Privacy & Security Policy

Effective date: September 8, 2026 | Issued by: FranMax Inc. (Brokerage), 480 Queenston Road, Cambridge, Ontario N3H 3J6 | Broker of Record: Roger Noble, JD (non-practising)

1. Overview and Commitment

FranMax Inc. (Brokerage) ("FranMax", "we", "us") is committed to protecting the privacy and security of all personal and financial information entrusted to us in the course of providing franchise financing brokerage services. This Policy describes how we collect, use, disclose, store, and protect that information, and explains your rights in relation to it.

FranMax operates in compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Ontario's applicable privacy legislation, and the professional obligations of FranMax Inc. (Brokerage) as a brokerage registered under the Trust in Real Estate Services Act (TRESA) in Ontario.

2. Information We Collect

In the course of providing franchise financing brokerage services, FranMax may collect the following categories of personal and financial information:

• Identity information: Full legal name, date of birth, government-issued identification details
• Contact information: Mailing address, telephone number, email address
• Financial information: Personal net worth statements, income documentation, bank statements, CRA Notices of Assessment, credit bureau data, and other financial records relevant to a financing application
• Business and transaction information: Franchise Disclosure Documents (FDDs), franchise agreements, business plans, cost estimates, lease information, and related transaction documentation
• Third-party verification data: Information obtained through open banking platforms, CRA direct-pull services, and independent contractor authentication in connection with FranMax's Verified Transaction Protocol™ and Commitment Guard™ processes
• Communications: Records of correspondence, instructions, and authorizations provided by you in the course of the engagement

We collect only the information reasonably necessary to provide the services you have engaged us to perform. We do not collect sensitive personal information (such as health or biometric data) unless you voluntarily provide it and it is relevant to your file.

3. How We Use Your Information

FranMax uses your personal and financial information solely for the following purposes:

• Assessing your eligibility for and structuring of Canada Small Business Financing Program (CSBFP) term loan financing and related instruments
• Preparing, assembling, and submitting financing applications to chartered bank lenders and other financial institutions on your behalf
• Verifying the completeness and accuracy of application materials in accordance with lender requirements
• Communicating with you and with relevant third parties (lenders, lawyers, franchisors) as authorized by you
• Fulfilling our legal and regulatory obligations as a TRESA-registered brokerage and CFA Support Services Member
• Maintaining records as required by applicable law and professional standards

We do not use your information for marketing, data analytics, profiling, or any purpose unrelated to the direct provision of services you have engaged us to perform.

4. Document Security and Storage

Canadian servers — always

All documents, financial records, and personal information provided to FranMax in connection with a financing engagement are stored exclusively on secure, Canadian-hosted servers. No client data is transferred to or stored on servers located outside Canada. This ensures your information remains subject to Canadian privacy law at all times.

Access controls

Access to your file and its contents is strictly limited to:

• The financial institution (chartered bank or approved lender) to which your application is submitted
• FranMax Inc. (Brokerage) associates working directly on your file, under the supervision of the Broker of Record
• Any third-party verification service engaged under your explicit authorization as part of the Commitment Guard™ or Verified Transaction Protocol™ process (e.g., open banking platforms, CRA direct-pull, independent contractor authentication services)
• Legal counsel or other professionals to whom you have specifically authorized disclosure

No other party has access to your file. FranMax does not share, sell, license, or disclose client information to any other party, including franchisors, real estate boards, or advertising platforms.

Technical safeguards

FranMax employs the following technical and organizational measures to protect your information:

• Encryption of data in transit (TLS/HTTPS) and at rest
• Password-protected, access-controlled document management systems
• Restricted access credentials issued only to authorized FranMax personnel
• Secure email protocols for transmission of sensitive documents
• Regular review of access permissions and third-party service agreements

5. Disclosure to Third Parties

FranMax does not disclose your personal or financial information to any third party except in the following circumstances:

• With your consent: When you have explicitly authorized us to share specific information with a specific party (e.g., a chartered bank, your franchise lawyer, or your accountant)
• As required by law: When disclosure is required by a court order, regulatory authority, or applicable legislation
• In connection with service delivery: To third-party verification services engaged as part of your financing application, under contractual confidentiality obligations no less protective than this Policy

We do not disclose client information to the franchisor whose system you are seeking to enter, or to any party whose interests may not be aligned with yours, without your explicit written authorization.

6. Retention and Disposal

FranMax retains your personal and financial information for as long as is reasonably necessary to fulfill the purposes described in this Policy, to comply with our legal and regulatory obligations, and to resolve any disputes that may arise in connection with our services. In general, this means client files are retained for a minimum of seven (7) years following the conclusion of an engagement, in accordance with applicable professional and tax record-keeping requirements.

At the end of the applicable retention period, personal information is securely destroyed or anonymized in a manner that prevents reconstruction.

7. Your Rights

Subject to applicable law, you have the right to:

• Access: Request confirmation of whether we hold personal information about you, and obtain a copy
• Correction: Request that inaccurate or incomplete information be corrected
• Withdrawal of consent: Withdraw consent to our use of your information (where our use is based on consent), subject to legal and contractual limitations
• Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated

To exercise any of these rights, please contact us using the information below. We will respond within 30 days of receiving a written request.

8. Website and Communications

This website (www.franmax.ca) uses Google Analytics to understand general visitor traffic and how our published content is used — for example, page views and report downloads. This is aggregate, non-identifying usage data; it does not include your name, contact details, or anything you submit through a form on this site. Analytics data is processed using Google's standard infrastructure, which may be located outside Canada. This is distinct from the financial and application documents you share with us directly as a client, which remain exclusively on secure, Canadian-hosted servers as described in Section 4. Contact forms and email links on this website transmit information directly to FranMax and are not processed by advertising or data-brokerage platforms.

Email communications with FranMax should not be used to transmit sensitive financial documents unless you have been provided with a secure upload method. When in doubt, call us directly.

9. Changes to This Policy

FranMax reserves the right to update this Privacy & Security Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. Any material changes will be posted on this page with an updated effective date. We encourage clients to review this Policy periodically.

10. Contact and Privacy Officer

Questions, requests, or concerns relating to this Policy or FranMax's handling of personal information should be directed to:

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca or 1-800-282-1376.