COOKIE POLICY

Version 2.1 · Effective 05.05.2026 · FINTRAC Registration No. C100000462

INTRODUCTION AND SCOPE

Purpose of this Policy

URIGHTCOMPANY FINANCE LIMITED hereinafter — the "Company" — uses cookies and similar technologies on its website, customer portal, payment pages, and related digital services to ensure proper functionality, security, performance, compliance, and user experience.

This Cookie Policy explains what cookies are, what types of cookies the Company may use, why they are used, and how users may manage their cookie preferences.

Application of this Policy

This Policy applies to all visitors and users of the Company's website and online services.

This Policy should be read together with the Company's Privacy Policy, Terms and Conditions, AML/CTF Policy, KYC procedures, Security Policy, and other applicable legal and compliance documents.

Privacy and Regulatory Commitment

The Company processes information collected through cookies in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA), and other applicable privacy laws.

Where the Company provides services to users located outside Canada, additional privacy and electronic communications requirements may apply, including the UK GDPR, the Privacy and Electronic Communications Regulations (PECR), the EU General Data Protection Regulation (GDPR), and applicable ePrivacy requirements.

The Company applies appropriate technical and organizational safeguards to protect information collected through cookies and similar technologies.

WHAT ARE COOKIES

Definition of Cookies

Cookies are small text files placed on a user's device, browser, or application when the user visits a website or uses an online service. Cookies allow the website to recognize the user's browser or device, maintain secure sessions, remember preferences, and improve the overall user experience.

Similar Technologies

For the purposes of this Policy, the term "cookies" also includes similar technologies, such as pixels, tags, scripts, local storage, session storage, device identifiers, and other technical tools that may be used to support website functionality, analytics, security, fraud prevention, or compliance controls.

Cookie Duration

Cookies may be:

  • Session Cookies: temporary cookies that are deleted when the browser is closed.
  • Persistent Cookies: cookies that remain on the device for a defined period or until deleted by the user.

Cookie Source

Cookies may also be:

  • First-Party Cookies: cookies placed directly by the Company.
  • Third-Party Cookies: cookies placed by external service providers acting on behalf of, or in connection with, the Company's website and services.

TYPES OF COOKIES USED BY THE COMPANY

Strictly Necessary Cookies

Strictly necessary cookies are required for the website and online services to operate properly. These cookies support essential functions, including:

  • page navigation;
  • secure login and authentication;
  • access to protected areas;
  • session management;
  • system availability and load balancing;
  • protection against unauthorized access;
  • fraud prevention and cybersecurity controls;
  • cookie consent management.

These cookies cannot generally be disabled through the Company's website because they are necessary to provide the requested online service.

Security and Fraud Prevention Cookies

Given the nature of the Company's activities as a Canadian Money Services Business and payment-related service provider, the Company may use cookies and similar technologies to support security, fraud prevention, and compliance controls.

Such technologies may be used to:

  • detect suspicious access attempts;
  • identify automated activity, bots, abuse, or misuse;
  • support device recognition and session integrity;
  • prevent unauthorized account access;
  • detect unusual behavior patterns;
  • support fraud, sanctions, AML/CTF, and transaction-risk monitoring where applicable.

These measures assist the Company in protecting customers, merchants, transactions, and the integrity of its financial services.

Functional Cookies

Functional cookies allow the Company's website and online services to remember user preferences and provide enhanced functionality, including:

  • language preferences;
  • region or country settings;
  • user interface preferences;
  • previously selected settings;
  • saved form information where permitted.

Disabling functional cookies may affect the availability or quality of certain website features.

Analytics and Performance Cookies

Analytics and performance cookies help the Company understand how users interact with its website and online services. These cookies may collect information regarding:

  • pages visited;
  • time spent on the website;
  • website errors;
  • browser type;
  • device type;
  • traffic sources;
  • general usage patterns.

The Company may use analytics tools, including Google Analytics or similar services, to monitor website performance, improve functionality, and enhance the user experience.

Marketing and Communication Cookies

The Company may use limited marketing or communication cookies to assess the effectiveness of business communications and website content.

These cookies may assist the Company in:

  • measuring campaign performance;
  • improving website content;
  • understanding user interest in business services;
  • reducing irrelevant or repetitive content.

The Company does not knowingly use cookies to collect sensitive personal information for advertising purposes.

Third-Party Cookies

Third-party cookies may be placed by external service providers that support the Company's website, analytics, cybersecurity, hosting, infrastructure, payment technology, customer communications, fraud prevention, or compliance processes.

Such third parties may process information in accordance with their own privacy and cookie policies.

PURPOSES FOR USING COOKIES

Operational Purposes

The Company uses cookies to ensure that its website and digital services operate reliably and securely. This includes maintaining website functionality, enabling navigation, supporting authentication, and preserving secure user sessions.

Security and Compliance Purposes

Cookies may be used to support:

  • fraud prevention;
  • cybersecurity monitoring;
  • detection of unauthorized access;
  • prevention of misuse or abuse;
  • transaction and account security;
  • compliance-related risk monitoring where applicable.

User Experience Purposes

Cookies help the Company remember user preferences, improve usability, and provide a more consistent online experience.

