Upstream Living | upstreamhomes.ca

Effective date: June 27, 2026

1. Who we are

This Privacy Policy explains how Canvergence Investment Solutions Inc., operating as Upstream Living (“Upstream,” “we,” “us,” or “our”), collects, uses, discloses, stores, and protects personal information through our website at upstreamhomes.ca and in connection with our rent-to-own homeownership program (the “Program”). Upstream is committed to handling personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection Act (British Columbia) and, where applicable, the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA), together with other applicable laws relating to privacy, electronic communications, and records retention.

2. Scope of this policy

This Privacy Policy applies to personal information collected through our website, online forms, email, telephone, text and messaging communications, video meetings, and the day-to-day operation of the Program. This Privacy Policy does not apply to third-party websites, platforms, applications, services or content that we do not own or control, even if they are linked from our website.

3. Personal information we collect

Upstream may collect personal information that you provide directly to us, including your name, email address, telephone number, mailing address, preferred location, household and employment information, approximate income range, approximate credit profile, savings or down payment readiness, housing preferences, and the contents of communications you send to us. Where appropriate to assess or administer participation in the Program, and with consent where required by law, we may also collect additional information such as government-issued identification, financial information, income verification, banking information, landlord references, credit information, and other documents reasonably required for eligibility review, underwriting, fraud prevention, legal compliance, or transaction administration. When you use our website, we may automatically collect technical information such as your IP address, browser type, device type, operating system, referring pages, pages viewed, and general interaction data

through cookies and similar technologies.Upstream does not request more personal information than is reasonably necessary for the purposes identified in this Privacy Policy or otherwise disclosed at or before the time of collection.

4. Purposes for collection, use, and disclosure

Personal information may be collected, used, and disclosed only for purposes that a reasonable person would consider appropriate in the circumstances, including to:

(a) Respond to inquiries and provide information about the Program.

(b) Assess eligibility, suitability, and readiness for the Program.

(c) Verify identity, financial capacity, and other information relevant to the Program or related transactions.

(d) Provide educational materials, updates, and service communications.

(e) Administer and operate the Program, including intake, underwriting, coordination with third parties, document preparation, transaction management, and ongoing participant support.

(f) Send marketing or promotional electronic messages where permitted by law and with the required consent.

(g) Improve our website, services, operations, security, and user experience.

(h) Detect, prevent, or investigate fraud, misuse, security incidents, or unlawful activity.

(i) Comply with legal, regulatory, insurance, audit, tax, risk-management, and record-keeping obligations.

5. Consent

Upstream collects, uses, and discloses personal information with consent, except where collection, use, or disclosure without consent is authorized or required by applicable law. Consent may be express or implied, depending on the sensitivity of the information, the reasonable expectations of the individual, and the circumstances of collection. Express consent will generally be obtained for more sensitive personal information. By voluntarily providing personal information to Upstream, submitting forms, communicating with us, or participating in the Program application or administration process, you consent to the collection, use, and disclosure of your personal information for the purposes described in this Privacy Policy, as reasonably apparent from the circumstances, or as otherwise permitted or required by law. You may withdraw consent at any time on reasonable written notice, subject to legal, regulatory,

contractual, fraud-prevention, evidentiary, or operational restrictions. Withdrawal of consent may limit or prevent our ability to respond to your inquiry, assess eligibility, continue processing your application, administer your participation in the Program, or provide certain services.

6. Marketing communications and CASL

Upstream may send service-related electronic communications that are necessary to respond to inquiries, process applications, manage files, provide updates relating to the Program, or otherwise administer our relationship with you. Upstream may also send commercial electronic messages, including newsletters, educational content, offers, and promotional updates, only in accordance with applicable law, including Canada’s anti-spam legislation (“CASL”). Where required, Upstream will obtain the necessary consent before sending such messages. Commercial electronic messages sent by Upstream will include the information required by law, including identification of the sender and a functioning unsubscribe mechanism. Unsubscribe requests will be processed without delay and, in any event, within the time required by applicable law.

