At Cliffside Capital Ltd. (“Cliffside,” “we,” or “us”), we sincerely value the trust that you have placed in us. We have adopted this privacy policy (the “Policy”) to affirm our commitment to maintaining the accuracy, confidentiality, and security of your personal information. This Policy explains how we collect, use, disclose, and safeguard the personal information that you or a third party provide. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Cliffside’s collection, use, and disclosure of your personal information in accordance with this Policy.For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. The meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.
Our Privacy Principles
Identifying Purposes and Obtaining Your ConsentWe identify the purposes for collecting your personal information at or before the time it is collected. We will not collect, use, or disclose your personal information without your consent unless we are required or permitted to do so by law. We collect, use, and disclose personal information about you so we can respond to your informational requests and for compliance with legislation. We will also use your personal information to communicate with you. If we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent.
Limiting the Collection, Use, and Disclosure of Your Personal Information
The Information We Collect
We collect personal information by fair and lawful means and limit collection to that information which is necessary for the purposes identified in this Policy. The types of personal information that we collect from time to time include:- Contact information that allows us to communicate with or contact you (e.g., address, telephone number, e-mail or other electronic address, social media account name, and fax number).- Identity information that allows us to identify you or to meet tax, anti-money laundering, and legal and regulatory obligations.The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may limit our ability to communicate with you.
How Your Information is Collected
Personal information may be collected in a number of ways, including in person, over the phone, by mail, by fax, over the Internet, and from third parties who you have authorized to disclose personal information to us.Web cookies are very small text files that are stored on your computer from a webpage to keep track of information about your browsing on that site. Through the use of web cookies, we may monitor the content you see and the frequency of views. The use of cookies also allows us to capture standard web traffic information, such as the time and date you visited our website, your IP address, and your browser information. In no circumstances do the cookies capture any information that can personally identify you. We also gather anonymous/non-personal information from our website and digital properties that is used primarily for technical, research, and analytical purposes like evaluating the various sections of our website. This information does not include any personal information and is only retained until its intended purpose is fulfilled.We make every reasonable effort to ensure that third parties that disclose your personal information to us have first obtained your consent. If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.Your personal information will only be used or disclosed in accordance with the purposes for which it was collected, unless you have otherwise consented or except where required or permitted by law.
Disclosure to Third Parties
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed, and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so.Your personal information may be disclosed in situations where we are legally permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights, our rights, or to investigate suspicion of unlawful activities. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of ourselves and others.
You also understand and agree that we may use your personal information and disclose your personal information to third parties for the purposes of evaluating and/or performing an actual or proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing personal information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use, and disclose your personal information for substantially the same purposes as those set out in this Policy. In the event the transaction does not go through, we will require, by contract, the other party or parties to the transaction not to use or disclose your personal information in any manner whatsoever for any purpose, and to return or destroy such personal information.
Keeping Your Information Accurate
We make every reasonable effort to keep your personal information as accurate, complete, and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.Despite our best efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
Protecting Your Personal Information
Access to Your InformationAccess to private, sensitive, and confidential information, including your personal information, is restricted to authorized employees with legitimate business reasons. We require all of our employees to abide by our privacy standards. Our employees understand the importance of keeping your information private. All employees are expected to maintain the confidentiality of personal information at all times, and failure to do so will result in appropriate disciplinary measures, including dismissal.
Disposal and Retention
Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfill the purposes for which it was collected.Safeguarding Your InformationTo ensure that your personal information is protected, we employ security safeguards that are on par with industry standards. We use modern technologies to ensure that your confidential information is not compromised. Our server environment and firewall infrastructure are well-maintained, and our security practices are reviewed on a regular basis.
Addressing Your Inquiries and Concerns
We are happy to provide you with a copy of this Policy and to discuss any of its content with you. Upon request, we will also inform you of: the type of personal information we have collected; how your personal information has been used; and any third parties to whom your personal information has been disclosed.
Please direct all questions or inquiries about this Policy to the attention of our Privacy Officer by email at:
privacyofficer@cliffsidecapital.ca
or by mail at:
11 Church St. Suite 200,
Toronto, ON, M5E 1W1.
Updating this Privacy Policy. Any changes to our privacy standards and information handling practices
