BlueSky Club
Privacy Policy
This Privacy Policy explains how BlueSky Club collects, uses, discloses, retains, and protects personal information through its website, investor dashboard, public company share price page, login and password reset tools, administrative investor records, KYC document workflows, dividend records, and related communications. In this Policy, personal information means information about an identifiable individual. It may include contact details, identity documents, account records, financial information, investment records, dividend records, communications, device information, and other information that can identify a person. This draft is intended to align with Canadian private-sector privacy principles, including accountability, identifying purposes, meaningful consent, limiting collection, limiting use and disclosure, retention, accuracy, safeguards, openness, access, correction, and the right to challenge compliance. Depending on BlueSky Club’s location and investor base, Alberta, British Columbia, Quebec, or other provincial requirements may also apply.
1. Accountability
BlueSky Club is responsible for personal information under its control. BlueSky Club should designate a privacy officer or responsible contact to oversee privacy compliance, answer privacy questions, manage access and correction requests, and coordinate privacy incident response. Before publication, BlueSky Club should insert the privacy contact name or title, mailing address, email address, and telephone number. If BlueSky Club uses service providers, it remains responsible for using contractual and operational measures appropriate to the sensitivity of the information.
2. Information We Collect
BlueSky Club may collect information directly from investors, from authorized representatives, from submitted documents, from administrators, from service providers, and automatically through website technology.
⁃ Account information: name, username, password credentials, email address, phone number, mailing address, profile photo, account status, and communication preferences.
⁃ Investor profile information: investor number or record ID, units purchased or allocated, share price records, estimated dashboard value, dividend records, dates, notes, and account history.
⁃ Investor profile information: investor number or record ID, units purchased or allocated, share price records, estimated dashboard value, dividend records, dates, notes, and account history.
⁃ KYC and identity information: government-issued identification, date of birth, residency, citizenship, tax residency, occupation, beneficial ownership details, corporate documents, trust documents, source-of-funds information, signatures, and supporting compliance documents where applicable.
⁃ Payment and transaction information: cheque details, payment confirmations, dividend payment records, receipts, tax-related documents, and administrative records of accepted or rejected transactions.
⁃ Communication information: emails, contact form messages, support requests, consent records, document requests, notices, and administrator notes.
⁃ Communication information: emails, contact form messages, support requests, consent records, document requests, notices, and administrator notes.
3. Purposes for Collection, Use, and Disclosure
BlueSky Club identifies purposes for collecting, using, and disclosing personal information before or at the time of collection, unless the purpose is obvious and the individual voluntarily provides the information for that purpose.
⁃ To create, authenticate, maintain, secure, and support investor accounts.
⁃ To verify identity, confirm investor eligibility, perform KYC or compliance review, and maintain legal documentation.
⁃ To record share purchases, allocations, unit totals, saved share prices, estimated values, dividend records, receipts, and investor history.
⁃ To administer offline cheque payments or other approved payment processes and reconcile company records.
⁃ To communicate account notices, security notices, document requests, dividend information, policy updates, and support responses.
⁃ To comply with applicable Canadian corporate, securities, tax, privacy, anti-spam, anti-fraud, accounting, audit, and legal obligations.
⁃ To protect the website, investors, BlueSky Club, and service providers from unauthorized access, misuse, fraud, cyber threats, errors, and unlawful activity.
⁃ To improve website reliability, accessibility, dashboard usability, reporting, and administrative workflows.
4. Consent
BlueSky Club seeks meaningful consent for the collection, use, and disclosure of personal information, except where consent is not required or an exception is permitted by law. Consent may be express or implied depending on the sensitivity of the information, the reasonable expectations of the individual, and the purpose of collection. Because investor records, KYC documents, identity information, financial information, and tax-related information can be sensitive, BlueSky Club should generally use clear express consent when collecting or using those categories, unless another lawful basis or exception applies. You may withdraw consent where permitted by law by contacting BlueSky Club. Withdrawal may limit or prevent BlueSky Club from providing account access, maintaining an investor dashboard, processing documents, confirming eligibility, paying dividends, or satisfying legal requirements.
