Privacy policy

Title:	Privacy policy
Prepared by:	Robert Cloutier
Approved by:	Johnna Muinonen	Approval date:	Sept 17, 2023
Policy number:	Magneto 006	Replaces policy number:	N/A

Privacy Policy (hereinafter the Policy)

Magneto Investments LP is a company dedicated to the exploration, evaluation and development of mineral resources. The acquisition and responsible development of high-quality mine sites characterizes its vision of prosperous growth and development. Magneto Investments LP’s main project is the Dumont nickel project, strategically located in the Abitibi region in the municipalities of Launay and Trécesson.

The purpose of this Privacy Policy is to set out our practices with respect to the collection, use, disclosure and retention of personal information.

By providing us with personal information through our website, by submitting your application for employment, by completing a hiring form, by submitting an offer of service or a subscription request to our newsletter in person or remotely, you agree to its processing as set out in this Privacy Policy, and you authorize Magneto Investments LP, its third parties and service providers to process your personal information for the purposes set out below (see p4).

This Privacy Policy does not apply to, and Magneto Investments LP is not responsible for, any third-party Web sites that may be accessed through links on our Web site. If you follow a link to a third-party Web site, that Web site will have its own privacy policies that you should review before submitting any personal information.

By browsing our website or using our systems or services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data and information in accordance with this Policy, where applicable.

This Privacy Policy is composed of the following elements:

1. Objectives of the Privacy Policy

2. Entry into force

3. How to obtain consent

4. Data collection objectives

5. Personal information collected

6. Data processing purposes

7. The treatment processes used

8. Access to and control of personal information

9. Sharing and reasons for sharing personal information with third parties

10. Use of cookies and similar technologies

11. Retention of personal information

12. Changes to the Policy

13. Contact Magneto Investments LP

1. Objectives of the Privacy Policy

Respect for privacy and the protection of personal information are essential to Magneto Investments LP, which is why, through this Policy, we intend to protect personal information in accordance with applicable laws.

To ensure this protection, Magneto Investments LP will only collect, process and share personally identifiable information with the consent of the individual, unless permitted or required by law, in which case your consent will not be required.

The purpose of the Policy is to inform users of why and how Magneto Investments LP, or anyone acting on its behalf, will collect and use their personal information. It is intended to be in plain language to ensure informed consent from users.

For the purposes of this Policy, “personal information” means any information about an identifiable individual, or information that allows an individual to be identified. Wherever possible, we will anonymize, pseudonymize and/or aggregate such information so that it no longer identifies an individual.

2. Entry into force

This Policy applies from September 17, 2023.

3. How to obtain consent

Magneto Investments LP is committed to obtaining consent prior to collecting personal information from an individual. Consent may be express or implied and may be provided directly by the individual or by his or her authorized representative.

Magneto Investments LP prefers to obtain express consent, whether verbally, electronically or in writing. However, implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to receive a publication, or a name and telephone number to obtain an answer to a question, is considered implied consent to the collection of information containing personal information. In determining the appropriate type of consent, we take into account the sensitivity of the personal information involved, the purposes for which it is collected and the reasonable expectations of a similarly situated individual.

If we want to use personal information for a new purpose, we will describe the intended use and ask for consent again.

It is not always possible to obtain consent for the collection, use or disclosure of personal information, particularly in response to a request from the authorities. Magneto Investments LP will not disclose personal information other than in accordance with this Policy, except as required or permitted by law.

4. Data collection objectives

Information is collected in accordance with the purposes and objectives set out in this Privacy Policy.

Here are some of the reasons Magneto Investments LP may collect your personal information:

• For service tenders : We will collect and process the data and information necessary to fulfill our mission and contractual obligations.

• For human resources purposes. Data is collected for hiring purposes.

• For the newsletter. The information is saved for the purpose of sending company-related documents.

• To meet legal obligations. Data is collected to meet obligations arising from laws, regulations or international treaties.

