Privacy Policy

Last Updated: November 20, 2025

Loon Technology Inc. ("Loon", the "Company", "we", or "us") values and respects your privacy. We have prepared this privacy policy to describe the manner in which we collect, use, disclose and otherwise process personal information when you visit our website located https://loon.finance (the "Website"), or otherwise interact with us.

The Company issues (mints) and redeems (burns) the Canadian dollar stablecoin CADC ("CADC"). The Company maintains a crypto trading platform, offering institutional clients ("Customers") the ability to purchase CADC with Canadian dollars ("CAD"), and redeem CADC for CAD, all through the Website (the "Platform"). The Company is the sole counterparty to each trade in CADC and at the time of purchase, CADC is immediately delivered to a Customer's digital wallet. The Company does not provide custodial services and therefore does not custody CADC on behalf of Customers. The Company also offers a solution that allows our Customers to use an Application Programming Interface ("API") to permit our Customers' users to buy and/or sell CADC (the "API Solution").

Table of Contents

Collection and Use of Personal Information

Means of Collection

We collect personal information that you provide directly to us (through our Website, or through other communication channels) as well as information your devices provide to us automatically.

Information we collect and use:

  • Use of the API Solution: When you are a Customer or act as a representative of one of our Customers, we may collect certain information from you, including first and last name, corporate email address, corporate phone number, business title, legal corporate name, business number, nature of business, incorporation date and jurisdiction, and payment information, to administer our Customer's account, including for billing and accounting purposes, and to provide the API Solution.
  • Registering for an Account: You will be asked to create an account before you can use the Platform. We collect your name, phone number, email address, date of birth, residential address, and occupation. We use this information to authenticate your request for an account and to create and administer your account. If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

    Once your account is activated, we may collect certain limited information to create your profile, and information about your device's registered locale and language preferences.
  • Know Your Customer ("KYC") Verification: You are required to complete the KYC verification before using the Platform. To verify your identity, we collect a picture of the front and back of your government-issued identification (e.g., driver's license, ID card, passport, or residency permit card) that you provide us or one of our service providers, and a "selfie" image, which is then compared to the picture of your ID to validate your identity. We also collect your name, email address, phone number, date of birth, residential address, and occupation, along with your status as a politically exposed person, if applicable, for KYC purposes. If you are a director of, or have an ownership stake in, one of our corporate Customers, we may also collect your name and your association with the corporate Customer.
  • Issuing CADC: We may collect your personal information when you purchase CADC, or otherwise fund your account on the Platform, including your name, email address, phone number, business address, and transaction and financial information (including: for bank transfers, details and account information such as name of financial institution, financial institution number, account number and type, and transit number; and for Interac e-Transfer details such as associated name, email address and reference number) and transaction history such as a full record of your transactions, including assets traded, amounts, price, and fees. We may also collect your wallet address, and information about your source of funds, when you use CAD to purchase CADC to comply with anti-money laundering ("AML") requirements.
  • Visit our Website: You do not have to register to visit or use our Website. However, we may collect certain personal information when you visit our Website. Please see the "Information About Our Website" section below for detailed information regarding the personal information we collect when you visit and use our Website, and the choices you have with regards to that collection.
  • Marketing Communications: We may send you updates, newsletters, offers or other marketing communications using your email address. You can unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of each. Alternatively, you can opt out of receiving marketing communications by contacting us at the contact information provided under the "Contact Us" section below. Please note that you may continue to receive transactional or account-related communications from us for administrative purposes.
  • Attend an Event: If you attend one of our events or webinars, we may collect information such as your first and last name, company name, work email address, phone number and address, so that we can communicate with you about the event or webinar and contact you about future events or webinars.
  • Provide Feedback and Reviews: We may collect and use feedback and/or reviews about our Platform and services to better understand our customers, and to enhance our Platform and services. With your consent, we may publish your feedback and/or reviews on our Website or in other promotional materials.
  • Apply for a Job at Loon: In connection with an application or related inquiry for a job at Loon, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information to process and respond to your application for current and future career opportunities at Loon.
  • Surveys and Research: From time to time, we may offer you the opportunity to participate in one of our surveys or other research projects. We will collect certain personal information about you if you choose to participate in a research survey of ours. The information we collect will depend on the particular survey or research project and we will provide you with specific details regarding our information practices for that survey or research project prior to collecting any information from you. The information obtained through our surveys and customer research is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Website, and for auditing and data analytics.
  • Contests, Promotions and Sweepstakes: When you enter a contest or participate in a promotion or sweepstake, we may collect your name, address, email address, phone number, and any additional information or content required for the contest or promotion, including to deliver a prize to you. We use this information to administer your participation in the contest, promotion or sweepstake. As part of a contest, promotion or sweepstake, we may obtain your consent to share or otherwise publish the content you submit.
  • Contact Us: When you contact us with a comment, question or complaint about the Company through our web form, email or by phone, you may be asked for information that identifies you, such as your first and last name, email address and phone number, along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and service offerings.