5. Limiting Collection
BlueSky Club will limit personal information collection to what is reasonably necessary for identified purposes. BlueSky Club should not request more identity, financial, tax, or document information than it reasonably needs for investor administration, compliance, security, legal obligations, and recordkeeping.
6. Limiting Use, Disclosure, and Retention
BlueSky Club will use and disclose personal information only for the purposes described in this Policy, for purposes reasonably related to those purposes, with consent, or as otherwise permitted or required by law.
Personal information will be retained only as long as reasonably necessary for the purposes described in this Policy, including account administration, investor records, legal compliance, audit, tax, dispute resolution, security, and backup purposes. Retention periods may be longer where required by corporate, securities, tax, accounting, anti-money laundering, limitation period, or other legal obligations.
When personal information is no longer required, BlueSky Club should securely delete, anonymize, archive, or restrict access to it according to its retention practices and legal obligations.
7. KYC, Investor Qualification, and Sensitive Documents
BlueSky Club may collect and store KYC, investor qualification, identity, financial, residency, tax, beneficial ownership, corporate, trust, and related compliance documents. These documents may include highly sensitive information and may be visible only to authorized administrators, professional advisors, or service providers who need access for permitted purposes.
BlueSky Club should limit internal access to KYC and compliance documents, keep records of document uploads and updates where practical, and use reasonable safeguards to reduce the risk of unauthorized access, misuse, loss, or disclosure.
8. Disclosure to Service Providers and Third Parties
BlueSky Club may disclose personal information to service providers and advisors that help operate the website, dashboard, records, and investor administration processes. These may include hosting providers, WordPress developers, security providers, email providers, document storage services, accountants, auditors, banks, payment processors, legal counsel, compliance consultants, tax advisors, and IT support providers.
BlueSky Club may also disclose information where required or permitted by law, including to courts, regulators, tax authorities, law enforcement, government agencies, securities authorities, corporate transaction parties, insurers, or other persons where necessary to protect rights, investigate fraud or security issues, comply with legal obligations, or complete a business transaction.
BlueSky Club does not sell personal information in the ordinary sense of selling investor data to data brokers. If that practice changes, this Policy should be updated and consent should be obtained where required.
9. Cross-Border Processing
Some service providers may process or store personal information outside the province or territory where BlueSky Club or the investor is located, including outside Canada. When information is processed in another jurisdiction, it may be accessible to courts, law enforcement, national security authorities, or regulators in that jurisdiction according to local law.
BlueSky Club should use contractual, technical, and organizational safeguards appropriate to the sensitivity of the information when using service providers. Individuals may contact BlueSky Club for information about its use of service providers and cross-border processing practices.
10. Safeguards
BlueSky Club uses reasonable physical, organizational, contractual, and technical safeguards appropriate to the sensitivity of the information. Safeguards may include access controls, password protection, role-based administrator permissions, secure hosting, encryption where appropriate, backups, audit logs, employee or contractor confidentiality obligations, security monitoring, malware protection, and document access restrictions.
No website, email system, hosting environment, or electronic storage method is completely secure. You are responsible for protecting your own account credentials, using secure devices, keeping your email account secure, and promptly reporting suspected unauthorized access.
11. Accuracy
BlueSky Club relies on investors and administrators to keep personal information accurate, complete, and current. Investors should promptly notify BlueSky Club of changes to name, contact information, tax residency, banking or payment details, authorized representatives, or other information relevant to account administration or compliance.
BlueSky Club may ask for updated documents or confirmation of information from time to time. Inaccurate or outdated information may delay document review, dividend processing, account access, or compliance approval.
12. Access and Correction Rights
Subject to exceptions under applicable law, individuals may request access to personal information BlueSky Club holds about them and may request correction of inaccurate or incomplete information. BlueSky Club may need to verify identity before responding.
