Privacy Policy

1. Our Commitment to Privacy

ValOre Metals Corp. and its subsidiaries (collectively, the “Company”) are committed to maintaining the security, confidentiality and privacy of the personal information in our possession. The Company has always respected your privacy and has strived to be an open and accessible organization. This Privacy Policy documents our ongoing commitment to those individuals whose personal information the Company may hold, including directors, officers, employees, consultants, shareholders, investors, subscribers to our communications, and visitors to our website.

This Privacy Policy has been developed in compliance with the British Columbia Personal Information Protection Act (“PIPA”) and, where it applies to the Company’s activities across provincial or national borders, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). It also reflects the requirements of Canada’s Anti-Spam Legislation (“CASL”) in respect of our electronic communications. The Policy continues to be based on the Canadian Standards Association (CSA) Model Code, which sets out ten principles that balance the privacy rights of individuals with the information requirements of private organizations.

2. Scope of Policy

This Privacy Policy addresses personal information about individuals. It applies to personal information the Company collects offline in the course of its business and to personal information collected through valoremetals.com and any related landing pages, forms, subscription services and advertising campaigns operated by or on behalf of the Company.

This Privacy Policy does not apply to information collected, used or disclosed with respect to corporate or commercial entities. Corporate and commercial information is protected by other Company policies and practices and through contractual arrangements.

This Privacy Policy does not impose any limits on the collection, use or disclosure of your business contact information or publicly available information.

Our website may contain links to third-party websites, including LinkedIn, VRIFY, SEDAR+ and news distribution services. This Privacy Policy does not apply to those websites, and we encourage you to review the privacy policies of any third-party site you visit.

3. Definitions

In this Privacy Policy:

“collection” means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means;

“consent” means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent may be given orally, in writing or electronically, if it is unequivocal and does not require any inference on the part of the Company. Implied consent exists when the Company can reasonably infer consent based upon your action or inaction;

“disclosure” means making personal information available to a third party;

“personal information” means information about an identifiable individual but does not include his or her business contact information. Personal information does not include information concerning corporate or commercial entities, and it does not include information that cannot be associated with a specific individual. Online identifiers such as IP addresses, cookie identifiers and device identifiers are treated as personal information where they can reasonably be associated with an individual;

“service provider” means an organization engaged by the Company to process personal information on the Company’s behalf and under the Company’s instructions, such as our website host, customer relationship management platform, email distribution platform and analytics providers;

“third party” means an individual or organization other than the Company and you;

“use” means the treatment and handling of personal information by and within the Company;

“you” and “your” refer to persons whose personal information the Company may have, including directors, officers, employees, consultants, shareholders, investors, subscribers and website visitors.

4. Accountability

The Company is accountable and responsible for personal information under its control. The Company has designated the Corporate Secretary as the Privacy Officer accountable for the Company’s compliance with this Privacy Policy.

Ultimate accountability rests with the Company’s Board of Directors, which delegates day-to-day accountability to the Privacy Officer. Other individuals within the Company may be accountable for the day-to-day collection and processing of personal information or may act on behalf of the Privacy Officer.

The Company remains accountable for personal information transferred to a service provider for processing. The Company uses contractual and other means to require service providers to protect personal information to a standard comparable to that described in this Privacy Policy, and to use that information only for the purposes for which it was transferred.

The Company maintains procedures to protect personal information and to receive and respond to complaints and inquiries.

5. Purposes for Collecting Personal Information

When collecting personal information, the Company will state the purpose of collection and will provide, on request, contact information for the Privacy Officer, who can answer questions about the collection.

The Company collects your personal information for the following purposes:

1. to manage and develop our business, including personnel and employment matters;
2. to establish, maintain and facilitate responsible communication with you, including responding to inquiries, maintaining shareholder and investor records, and distributing news releases, corporate updates and event invitations;
3. to operate, secure, maintain and improve our website, including diagnosing technical problems and preventing fraud and misuse;
4. to measure how our website and communications are used, so that we can improve their content and performance;
5. to plan, deliver and measure our advertising and marketing activities, including advertising delivered through Google and LinkedIn, and to show our advertising to individuals who have previously visited our website; and
6. to meet legal, regulatory and stock exchange requirements, including those of the TSX Venture Exchange and applicable Canadian securities legislation.

