymize it in accordance with our internal retention schedules.

7. Data Security

We implement administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encryption in transit and at rest, access controls, and security monitoring across our infrastructure.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

8. International Data Transfers

Everett & Co. operates in Canada and the United States. If you are located outside these jurisdictions, your information may be transferred to, stored, and processed in countries with different data protection laws than your own. We take appropriate steps to ensure such transfers comply with applicable law, including the use of standard contractual clauses where required.

9. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access — request a copy of the personal information we hold about you

• Correction — request that inaccurate or incomplete information be corrected

• Deletion — request that we delete your personal information, subject to legal retention requirements

• Portability — receive your information in a structured, machine-readable format

• Objection or Restriction — object to or request restriction of certain processing activities

• Withdrawal of Consent — withdraw consent at any time where processing is based on consent

To exercise any of these rights, please contact us at the address below. We will respond within the timeframe required by applicable law.

10. Children's Privacy

Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If you believe we have inadvertently collected such information, please contact us and we will take steps to delete it.

11. Third-Party Links

Our Services may contain links to third-party websites, platforms, or applications. This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies before providing any personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will post the updated Policy on our website with a revised effective date. Where changes are material, we will provide additional notice (such as by email or prominent notice on our site).

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: privacy@everettco.dev

Website: everettco.dev

For residents of the European Economic Area or United Kingdom, you also have the right to lodge a complaint with your local data protection authority.