Access may be limited where disclosure would reveal another person’s personal information, confidential commercial information, legally privileged information, security-sensitive information, or information that cannot be disclosed under law. If BlueSky Club refuses access or correction, it should explain the reason where permitted.
13. Cookies, Analytics, and Website Technology
The website may use cookies, pixels, logs, analytics tools, security tools, and similar technologies to operate the site, remember sessions, protect login areas, support password reset flows, measure page performance, detect abuse, and understand general website usage.
You can adjust browser settings to refuse or delete cookies. Some features, including login, security, forms, and dashboard functions, may not work properly without required cookies.
14. Commercial Electronic Messages
BlueSky Club may send electronic messages about account administration, security, document requests, dividend records, investor notices, and policy updates. Where a message is a commercial electronic message under Canada’s Anti-Spam Legislation, BlueSky Club will seek consent and include required identification and unsubscribe information unless an exemption applies.
Unsubscribing from marketing messages will not necessarily stop transactional, legal, security, investor record, dividend, or account administration messages that BlueSky Club is permitted or required to send.
15. Privacy Breaches
BlueSky Club should maintain procedures for identifying, containing, investigating, documenting, and responding to privacy incidents. Where a breach creates a real risk of significant harm, BlueSky Club may be required to notify affected individuals, report to the Office of the Privacy Commissioner of Canada or another applicable regulator, and keep records as required by law.
If you believe your account or personal information has been compromised, contact BlueSky Club promptly using the privacy contact information published on the website.
16. Children and Minors
The website and investor dashboard are not intended for children. BlueSky Club does not knowingly collect personal information from minors except where necessary for lawful investor administration and with appropriate consent or authority. If you believe a minor’s information has been provided without proper authority, contact BlueSky Club.
17. Changes to This Policy
BlueSky Club may update this Privacy Policy from time to time. The effective date identifies the latest version. If changes are material, BlueSky Club may provide additional notice through the website, dashboard, email, or another reasonable method. Where required, BlueSky Club will seek renewed consent before using or disclosing personal information for new purposes.
18. Questions, Requests, and Complaints
Questions, access requests, correction requests, consent withdrawal requests, or complaints should be sent to BlueSky Club’s privacy contact. Before publication, BlueSky Club should insert the exact privacy contact email, mailing address, and phone number.
If you are not satisfied with BlueSky Club’s response, you may have the right to contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner, depending on the privacy law that applies.
Appendix A: Data Category and Retention Guide
The following guide is intended to help BlueSky Club configure internal retention and access practices. It should be reviewed with counsel and accountants before publication or implementation.
⁃ Account and profile records: retain while the account is active and for a reasonable period afterward for legal, audit, tax, and dispute purposes.
⁃ KYC and investor qualification records: retain as required by applicable compliance, securities, corporate, tax, audit, anti-fraud, and limitation period obligations.
⁃ Share allocation and dividend records: retain as official investor administration records for as long as necessary to support corporate, accounting, tax, audit, and investor history obligations.
⁃ Website logs and security records: retain for a limited period appropriate for security, fraud prevention, troubleshooting, and legal investigation needs.
⁃ Contact form and support messages: retain as long as needed to respond, maintain account history, manage disputes, and meet legal obligations.
Appendix B: Plain-Language Privacy Summary
BlueSky Club should consider placing a short privacy summary near registration, login, investor onboarding, KYC upload, and dividend documentation workflows. A plain-language summary may improve meaningful consent and investor trust.
⁃ We collect identity, contact, investor, KYC, transaction, dividend, and website information to administer your investor account and comply with legal obligations.
⁃ Some information, especially identity, financial, tax, and KYC documents, is sensitive and may be visible only to authorized administrators.
⁃ We use service providers and professional advisors to operate the website, protect data, maintain records, and support compliance.
⁃ You can request access to your personal information, ask for corrections, and ask questions about privacy by contacting BlueSky Club.
⁃ We keep information only as long as reasonably necessary for account administration, legal, tax, audit, security, and dispute purposes.