Last updated on September 10, 2026
1. INTRODUCTION AND SCOPE
1.1. Purpose of the Policy
This Cookies Policy (hereinafter – “Policy“) provides a clear, comprehensive, and transparent explanation of how HOLDEN TRANSFER INC., a company incorporated under the laws of the Province of Alberta, Canada (Corporate Access Number: 2028406771), having its registered and business address at 700-602 12 AVENUE SW, Calgary, Alberta, T2R1J3, Canada (hereinafter – “Company“, “We“, “Our“, or “Us“), uses cookies on its website and related digital interfaces.
1.2. Use of Necessary Cookies
The Company uses only cookies that are necessary for the proper, secure and reliable operation of the Website and related Service functionality. Such cookies may support essential functions including secure authentication, session management, security controls and the storage of cookie-related settings where applicable.
1.3. Regulatory Framework
This Policy is designed to empower you with full control over your digital footprint while ensuring the Company’s strict compliance with applicable Canadian data protection frameworks. Our deployment and management of tracking technologies are governed by:
- The Personal Information Protection and Electronic Documents Act (hereinafter – “PIPEDA”), S.C. 2000, c. 5, of Canada;
- The Personal Information Protection Act (hereinafter – “PIPA”), S.A. 2003, c. P-6.5, of the Province of Alberta.
Because the Company is organized and operates from Alberta, PIPA is the primary statute governing our deployment of cookies within the province; PIPEDA additionally applies to cookie data collected, used, or disclosed in the course of interprovincial or international commercial activity.
1.4. Scope and Applicability
For the purposes of this Policy, the relevant digital environment includes the Company’s Website and any secure web-based interfaces through which cookies are actually deployed. Accessing these Services or interacting with the digital infrastructure constitutes an explicit acknowledgment of the practices described in this Policy, which must be read and interpreted in conjunction with the overarching Privacy Policy and OTC Service Terms of Use.
2. UNDERSTANDING COOKIES
2.1. The Nature and Function of Cookies
Cookies are small text files containing a limited amount of data, which may include an anonymous unique identifier, that are sent to your browser and stored securely on your device (such as a computer, smartphone, or tablet) when you access our Service.
Necessary cookies are used to support essential Website functionality, maintain secure sessions, authenticate users where applicable, remember cookie-related settings and help protect the Website against unauthorized or malicious activity.
2.2. Operational Classification by Duration
To provide full transparency regarding how long data remains on your device, we classify our cookies by their lifespan:
- Session Cookies: These are temporary cookies that are permanently deleted from your device’s hard drive the moment your web browser is closed. In the context of our OTC operations, session cookies are absolutely vital. They maintain the integrity of a secure connection during a single active session, ensuring that your authenticated state and transaction requests are securely preserved while you navigate between different pages of the Service.
- Persistent Cookies: These cookies remain stored on a device for a defined period and may be used where necessary to remember essential settings, security-related choices or cookie-notice preferences.
2.3. Operational Classification by Provenance
Depending on which domain places the tracking technology on your device, cookies are further categorized as follows:
- First-Party Cookies: These are cookies that are set and managed directly by the Company’s website that you are visiting. They are primarily necessary files designed to establish core Service functionality, execute secure user requests, and enforce our internal security protocols.
3. CATEGORIES OF COOKIES WE DEPLOY
We deploy tracking technologies selectively, purposefully, and in strict adherence to the principles of data minimization and proportionality. Based on their specific operational function, the cookies utilized on our Service are systematically grouped into the following distinct categories:
Necessary Cookies
These cookies are essential for the proper functioning, security, and basic operation of our Service and the seamless delivery of our OTC services. They enable critical core features, including secure user authentication, active session management, and continuous access to secure, restricted areas of the site. These cookies act as our primary technological defense mechanism against fraudulent activity, ensuring the continuity of your trading sessions and orders while preventing unauthorized access.
- Consent Requirement: Because the Service cannot function securely or properly without them, these necessary cookies are placed automatically upon your arrival and do not require user consent.