Sharing of Personal Information

The Company do not sell, disclose or share your personal information with third parties without your consent, except for the following purposes or as required or permitted by law.

  • Service Providers: Your personal information will be transferred or otherwise made available to certain third parties (including affiliates) that provide services on our behalf. We use service providers to provide services such as KYC verification, AML compliance, customer inquiry support, IT support, hosting the Website, storing data, providing marketing assistance, conducting analytics, and providing customer service. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. We and our service providers may access, store and otherwise process personal information outside of Canada (including for residents of the Province of Quebec, outside of Quebec), including in the United States or other foreign jurisdictions, where we or our service providers are located.
  • Legal and Compliance: We and our Canadian, US and other foreign service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
  • Sale of Business: We may transfer any personal information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Company or as part of a corporate reorganization or other change in corporate control.

Information About Our Website

  • Visiting Our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Website and other information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website's activity and to monitor and improve our Website.
  • Cookies: Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a user's browser, which may then be stored on the user's hard drive so that we can recognize the user's computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website's features.
  • Analytics: We may use a third-party such as Google Analytics or Microsoft Clarity to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics' data privacy and security at the following links:For more information about Microsoft Clarity, and for information on how to opt-out of Microsoft Clarity-based analytics, please visit this link: https://learn.microsoft.com/en-us/clarity/faq.
  • Third-Party Links: Our Website may contain links to other websites and applications that the Company do not own or operate. We provide links to third-party websites and applications as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites or applications. The linked websites and applications have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites and applications, and therefore we have no responsibility or liability for the manner in which the organizations that operate such websites and applications may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

Safeguards and Retention

We have implemented administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We have measures in place that are designed to restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes of providing the services to our Customers, for the purposes set out herein, or as otherwise required to meet legal or business requirements.

Your Choices

Marketing Communications

As indicated above, if you receive our email marketing communications from the Company, you can unsubscribe any time by clicking the "unsubscribe" link included at the bottom of the email. Alternatively, you can opt out of receiving our marketing communications by contacting us at the contact information under the "Contact Us" section below.

Exercising Your Privacy Rights

Subject to applicable law and depending on the jurisdiction in which you are based, you have the right to access, update, rectify and correct inaccuracies in, and withdraw consent to the processing of, your personal information in our custody or control. You may make such a request or withdraw consent in respect of personal information for which we are accountable (see "Information we process on our own behalf") by emailing or writing to us using the contact information provided in the "Contact Us" section below. We may request certain personal information for the purpose of verifying your identity.

Information about our Privacy Governance Policies and Practices

We are committed to protecting personal information and have implemented a comprehensive set of policies and practices that govern our treatment of personal information. These policies and practices include:

  • policies and procedures designed to protect personal information in our custody and control from unauthorized access, use or disclosure;
  • processes to respond to data subject requests and complaints in a timely and effective manner;
  • policies and procedures to respond to privacy and security incidents;
  • a framework for the retention and destruction of personal information designed to ensure compliance with legal and contractual obligations, and to securely destroy personal information once no longer required;
  • a designated Privacy Officer who is responsible for overseeing the Company' compliance with privacy legislation;
  • a framework that contemplates the roles and responsibilities of our employees with respect to the treatment of personal information.

Updates to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated.

Contact Us

If you have any questions or comments about this Privacy Policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, please contact us at:

Privacy Officer

legal@loon.finance

If you have any questions regarding the personal information we process on behalf of one of our Customers, we encourage you to first contact the Customer directly or review their applicable privacy policy.