The above collection, use and disclosure are a reasonably necessary part of your relationship with the Company.

When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use and your consent will be sought, unless the use without consent is authorized or required by law.

The Company does not use personal information collected through its website to make automated decisions that produce legal or similarly significant effects about you.

6. Consent

The Company will obtain your consent to collect, use or disclose personal information except where the Company is authorized or required by law to do so without consent. The Company will make reasonable efforts to ensure that you understand how your personal information will be used and disclosed. Your consent may be express or implied, or given through an authorized representative such as a lawyer, agent or broker.

The Company may collect, use or disclose personal information without your knowledge or consent in exceptional circumstances such as:

1. the use of information is for acting in an emergency that threatens an individual’s life, health or personal security;
2. the information is publicly available;
3. the Company is collecting or paying a debt;
4. the Company is obtaining legal advice; or
5. the Company reasonably expects that obtaining consent would compromise an investigation or proceeding.

Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify the Company that you do not wish your personal information collected, used or disclosed for optional purposes following reasonable notice to you) or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application, subscription request or other information; or in writing when signing an agreement or application form.

Consent for online tracking

Cookies and similar technologies that are not strictly necessary to operate our website, including those used for analytics and advertising, are activated only after you provide consent through the cookie banner presented on your first visit. You may change or withdraw that consent at any time using the “Cookie Settings” link in the website footer. Strictly necessary cookies are always active because the website cannot function without them.

Withdrawing consent

You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal is given by you to the Company. Upon receipt of your notice, the Company will inform you of the likely consequences of the withdrawal, which may include the inability of the Company to provide certain services for which the delivery of that information is a prerequisite. If the information is required by law, the Company may decline to deal with a person who will not consent to the use of such information.

7. Limits on Collection of Personal Information

The Company will only collect personal information for the purposes identified in this Privacy Policy. The Company will use methods that are lawful and will not collect information indiscriminately. Website forms request only the information reasonably needed to respond to your request or to deliver the communications you have asked to receive. The Company may also collect information as authorized by law.

8. Limits for Using, Disclosing and Retaining Personal Information

Your personal information will only be used or disclosed for the purposes set out in this Privacy Policy and as authorized by law. The Company does not sell employee, shareholder or subscriber lists, or personal information, to third parties.

The Company may disclose personal information to its service providers as described in Sections 9 and 11, to its professional advisors, to its transfer agent and registrar, and to securities regulators, stock exchanges and other authorities where required or permitted by law. Personal information may also be disclosed in connection with a proposed or completed corporate transaction, subject to appropriate confidentiality protections.

The Company will retain personal information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation. As general guidance:

• Shareholder, director, officer and corporate records are retained for the periods required by applicable corporate and securities legislation.

• Contact and inquiry records held in our customer relationship management system are retained for the duration of the relationship and for a reasonable period afterward.

• Subscription records are retained until you unsubscribe, and a minimal suppression record is retained afterward so that we can honour your unsubscribe request.

• Website analytics data is retained in accordance with the retention settings configured in the relevant platform.

9. Information Collected Through Our Website

9.1  Information you provide to us

You can visit our website without telling us who you are. If you complete a contact form, subscribe to our news releases or corporate updates, register for an event, or otherwise contact us through the website, we collect the information you provide, which typically includes your name, email address, company or organization, and any message content you choose to send.

9.2  Information collected automatically

When you visit our website, our servers and service providers automatically record technical information such as your IP address, browser type and version, operating system, device type, referring website, the pages you view, and the date and time of your visit. This information is used to operate and secure the website and to understand how the website is used.

9.3  Cookies and similar technologies

Cookies are small text files placed on your device by a website. We also use similar technologies such as pixels and tags. We group them into the following categories:

• Strictly necessary: required for the website to function, including security, page delivery and remembering your cookie preferences. These are always active.