5. Personal information collected

Magneto Investments LP may collect personal information in various forms, but will only do so by lawful means and only for the necessary purposes disclosed to you, as described in this Policy, or as permitted or required by law.

The personal information we collect, and its sensitivity, may vary depending on the context of your interactions with Magneto Investments LP. This is why it is our priority to inform you of the nature of the personal information we use.

Magneto Investments LP protects all personal information collected. Among the personal information that may be collected and used, we pay particular attention to :

• Name and contact information. First and last name, e-mail address, mailing address, telephone number and other similar data used to contact you.

• Demographic data. Information about you, such as your age, gender, country and language of communication.

• Biographical data. Data such as job title, employer, professional and/or personal background, photos and video or audio content.

• Professional data. Data on training courses and programs in which you are or have been enrolled; your networks, your social involvement, your professional affiliations.

• Payment data. Data required to process your payments, such as payment instrument number (e.g. bank details).

• Subscription data. Information about your newsletter subscriptions.

• Web interaction data. Data relating to your use of the websites, platforms and tools created. This is data that you provide in order to use the products. In other cases, such as error reports, this data is generated by us.

Other examples of interaction data that Magneto Investments LP collects include:

• Searches and orders. Search queries you make when using our website.
• Location data. Data, which may or may not be precise, about the location of your device. For example, it is possible to collect location data from a device’s IP address.
• Other data. Other data provided when you use our website, in particular data from Google Analytics or other sources.

Magneto Investments LP will not knowingly collect information from children or others under the age of 14. If you are a minor under the age of 14, please do not provide us with any personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to delete that information from our servers.

6. Data processing purposes :

Magneto Investments LP may use personal information in any of the ways listed below, with your consent or, where applicable, under another legal basis. In each case, we indicate the purposes for which we use your personal information:

• In order to facilitate the use of our websites, to ensure that content is relevant and presented in the most effective way for you and your device.

• For service offering purposes, to enable us to process and evaluate proposals.

• For recruitment purposes, to enable us to process job applications and assess whether an individual meets the requirements of the position for which they may be applying.

• To meet our legal, regulatory or risk management obligations.

• In order to reorganize or change our business, if we undertake a reorganization (for example, by merging, consolidating or divesting part of the business), we may be required to transfer some or all personal information to an applicable third party (or its advisors) as part of any due diligence process or transfer to such reorganized entity or third party for the same purposes as set out in this Privacy Policy or for the purposes of analyzing any proposed reorganization. In such a situation, we will take all possible steps to ensure the protection and security of personal information.

• Promotional communications. We use the data we collect to provide promotional communications.

7. The treatment processes used

Magneto Investments LP attaches the utmost importance to the security of your personal information and undertakes to treat it in accordance with industry standards and norms, solely for the purposes for which it is collected as described in this Policy or in a specific notice to that effect. However, given the inherent security limitations of transmission via the Internet, it is impossible to safeguard your personal information absolutely. Information transmitted to us is therefore ultimately at the user’s own risk.

8. Access to and control of personal information

Magneto Investments LP ensures that all personal information in its possession is as accurate, current and complete as necessary for the purposes for which it is to be used.

You have the right to request access to your personal information for verification purposes and to request a correction if your personal information is inaccurate. If you believe that your personal information is inaccurate, or if you wish to access your personal information, you may make a request using the contact information provided in the “Contact Magneto Investments LP” section.

To the best of our ability, we will provide you with timely access to your personal information. However, for security reasons, we may need to verify your identity.

There may be circumstances where we will not be able to provide you with access to your personal information. For example, where access may lead to the disclosure of another person’s personal information and that person refuses to consent to the disclosure, or where legal restrictions apply. If such a situation arises, we will notify you of the reason why we cannot provide you with access to your personal information.

If your request concerns data appearing on third-party web pages or platforms, please contact these third parties directly.

