Legal Documentation

Privacy Policy

This Privacy Policy describes how Syntra Refining Corp. collects, uses, protects, and manages personal information in connection with our digital services, business operations, and commercial relationships.

Effective Date

January 9, 2026

Last Revised

January 9, 2026

Version

2.0

Introduction

Syntra Refining Corp. ("Syntra," "we," "us," or "our") is a critical minerals processing and refining company headquartered in Halifax, Nova Scotia, Canada. We are committed to protecting the privacy and security of personal information entrusted to us by our commercial partners, suppliers, investors, career applicants, and website visitors.

This Privacy Policy applies to all personal information collected through our website, digital portals, business communications, and related services (collectively, the "Services"). By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

This policy does not apply to information collected offline or through third-party websites, even if linked from our Services. We encourage you to review the privacy policies of any third-party sites you visit.

1

Information We Collect

1.1 Information You Provide Directly

We collect information that you voluntarily provide when you:

  • Submit inquiries through our contact forms (commercial, investor, supplier, or observer portal requests)
  • Apply for career opportunities and submit application materials
  • Register for partner portals or observer program access
  • Enter into commercial agreements or non-disclosure agreements (NDAs)
  • Subscribe to newsletters or communications
  • Communicate with us via email, phone, or other channels

This information may include:

  • Contact details: name, email address, phone number, mailing address
  • Professional information: organization name, job title, role, industry sector
  • Career application data: resume/CV, cover letter, work history, education, references, LinkedIn profile
  • Business information: company details, project specifications, technical requirements, procurement needs
  • Financial and investor information: investment interests, accreditation status, entity type

1.2 Information Collected Automatically

When you access our Services, we automatically collect certain technical information, including:

  • Device and browser information: IP address, browser type and version, operating system, device identifiers
  • Usage data: pages visited, time spent on pages, clickstream data, referral sources, access times
  • Location data: general geographic location inferred from IP address (country, region, city)
  • Cookies and similar technologies: session identifiers, analytics cookies, preference settings

This information helps us improve our Services, diagnose technical issues, analyze usage patterns, and enhance security.

1.3 Information from Third-Party Sources

We may supplement the information we collect with information from third-party sources, including publicly available databases, business intelligence platforms, industry directories, professional networking sites (e.g., LinkedIn), and our service providers. This helps us verify information, prevent fraud, and maintain the accuracy of our records.

2

How We Use Information

We use the information we collect for the following purposes:

Business Operations and Communications

  • Responding to commercial, technical, supplier, investor, and general inquiries
  • Processing and evaluating career applications and managing recruitment workflows
  • Facilitating onboarding for partner portals, observer programs, and data room access
  • Managing contractual relationships and fulfilling obligations under agreements
  • Sending transactional communications related to your requests or accounts

Service Improvement and Analytics

  • Analyzing usage patterns to improve website functionality and user experience
  • Conducting internal research and development to enhance our Services
  • Testing new features, functionality, and system performance
  • Generating aggregated, anonymized statistics for business intelligence

Security, Compliance, and Legal

  • Detecting, preventing, and addressing fraud, security incidents, and technical issues
  • Enforcing our Terms of Service and other legal agreements
  • Complying with applicable laws, regulations, and legal processes
  • Protecting the rights, property, and safety of Syntra, our users, and the public
  • Responding to lawful requests from public authorities and regulatory bodies

Marketing and Relationship Management

  • Sending periodic updates, newsletters, and marketing communications (with your consent where required)
  • Providing information about our services, projects, and corporate developments
  • Maintaining ongoing relationships with commercial partners, suppliers, and stakeholders

Note: We will seek your explicit consent before using your information for purposes not described in this Privacy Policy or as otherwise required by applicable law.

3

Information Sharing and Disclosure

We do not sell, rent, or trade your personal information.

We may share your information only in the following limited circumstances:

3.1 Service Providers and Business Partners

We engage trusted third-party service providers to support our business operations, including:

  • Cloud infrastructure and hosting providers (e.g., Supabase, AWS, or similar platforms)
  • Email and communication platforms
  • Analytics and monitoring services
  • Human resources and recruiting platforms
  • Payment processors and financial service providers

These service providers are contractually obligated to protect your information, use it only for the purposes for which it was disclosed, and comply with applicable data protection laws.

3.2 Professional Advisors

We may share information with legal counsel, accountants, auditors, consultants, and other professional advisors who are bound by confidentiality obligations and provide services related to our business operations, compliance, litigation, or strategic transactions.