• Analytics: help us understand how visitors find and use the site so we can improve it.

• Advertising: used to measure the performance of our advertising and to show our advertising to individuals who have previously visited our website.

• Functional: support enhanced features and our customer relationship management, such as recognizing a returning contact who has previously completed a form.

Analytics, advertising and functional cookies are set only after you consent through our cookie banner.

9.4  Our website and marketing technology providers

The Company uses the following providers in connection with its website and marketing activities. Each acts as a service provider to the Company, except where noted below in respect of advertising platforms.

Provider	What it does on our website	Information involved	Where processed
WordPress	Operates and delivers the website, including page display and form functionality.	Strictly necessary session and preference cookies. No advertising or profiling use.	Canada
Google Analytics 4	Measures website traffic and how visitors move through the site so we can improve it.	Pages viewed, session activity, referring source, device and browser type, approximate location derived from IP address.	United States and other Google facilities
Google Ads	Measures the performance of our advertising and, where enabled, shows our ads to people who have visited the site.	Cookie and advertising identifiers, pages viewed, actions taken on the site.	United States and other Google facilities
LinkedIn Insight Tag	Measures the performance of our LinkedIn advertising and supports audience targeting.	Page visited, referring URL, truncated IP address, device and browser characteristics, timestamp. LinkedIn may match this to a member profile.	United States and other LinkedIn facilities
HubSpot	Customer relationship management, website forms, contact records, and email delivery and tracking for investor relations.	Name, email address, company, telephone, form submissions, pages viewed, email opens and clicks.	United States
Mailchimp	Distributes our email newsletters and news releases and manages subscription preferences.	Email address, name, subscription preferences, email opens and clicks, IP address, approximate location.	United States

Google and LinkedIn may also use information collected through their tags for their own purposes as independent controllers of that information, in accordance with their own privacy policies. Their privacy policies are available at policies.google.com/privacy and linkedin.com/legal/privacy-policy.

9.5  Managing your choices

You can manage the information collected about you online in the following ways:

• Cookie settings: use the “Cookie Settings” link in our website footer to change or withdraw your consent at any time.

• Browser controls: most browsers allow you to block or delete cookies. Blocking strictly necessary cookies may prevent parts of the website from working.

• Google advertising: you can manage the ads Google shows you through Google My Ad Center at myadcenter.google.com.

• Google Analytics: you can install the Google Analytics opt-out browser add-on available from Google.

• LinkedIn advertising: you can manage advertising preferences in the advertising data settings of your LinkedIn account.

• Email: you can unsubscribe from our communications at any time using the unsubscribe link in any email we send, or by contacting the Privacy Officer.

10. Electronic Communications

The Company sends commercial electronic messages, including news releases, corporate updates and event invitations, in accordance with Canada’s Anti-Spam Legislation. We send these messages only where we have your express consent, or where we are permitted to rely on implied consent, for example because of an existing business relationship or because you have conspicuously published or provided your business contact information without indicating that you do not wish to receive such messages.

Every commercial electronic message we send identifies the Company, provides current contact information, and includes an unsubscribe mechanism that can be readily performed at no cost. Unsubscribe requests are given effect promptly and in any event within ten business days. The Company maintains records of consent and unsubscribe requests.

Certain communications are not commercial electronic messages and may continue to be sent where required or permitted by law, including notices to shareholders under corporate and securities legislation.

11. Service Providers and Information Stored Outside Canada

The Company uses service providers to help operate its website, manage its contact records and distribute its communications. Some of these service providers, including those identified in Section 9.4, store and process personal information on servers located in the United States or in other countries.

While personal information is outside Canada, it is subject to the laws of the jurisdiction in which it is held. Personal information may be accessed by the courts, law enforcement agencies and national security authorities of that jurisdiction in accordance with those laws. This is the case for any organization that uses service providers located outside Canada.

Where the Company transfers personal information to a service provider, it uses contractual and other reasonable means to require the service provider to apply a comparable level of protection and to use the information only for the purposes for which it was transferred. The Company remains accountable for that information.