- Operational Examples: Technical tokens for secure authentication, Cross-Site Request Forgery protection, and rate-limiting enforcement rules used to distinguish users sharing the same IP address and mitigate malicious traffic.
4. NECESSARY COOKIES AND CONSENT
The Company currently uses only cookies that are necessary for the proper and secure operation of the Website. Because these cookies are required to provide essential Website functionality, they are not subject to optional cookie preference controls.
Users may block or delete cookies through their browser settings; however, disabling necessary cookies may cause certain Website features to function improperly or become unavailable.
5. MANAGING YOUR COOKIE PREFERENCES
Users may manage, block or delete cookies through the settings of their web browser. Most browsers allow users to view stored cookies, delete existing cookies or block cookies from being placed.
Please note that restricting or disabling necessary cookies may affect the proper operation, security or availability of certain Website features.
Instructions for managing cookies are available through the help documentation provided by major browser providers, including Google Chrome, Microsoft Edge, Mozilla Firefox, Opera and Safari.
6. DATA RETENTION AND MINIMIZATION
6.1. Core Principles of Storage Limitation
The Company is committed to applying the core principles of data minimization, proportionality, and storage limitation concerning any data derived from cookies and analogous tracking technologies. All cookie data collected via our Service is securely retained only for the period necessary to fulfill its explicitly intended operational, or security purpose.
6.2. Retention Schedules by Cookie Function
We distinguish between different retention behaviors depending on the technical function and ownership of the specific cookie. Our retention periods are classified as follows:
- Session Data (Immediate Deletion): Session cookies are utilized exclusively for temporary purposes, such as maintaining secure session continuity and one-time authentication. These files are automatically and permanently deleted from your device the moment you close your web browser.
- Cookie Notice Preference: Where the Website uses a cookie to remember that a User has acknowledged the cookie notice, such cookie may remain stored for the period specified by the Website’s technical configuration.
6.3. Ongoing Review
The Company periodically reviews the cookies used on the Website and removes or replaces cookies that are no longer necessary for the purposes for which they were deployed.
7. AMENDMENTS TO THIS POLICY
7.1. Right to Modify and Update
The Company reserves the unilateral right to review, update, or comprehensively amend this Cookies Policy periodically. These modifications may be enacted to ensure our continued alignment with internal operational standards, cybersecurity best practices, and external legal obligations.
7.2. Drivers for Policy Revision
Such amendments will typically be implemented in direct response to evolving circumstances, which include, but are not limited to:
- Amendments to applicable Canadian data protection legislation (such as PIPEDA or PIPA) or new binding guidance issued by privacy supervisory authorities.
- Significant technological developments, cybersecurity infrastructure upgrades, or modifications to the functionality of our Service and OTC services.
- The integration of new, authorized third-party service providers or strategic changes in our broader business practices.
7.3. Notification of Changes
Where this Policy is updated, the Company will revise the “Last Updated” date at the top of the document. If the Company introduces new categories of cookies or materially changes the purposes for which cookies are used, this Policy will be updated accordingly and any consent mechanism required by applicable law will be implemented before such non-essential cookies are deployed.
7.4. Continued Acknowledgment
We strongly encourage you to review this Policy regularly to stay continuously informed about how we deploy tracking technologies and how you can manage your personal preferences. Users are encouraged to review this Policy periodically to remain informed about the Company’s use of cookies.
8. CONTACT INFORMATION
If you believe your rights concerning cookies or other tracking technologies have not been respected, you may also lodge a formal complaint with the Office of the Information and Privacy Commissioner of Alberta, the Company’s primary regulator under PIPA, or, for matters falling under PIPEDA, with the Office of the Privacy Commissioner of Canada.
If you have any technical questions, require further clarification regarding our deployment of tracking technologies, or wish to escalate a privacy concern, please direct your inquiries to our team:
Holden Transfer Inc.
Registered Office: 700-602 12 AVENUE SW, Calgary, Alberta, T2R1J3, Canada
Company Registration Number: 2028406771
Email: holden.transfer@gmail.com