Analytics and Improvement Purposes

Cookies allow the Company to understand how users interact with the website, identify technical issues, measure performance, and improve the quality of online services.

Business Communication Purposes

Where permitted by applicable law, cookies may be used for limited business-to-business communication analytics and website content optimization.

COOKIE CONSENT

Consent Requirement

Where required by applicable law, including Canadian privacy requirements, UK PECR / UK GDPR, and EU ePrivacy / GDPR requirements, the Company will obtain user consent before placing non-essential cookies or similar technologies on the user's device.

Strictly necessary cookies may be used without consent where they are required to provide the website or service requested by the user, maintain security, authenticate sessions, prevent fraud, or support essential technical operations.

Non-Essential Cookies

Analytics, performance, functional, marketing, advertising, and other non-essential cookies will not be activated before the user has provided valid consent, where such consent is required by applicable law.

Consent Standard

Where UK or EU requirements apply, consent must be freely given, specific, informed, and unambiguous. The Company does not rely on silence, pre-ticked boxes, inactivity, or continued browsing as valid consent for non-essential cookies.

Consent Management

Users may be provided with options to:

  • accept all cookies;
  • reject non-essential cookies;
  • manage cookie preferences by category.

Users may change or withdraw consent at any time through available website settings, browser settings, or other consent-management tools provided by the Company, where applicable.

Effect of Refusing Consent

Refusing or withdrawing consent for non-essential cookies will not prevent users from accessing the Company's website or services, although certain optional features, preferences, analytics, or personalization functions may be limited.

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

MANAGING COOKIES

Browser Controls

Users may manage cookies through their browser settings. Most browsers allow users to:

  • view stored cookies;
  • delete existing cookies;
  • block all cookies;
  • block third-party cookies;
  • allow cookies from specific websites only;
  • receive warnings before cookies are stored.

Effect of Disabling Cookies

Disabling cookies may affect the functionality, security, availability, or usability of the Company's website and online services. Certain secure areas, login functions, payment-related pages, or user preferences may not operate properly if cookies are disabled.

Third-Party Controls

Where cookies are placed by third-party providers, users may also manage preferences through tools or settings made available by those providers.

DATA COLLECTED THROUGH COOKIES

Categories of Data

Depending on the cookie type, the Company may collect or process the following information:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • approximate location based on IP address;
  • pages visited;
  • session identifiers;
  • login or authentication status;
  • security and fraud-prevention signals;
  • language and regional preferences;
  • referral source and interaction data.

Payment Card Information

The Company does not use cookies to collect full payment card numbers or full payment credentials. Payment information is processed through secure payment infrastructure and tokenization practices where applicable.

Sensitive Data

The Company does not knowingly use cookies to collect sensitive personal information unless required for security, legal, compliance, or fraud-prevention purposes and permitted by applicable law.

THIRD-PARTY TOOLS AND SERVICE PROVIDERS

Use of Third-Party Tools

The Company may use third-party tools and service providers to support:

  • website analytics;
  • cybersecurity and threat monitoring;
  • hosting and infrastructure;
  • payment-related technology;
  • customer communications;
  • fraud prevention;
  • compliance and risk controls.

Third-Party Policies

Third-party providers may set their own cookies or similar technologies. The Company does not control all third-party cookie practices. Users are encouraged to review the privacy and cookie policies of such providers.

Risk-Based Oversight

Where appropriate, the Company applies risk-based oversight to third-party providers that support its website, technology, payment, security, or compliance functions.

DATA PROTECTION AND SECURITY

Security Measures

The Company applies appropriate technical and organizational measures to protect information collected through cookies from unauthorized access, disclosure, alteration, misuse, or loss.

Access Controls

Access to cookie-related data is limited to authorized personnel and service providers who require such access for legitimate business, technical, security, compliance, or legal purposes.

Data Protection Standards

Where applicable, cookie-related data is processed in accordance with Canadian privacy legislation, PIPEDA, UK GDPR, EU GDPR, and other relevant data protection requirements.

RETENTION OF COOKIE DATA

Retention Periods

Cookies are retained for different periods depending on their purpose and category.

  • Session cookies are generally deleted when the browser is closed.
  • Persistent cookies remain for a defined period or until deleted by the user.
  • Security-related records may be retained as required for fraud prevention, audit, legal, or compliance purposes.

Limitation of Retention

The Company does not retain cookie-related data for longer than necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by law.

POLICY REVIEW AND UPDATES

Periodic Review

This Policy is reviewed periodically to ensure that it remains aligned with changes in technology, legal requirements, regulatory expectations, and the Company's business operations.

Publication of Updates

Any updates to this Policy will be published on the Company's website with a revised effective date.

Where changes materially affect the use of non-essential cookies or similar technologies, the Company may request renewed consent where required by applicable law.

CONTACT INFORMATION

For any questions regarding this Cookie Policy or the Company's use of cookies and similar technologies, please contact:

  • Email: [email protected]
  • Address: 1 - 4903 54 STREET, LLOYDMINSTER, SASKATCHEWAN, CANADA, S9V 0N6
  • Regulatory Reference: FINTRAC MSB Registration #C100000462