Introduction
Clifton Blake Asset Management, its affiliates and managed investments (referred to herein, collectively, as “Clifton Blake”, “our”, “us” or “we”) has created the Privacy Policy to demonstrate our firm commitment to privacy. This Privacy Policy sets out the privacy procedures and practices of Clifton Blake with respect to the collection, use, and disclosure of personal information in connection with Clifton Blake’s websites, including websites for our projects (the “Website”).
In this Privacy Policy, “personal information” means information about an identifiable individual, as further defined under applicable Canadian laws, and “including” and its derivatives means “including without limitation”.
Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy at any time. If Clifton Blake makes any changes to the Privacy Policy, such changes will be posted on the Website and will be effective immediately thereafter. Your continued use of this Website after any changes constitutes your acceptance of the updated Privacy Policy. You agree to regularly review this Privacy Policy to be aware of any changes.
Collection and Use of Information
We collect information from visitors to the Website and others (each, referred to as an “Individual” or “you”) when an Individual: (i) uses the Website, (ii) contacts Clifton Blake with comments or questions and (iii) signs up to receive from time-to-time email news updates from Clifton Blake.
For greater certainty, the information collected by Clifton Blake from your use of the Website or as a result of you contacting Clifton Blake with comments or questions, includes but is not limited to information collected in our server logs (such as browser type, pages visited, referring page, IP address, date and time stamps, other statistics, and errors), through cookies (such as saving your login information and storing session information), and about the device you are using to access the Website (such as hardware and operating system details).
Not all information we collect identifies you or can be attributed as being identifiably about you when taken on its own. Similarly, we may aggregate your information with other information in a way that it is not attributable as being identifiably about you (including by aggregating it into groups or categories). This Privacy Policy does not apply to restrict our collection, use or disclosure of such anonymous or aggregated information. However, this same information may be considered personal information if we combine it with other information (such as identifiers like your name or address) in a way that makes it attributable as being identifiably about you. This Privacy Policy will apply to your information when it is combined in this identifiable way.
Clifton Blake uses such personal information as is reasonably required to: (i) maintain accurate records; (ii) make the Website more user-friendly; (iii) provide information to Individuals, as requested by them; and (iv) provide the requested services, and as is otherwise required or permitted by law. Clifton Blake may use personal information collected by it for additional purposes that may be identified at or before the time that the information is collected.
Our third-party service providers, including advertising service providers, may also use web beacons and cookies to collect personal information from your browser or device when you visit or use our Website. We and our service providers use this personal information to advertise to you, including by providing targeted advertisements to you on other websites. You may be able to change the preferences on your browser or device to prevent or limit the acceptance of cookies, but this may prevent you from taking advantage of some Website features. You may also opt-out of the use of cookies by contacting our Privacy Officer using the contact information provided below.
Clifton Blake will retain personal information only to the extent required for the purposes set out in this Privacy Policy, or as required or permitted by law. Clifton Blake will not use or disclose personal information other than for the purposes for which it was collected, unless an Individual has provided his or her consent or as otherwise required or permitted by law.
We may store or process your personal information on servers in jurisdictions outside of Canada, including in the United States of America. While your personal information is in a jurisdiction it may be accessed by the courts, law enforcement and national security authorities of that jurisdiction in accordance with the laws applicable in that jurisdiction.
Disclosure of Information
While Clifton Blake typically does not currently share, disclose or sell personal information with other companies or organizations, we may disclose personal information:
- To third party service providers and to affiliated entities in order to carry out work on our behalf.
- If you choose to share personal information publicly, with other users of the Website, or with other sites (such as social media sites), we may facilitate this sharing. We do not control these third parties that you might choose to share your personal information with or how they use your personal information, and we are not responsible for their privacy practices. You should review the privacy policies of any third party before you decide to share your personal information with them and always exercise caution when publicly sharing your personal information.
- To a third party where you express interest in, or choose to purchase or participate in, a promotion, program, activity, service, or product offered by the third party. However, if you do not want your personal information to be shared in this way, you may opt not to express interest in, or not to purchase or participate in, such promotions, programs, activities, services, or products.
- As required or permitted by law, and to law enforcement agencies and private parties for the purposes of investigating fraud or other offences.
- To legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of our business or operations.
- In the case of any emergency where the life, health, or security of an individual is threatened.
- As consented to by you from time to time, including to fulfill any other purposes that are identified when the personal information is collected.
- As otherwise permitted or required by law.
Consent
Your consent may be express or implied and given in writing by using or not using a check-off box, electronically, orally, or by your conduct, such as use of the Website.
Links
The Website may contain links to other sites. We are not responsible for the privacy practices or the content of such sites. You should review the privacy policies of the sites that you visit. This Privacy Policy applies solely to information collected by Clifton Blake in connection with the Website.
Security
We protect against the loss, misuse, and alteration of personal information with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures and appropriate training of employees. However, it is possible that any information transmitted via the internet may be intercepted by unknown third parties.
Opt-Out
When appropriate, you are given the opportunity to: (i) opt-out of receiving communications from us; (ii) remove your personal information from our records; or (iii) elect to no longer use the Website. If you wish to opt-out of receiving further communications, please contact our Privacy Officer by email or phone using the contact information provided below.
Corrections/Contact
You may contact our Privacy Officer to modify or correct any of your personal information that is under our control. You may also direct a written complaint regarding compliance with this Privacy Policy to our Privacy Officer and, within a reasonable time upon receiving the written complaint, our Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, our Privacy Officer will inform you whether the complaint will be allowed or denied. If our Privacy Officer allows the complaint, we will take appropriate measures necessary to rectify the source of the complaint.