If you have questions about the Company’s policies and practices relating to service providers outside Canada, including how to obtain further information about those practices, please contact the Privacy Officer using the contact information in Section 15.

12. Accuracy

The Company will make a reasonable effort to ensure that personal information it is using or disclosing is accurate, complete and current as required for the purposes for which it was collected. In most cases, the Company will rely on you to ensure that certain information, such as your street address, email address or telephone number, is current, complete and accurate.

The Company will not routinely update information unless it is necessary to fulfill the purposes for which it was collected. You may request amendments to your personal information in our records. If appropriate, the Company will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, the Company will annotate the personal information under its control with a note that a correction was requested but not made.

13. Safeguarding Personal Information

The Company is committed to the safekeeping of your personal information in order to prevent its loss, theft, unauthorized access, collection, use, disclosure, duplication or modification.

Depending on the sensitivity of the information, the Company will take appropriate security measures to protect it. Specific safeguards include the physical security of offices, access controls and role-based permissions within our systems, encryption of information in transit, multi-factor authentication on business-critical accounts, and secure configuration of our website and hosting environment. The Company will also take reasonable steps, through contractual or other reasonable means, to require service providers to implement a comparable level of protection.

Confidentiality and security are not assured when information is transmitted through email or other wireless communication. If you choose to communicate with the Company in this manner, it is at your own risk. The Company will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when you transmit information to the Company by email or other wireless communication, or when the Company transmits such information by such means.

The Company will use appropriate security measures when disposing of your personal information so as to prevent unauthorized access to such information.

Response to privacy breaches

The Company maintains a procedure for responding to any loss of, or unauthorized access to, personal information in its custody or control. The Company will contain and investigate the incident, assess whether it creates a real risk of significant harm to any individual, and where that threshold is met will notify affected individuals and the applicable privacy commissioner as required by law and without unreasonable delay. The Company maintains records of privacy breaches.

The development of the Company’s policies and procedures for the protection of personal information is an ongoing process.

14. Openness

The Company is open about the policies and procedures it uses to protect your personal information. This Privacy Policy is published on the Company’s website and is available in writing on request. However, to ensure the integrity of our security procedures and business methods, the Company may decline to publicly disclose certain information.

15. Providing Access to Your Personal Information

You have a right to access your personal information held by the Company.

Upon written request and proof of your identity, the Company will, within a reasonable time period, tell you what personal information it holds, what it is being used for, and give you a description of the individuals and organizations to whom such information has been disclosed. The Company may ask you to be specific about the information you would like to access.

The Company may charge a reasonable fee for providing personal information in response to an access request and will provide an estimate of any such fee upon receiving a written access request. The Company may require a deposit for all or part of the fee.

The Company will make the personal information available within 30 days or provide written notice where additional time is required to fulfill the request.

In some situations, the Company may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor and client privilege, the information was collected for the purpose of an investigation, or where there are legal, security or commercial proprietary reasons for not providing access.

Where an access request is refused in whole or in part, the Company will notify you in writing, giving the reason for refusal and outlining the further steps available to you.

16. Questions and Complaints

Any complaints, concerns or questions regarding this Privacy Policy, and any request to access, correct or delete your personal information or to withdraw your consent, must be directed in writing to the Privacy Officer. If the Privacy Officer is unable to address your concern, the issue may be referred to the office of the Chief Executive Officer.

Privacy Officer
Corporate Secretary, ValOre Metals Corp.
Suite 1020 – 800 West Pender Street
Vancouver, British Columbia  V6C 2V6
[email protected]

At any point in this process you may also write to the Office of the Information and Privacy Commissioner for British Columbia, or, in respect of matters governed by PIPEDA, to the Office of the Privacy Commissioner of Canada.

17. Changes to this Privacy Policy

The Company reviews this Privacy Policy periodically and may update it to reflect changes in its practices, its technology or applicable law. The effective date at the top of this Privacy Policy indicates when it was last approved. Material changes will be posted on our website. We encourage you to review this Privacy Policy when you visit our website.