A response to requests for access to personal information and rectifications submitted by the persons concerned will be made within 30 days.

Finally, it is also possible to lodge a complaint with a data protection supervisory authority, more specifically in the country, province or state in which you normally reside (in Quebec, the Commission d’accès à l’information), in which we are located or in which an alleged breach of data protection laws has occurred.

To exercise any of these rights, please contact us as indicated in the “Contact Magneto Investments LP” section.

9. Sharing and reason for sharing personal information with third parties

Magneto Investments LP does not share your personal information with companies, organizations, or individuals outside of Magneto Investments LP, with the exception of our authorized suppliers and partners who need access to the information for the purposes listed in this Policy and within the limits of this Policy, as well as in the following cases:

Personal information may be shared with government authorities and law enforcement agencies when required by applicable laws. Specifically, we may disclose personal and other information if we are required to do so by tax or other laws, or if we believe in good faith that such disclosure is necessary to comply with applicable laws, in response to a court order or subpoena or government search warrant, or otherwise to cooperate with such government authorities and law enforcement agencies.

Personal information may be transferred to a purchaser, successor or assignee in connection with any merger, acquisition, debt financing, asset sale or similar transaction, as well as in the event of insolvency, bankruptcy or receivership involving the transfer of personal information as a business asset to one or more third parties;

10. Cookies and similar technologies

Magneto Investments LP may use cookies, web beacons, web beacons, web beacons, log files or other technologies to collect certain personal information about visitors to our Web sites, as well as about the recipients of our newsletters, invitations and other communications. Cookies are pieces of information transmitted by the server to the browser during a visit to the Web site that uniquely identify the current connection. This data may include information such as your Internet Protocol (IP) address, browser type, browser version, the pages of our site you visit, the time and date of your visit, the time spent on the site and any other statistics.

Cookies are used to retrieve session-related search history, to facilitate the user’s online browsing experience. It is important to note that, depending on the settings you choose, activating the cookies option may allow other servers to install cookies on your system. You can set your browser to inform you of the presence of cookies, giving you the chance to decide whether or not to accept them.

Please note that our Web site may contain links or references to third party sites. This Policy ceases to apply when you leave our Web site and Magneto Investments LP is not responsible for the collection or processing of personal information by or through such third parties or external sources.

11. Retention of personal information

Magneto Investments LP retains personal information only as long as is necessary for the purposes for which it was collected and to comply with legal and regulatory obligations. During the retention period, Magneto Investments LP takes physical and technical measures to ensure the security of data containing personal information.

The main locations where personal information is stored are the cities in which Magneto Investments LP has offices or facilities.

Personal information may be held outside the country in which you live, if a third-party supplier or other entity to whom we disclose personal information in accordance with this Policy is located outside the country. In such cases, personal information may be subject to the local laws of the countries or territories in which the information is collected, used, disclosed or stored, and may be accessible to the governmental and law enforcement authorities of those countries or territories.

Once the retention period has expired, personal information is destroyed. Only statistics or reports containing de-identified and anonymized data may be retained for extended periods of time.

For more information about how long Magneto Investments LP retains personal information, or if you have reason to believe that personal information has been compromised, please contact us at the coordinates listed in the “Contact Magneto Investments LP” section. We will take reasonable steps to reduce the risk of harm occurring and to prevent similar incidents in the future.

12. Changes to the Policy

Magneto Investments LP may make changes to this Privacy Policy from time to time. We will always indicate the date on which the latest changes were made.

Person responsible for compliance: Robert Cloutier

13. Contact Magneto Investments LP

If you have any questions, comments or complaints about this Policy, you can contact the person responsible for ensuring compliance with this Privacy Policy :

Robert Cloutier

Dumont Nickel

Magneto Investments LP

42 Trudel Street, Amos

Qc, J9T 4N1

Tel: 819 727-3777 #225

Cell : 819 218-0122