3.3 Legal and Regulatory Authorities

We may disclose information when required by law or in response to valid legal processes, including:

  • Subpoenas, court orders, or other legal requests
  • Regulatory inquiries or government investigations
  • Enforcement of our legal rights or defense of legal claims
  • Protection of the safety, rights, or property of Syntra or others

3.4 Business Transactions

In the event of a merger, acquisition, reorganization, sale of assets, or other corporate transaction, personal information may be transferred to the acquiring or successor entity, subject to the protections described in this Privacy Policy.

3.5 With Your Consent

We may share your information with third parties when you have provided explicit consent or directed us to do so.

4

Data Storage and Security

4.1 Data Storage

Personal information is stored on secure servers located in Canada and may be processed in other jurisdictions where our service providers operate. We ensure that any cross-border data transfers comply with applicable data protection laws, including the use of standard contractual clauses or other approved transfer mechanisms.

4.2 Security Measures

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

  • Encryption of data in transit and at rest using industry-standard protocols
  • Access controls and authentication mechanisms to restrict access to authorized personnel only
  • Regular security assessments, vulnerability scans, and penetration testing
  • Employee training on data security and privacy best practices
  • Incident response procedures to address potential security breaches
  • Secure backup and disaster recovery systems

Note: While we take reasonable precautions to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security, and you use our Services at your own risk.

4.3 Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type of information and the nature of our relationship with you:

  • Career applications: Retained for up to 24 months unless you request earlier deletion
  • Commercial and contractual records: Retained for the duration of the relationship plus applicable limitation periods (typically 7 years)
  • Website analytics and technical logs: Retained for up to 13 months
  • Marketing communications: Retained until you opt out or withdraw consent

After the applicable retention period, we securely delete or anonymize personal information in accordance with our data retention policies.

5

Your Rights and Choices

Depending on your location and applicable law, you may have the following rights regarding your personal information:

Access

Request a copy of the personal information we hold about you.

Correction

Request correction of inaccurate or incomplete information.

Deletion

Request deletion of your personal information, subject to legal and contractual obligations.

Restriction

Request restriction of processing in certain circumstances.

Data Portability

Receive your information in a structured, machine-readable format.

Objection

Object to processing based on legitimate interests or for direct marketing.

Withdraw Consent

Withdraw consent for processing where consent was the legal basis.

Lodge a Complaint

File a complaint with your local data protection authority.

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: privacy@syntrarefining.com
Subject Line: "Privacy Rights Request"

We will respond to your request within 30 days (or as otherwise required by applicable law). We may require verification of your identity before processing certain requests to protect your privacy and security.

Marketing Communications

You may opt out of receiving marketing emails at any time by clicking the "unsubscribe" link at the bottom of our emails or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you transactional or administrative messages related to your use of our Services.

Cookies and Tracking Technologies

Most web browsers allow you to control cookies through browser settings. You can configure your browser to refuse all cookies or alert you when cookies are being sent. However, disabling cookies may affect the functionality of certain features of our Services.

6

Third-Party Services and Links

Our Services may contain links to third-party websites, applications, or services that are not operated or controlled by Syntra. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices.

We use the following categories of third-party services in connection with our operations:

  • Cloud hosting and infrastructure: Supabase, AWS, or similar platforms for data storage and application hosting
  • Analytics: Tools to analyze website traffic, usage patterns, and performance
  • Communication platforms: Email delivery, contact management, and customer support tools
  • Recruiting and HR systems: Platforms for managing career applications and candidate communications

We encourage you to review the privacy policies of any third-party services you interact with. We select service providers that maintain strong privacy and security standards, but we cannot control their practices.

7

Children's Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@syntrarefining.com, and we will take prompt steps to delete such information.

8

International Data Transfers

Syntra is based in Canada, and our primary data infrastructure is located in Canada. However, we may transfer personal information to service providers located in other countries, including the United States and other jurisdictions where our partners operate.

When we transfer personal information outside of Canada, we ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws. These safeguards may include:

  • Standard contractual clauses approved by relevant data protection authorities
  • Adequacy decisions recognizing equivalent levels of data protection in the destination country
  • Binding corporate rules or other approved transfer mechanisms

If you have questions about international data transfers, please contact us at privacy@syntrarefining.com.

9

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

  • Updating the "Last Revised" date at the top of this policy
  • Posting a notice on our website
  • Sending an email notification (if you have provided your email address)

We encourage you to review this Privacy Policy periodically. Your continued use of the Services after any changes indicates your acceptance of the updated policy.

10

Contact Information

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

Privacy Contact

Mailing Address

Syntra Refining Corp.
Attn: Privacy Officer
Halifax, Nova Scotia
Canada

General Inquiries

info@syntrarefining.com

We are committed to working with you to resolve any privacy concerns. We will respond to all inquiries within a reasonable timeframe, typically within 30 days.

Acknowledgment

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein. If you do not agree with this Privacy Policy, please do not use our Services.