7. How we share your information

Upstream does not sell personal information. Personal information may be disclosed only as reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by law, including to:

(a) Service providers that support our website, cloud hosting, data storage, document management, customer relationship management, analytics, communications, payment processing, or security functions.

(b) Professional advisors and service partners, such as lawyers, mortgage professionals, accountants, consultants, insurers, and compliance providers, where reasonably necessary and subject to appropriate confidentiality or contractual protections.

(c) Property owners, investors, lenders, brokers, agents or other parties involved in evaluating, structuring, funding, documenting or administering a proposed or actual Program transaction, where the disclosure is reasonably necessary and lawful.

(d) Government bodies, regulators, courts, law enforcement agencies, or other persons where disclosure is required or permitted by law.

(e) A purchaser, successor, lender, investor, or other party involved in a proposed or completed financing, reorganization, merger, sale, or transfer of all or part of our business, subject to appropriate safeguards and lawful authority. Upstream may also disclose de-identified or aggregated information that does not reasonably identify an individual.

8. Storage and transfer outside Canada

Personal information may be stored or processed in Canada or in other jurisdictions, including the United States, by us or our third-party service providers. When information is processed in another jurisdiction, it may be accessible to courts, law enforcement, national security authorities, or regulators in that jurisdiction under its laws.

Upstream uses contractual, administrative, and other reasonable measures to require service providers to protect personal information in a manner appropriate to its sensitivity and consistent with applicable law.

9. Cookies and similar technologies

Our website may use cookies, pixels, tags, scripts, and similar technologies to enable site functionality, remember user preferences, understand site traffic and usage, improve performance, maintain security, and support communications or analytics features.

You may modify your browser settings to refuse, limit, or delete cookies, but doing so may affect the availability or functionality of some parts of the website. If non-essential analytics, advertising, or similar technologies are used, Upstream may provide additional notice or consent tools where required by applicable law.

10. Retention

Upstream retains personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to administer the Program, to satisfy legal, accounting, insurance, limitation-period, and regulatory requirements, or as otherwise permitted or required by law. When personal information is no longer required, we will securely destroy, erase, anonymize, or de-identify it, as appropriate.

11. Safeguards and breach response

Upstream uses reasonable physical, technical, and administrative safeguards appropriate to the sensitivity of the information to protect personal information against loss, theft, and unauthorized access, use, disclosure, copying, or modification. These measures may include restricted access, passwords, encryption or secure transmission methods where appropriate, staff confidentiality measures, and service-provider controls. No system can be guaranteed to be completely secure, and therefore absolute security cannot be assured. If a privacy breach occurs, Upstream will assess it and provide any notices required by applicable law.

12. Access, correction and complaints

Subject to applicable law, you may request access to the personal information we hold about you and request correction of inaccurate personal information. Requests must be made in writing using the contact information below, and we will respond within the time required by applicable law, subject to any lawful exceptions. If you have a concern or complaint about our privacy practices, you may contact our Privacy Officer in writing using the information below. We will review the matter and respond in accordance with applicable law.

13. Links to other websites

Our website may contain links to third-party websites or resources for convenience only. We do not endorse, and are not responsible for, the privacy practices, content, accuracy, security, terms, or policies of those third-party websites or resources. We encourage you to review the privacy policies of those third-party website.

14. Children

Our website and the Program are intended for adults who have reached the age of majority in the applicable province or territory. We do not knowingly collect personal information from children.

15. Changes to this policy

Upstream may amend this Privacy Policy from time to time to reflect changes in legal requirements, business practices, service providers, technology, or the Program. The updated version will be posted on the website with a revised effective date, and continued use of the website after any changes are posted constitutes acknowledgment of the updated Privacy Policy, to the extent permitted by law. We encourage you to review this policy periodically.

16. How to contact us

If you have questions about this Privacy Policy, would like to make an access or correction request, withdraw consent, or make a privacy complaint, please contact in writing our Privacy Officer:

Canvergence Investment Solutions Inc. o/a Upstream Living

Mailing address: Unit 139 – 4111 Hastings Street, Burnaby, BC V5C 2J3

Email: info@upstreamhomes.ca