PRIVACY POLICY

Scope of Policy

PE Gate Partners (“PE Gate”, the “Firm” or “we”) is committed to protecting the privacy of personal information. PE Gate has adopted this privacy policy (the “Privacy Policy”) to explain the manner in which we collect, use, disclose and otherwise treat Personal Information (defined below) of our clients, prospective clients and, where applicable, our clients’ beneficial owners, officers and directors (collectively, “Clients”) as well as other individuals who visit our website or otherwise engage with us.

This Privacy Policy applies to the privacy practices of PE Gate on our website located at  www.pe-gate.com (“Website”), our online portal (the GATE) available at https://icx.efrontcloud.com/pegate/login.aspx (“Service”) and through other face-to-face meetings, telephone conversations and electronic communications  with our Clients and other individuals.  

Collection and Use of Personal Information

In the course of our provision of exempt market dealer (EMD) services to Clients, PE Gate may collect identifiable information (“Personal Information”) such as residential address, telephone number, e-mail address, bank account numbers and other “know your client” information, including identity verification records required under applicable laws including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), regulations and policies made thereunder and other statutes and regulations that take legislative measures against money laundering, terrorist financing and against financial dealings with certain sanctioned individuals and entities. PE Gate may also collect information about the investment holdings and activities of our Clients, including transactional information regarding our Clients’ participation in investments presented through the GATE (each, a “PE Gate Investment” and collectively, “PE Gate Investments”) as well as account statements, financial statements and other information regarding Clients’ investments other than PE Gate Investments which is uploaded to the GATE.

Personal Information is used for the following purposes:

·       conducting an analysis of the suitability of a proposed PE Gate Investment for a Client;

·       processing PE Gate Investments, opening and servicing Client accounts;

·       verifying identity and other Personal Information provided to PE Gate (including bank account);

·       if applicable, reporting PE Gate Investments to the relevant securities regulatory authority;

·       completing applicable books and records information for PE Gate Investments;

·       detecting and preventing fraud and other unauthorized or illegal activities; and

·       meeting other legal and regulatory requirements.

PE Gate may also collect Personal Information of the directors, officers, managers and other relevant individuals involved in PE Gate Investments in the course of conducting due diligence regarding, negotiating and closing such PE Gate Investments.

Online Registration: If you register or submit an initial membership inquiry on our Website or Service, we collect your email address and a password you choose in order to create and administer an online account for you and provide you with access to the GATE. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

Marketing Communications: PE Gate may use Personal Information to send communications by mail, email or telephone marketing or to promote PE Gate Investments or other products and services that may be of interest to our Clients or other individuals. You can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting PE Gate at the contact information set out below. Please note that you will continue to receive certain transactional or informational electronic communications from PE Gate after opting out.

Call Recording: We may monitor and record our telephone conversations with Clients or other individuals for training and quality assurance purposes. You will be provided with a notice at the beginning of any call that is being recorded. If you do not wish to have your call recorded, please let us know.

Surveys and Customer Research: From time to time, we may offer Clients or other individuals the opportunity to participate in one of our surveys or other customer research. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings.

Disclosure of Personal Information

PE Gate will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein.

Exempt Trade Report: Clients’ Personal Information, including full legal name, residential street address, telephone number, email address (if available), specific purchase details and details of the prospectus exemption relied on, may be disclosed to the relevant Canadian securities regulatory authorities and become available to the public in accordance with the requirements of applicable securities and freedom of information laws. Clients authorize such disclosure of Personal Information and acknowledge that: (i) the Personal Information is being collected indirectly by the applicable Canadian securities regulatory authority under the authority granted to it in securities legislation; (ii) the Personal Information is being collected for the purposes of the administration and enforcement of applicable Canadian securities legislation; and (iii) clients have been notified of the title, business address and business telephone number of the public official in their jurisdiction in the subscription agreement.

Service Providers: Personal Information may be transferred (or otherwise made available) to third parties in Canada,  the U.S. or other jurisdictions which provide services on PE Gate’s behalf. PE Gate may use service providers to verify Personal Information (such as identity and bank account number) and other know-your-client information provided by Clients, administer PE Gate Investments, send email or other communications, or manage and analyze data. In the event Personal Information is transferred to the U.S. or other foreign jurisdiction, it will be subject to the laws of that jurisdiction.. Service providers are given the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes.

Legal/Compliance: PE Gate and its Canadian, U.S. or other service providers may provide Personal Information in response to a search warrant or other legally valid inquiry or order, (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud , or as otherwise required or permitted by applicable Canadian, U.S. or other law. Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: Personal Information may be transferred as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of PE Gate’s business or as part of a corporate reorganization or stock sale or other change in corporate control.

Website Information, Cookies, and Interest-based Advertising

In general, you can visit the website without telling us who you are or submitting any personal information. However, we and/or our service providers collect IP (Internet protocol) addresses from all visitors to the website and other related information such as page requests, browser type, language, operating system and average time spent on our website. This information is used to help us understand our website activity, and to monitor and improve the website.

Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. The website may use both “session” cookies and “persistent” cookies. A session cookie is used to identify a particular visit to our site and expire after a short time, or when you close your web browser. A persistent cookie will remain on your devices for a set period of time specified in the cookie in order to remember your information and settings over a longer period of time.

You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features of our website.

Our Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on our website. These tracer tags are used to help us optimize and tailor our website for you and other future visitors to our website.

Analytics: We may also use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.

Third Party Links

Our Website or Service may contain links to other sites that we do not own or operate, including social media websites. Also, links to our Website or Service may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your Personal Information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your Personal Information.

Safeguards and Retention

PE Gate has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in its custody and control against theft, loss and unauthorized access, use, modification and disclosure. PE Gate restricts access to Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. PE Gate has record retention processes designed to retain Personal Information for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of a Member’s relationship with PE Gate).

Access to Personal Information

Clients have the right to access, update and correct inaccuracies in their Personal Information in PE Gate’s custody and control, subject to certain exceptions prescribed by law. Clients may request access, updating and corrections of inaccuracies in Personal Information in PE Gate’s custody or control by emailing or writing to PE Gate at the contact information set out below. PE Gate may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.

Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to PE Gate’s Personal Information practices. The updated Privacy Policy will be posted on our Website and PE Gate will provide clients with an updated copy of its Privacy Policy annually or more frequently upon request.

Contact Us

Clients may contact PE Gate’s Privacy Officer with any questions or comments about this Privacy Policy, or to obtain access, update, and/or correct inaccuracies in Personal Information, or otherwise with any question or complaint about the manner in which PE Gate or its service providers treat Personal Information at the following contact information:

 

Ara Sahakian

416-333-7477

ara@pe-gate.com