We are subject to the operation of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”), the Act respecting the protection of personal information in the private sector (Québec), Privacy Act 1988 (Cth) and the Australian Privacy Principles, as applicable from time to time (together, “Privacy Laws”). This policy explains how we handle personal information relating to individuals so as to ensure we meet our obligations under the Privacy Laws.
Privacy Laws regulate the collection, use and disclosure of “personal information”, which includes information or an opinion about an identified individual or an individual who is identifiable, whatever the medium or format.
If you are an Australian resident, Section 8 (“Australian Residents”) will apply.
We collect personal information by various means including (but not limited to) when you invest in us as a shareholder, when you contact us by any means, when you view, navigate and/or use any of our websites, such as by subscribing to our newsletter and by contacting us through our general contact forms or our service offer submission forms.
This information may include (but is not limited to) your name, e-mail and mailing addresses, contact numbers, company or employer, date of birth, and any content of your communications when you exchange with us by any means.
We may also collect information about how you interact with our Websites, including (but not limited to) your web browser and version, device type, connection type, IP address, performance metrics and usage information, in order to help us to develop and improve our Websites.
We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. We use your personal information for the purpose for which it has been provided, any other purpose you 1 have consented to and any other purpose permitted under the Privacy Laws or any other applicable laws. The primary purpose for which we collect, use and disclose personal information is to manage our operations and promote our business. This may include using your personal information for any of the following purposes:
• Providing you with information about our company, the business or matters concerning shareholders;
• Responding to your questions and suggestions;
• Processing job applications and conducting recruitment;
• Conducting marketing activities; and
• Continuing to improve your experience with our websites.
We may disclose your personal information to third parties for the purposes for which we may use your information as described above. This may include disclosing information to: • our related entities and affiliates;
• third party organisations such as our lawyers, business partners, advertising partners, securities exchanges, mailing and printing houses, IT providers, analytics providers, professional advisors, investor relations firms and other service providers;
• anyone who is considering acquiring an interest in our assets or businesses (or any part of them) as part of a due diligence or sale process; and/or
• our registrars in Australia, Canada, the US and any other jurisdiction where a register is maintained.
We will only disclose your personal information for other purposes if you consent, where we are required or authorised by law to do so, where the disclosure is authorised under the Privacy Laws, or where we believe you would reasonably expect us to disclose your personal information for a purpose which is related to the primary purpose of collection including to respond to subpoenas, judicial processes or legitimate requests by law enforcement officials or government agencies or departments.
In the event of a change of ownership, sale, merger, liquidation, reorganization or acquisition of any member of our Group, in whole or in part, your personal information may be transferred as part of the transaction.
In addition to this, we also use Google Analytics as part of analytics cookies on our Websites. Google Analytics is Google’s analytical tool that helps us to understand how users engage with our Websites. The information we collect through Google Analytics is page views, time spent through the Network Services, number of visitors, the source where they come from, the pages they have visited, session and Websites usage, the whole in an anonymous form. It uses a set of cookies to collect such information and reports site usage statistics without allowing us to identify individual visitors.
Your personal information is stored by the Champion Group in Montreal, Quebec, Canada. However, it may also be stored and processed in any country where we have facilities or in which we engage service providers. By using our Websites, you consent to the transfer of information to countries outside your country of residence which may have different data protection rules than in your country.
We take reasonable steps to secure any personal information which we hold about you and to keep this information accurate and up to date. Personal information is stored electronically or in hard copy and various physical, administrative, technical and technological security measures are in place to protect this information from misuse, interference and loss.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Users should be aware that there are inherent risks in transmitting information across the Internet.
We will take such steps that are reasonable in the circumstances (if any) to destroy or de- identify personal information when it is no longer required for the purpose(s) for which it was provided. However, we will maintain your personal information for as long as a business need exists, or as required by applicable laws, regulations, or government orders.
We will take such steps as are reasonable to ensure that the personal information which we collect remains accurate, up to date and complete.
We will provide you with access to your personal information held by us unless we are permitted under Privacy Laws (as applicable) to refuse to provide you with such access, such as where the request relates to an existing or anticipated legal proceeding or if your request is vexatious. Please contact us via the details set out in Section 7 below if you:
(a) wish to have access to the personal information which we hold about you;
(b) consider that the personal information which we hold about you is not accurate, complete or up to date; or
(c) require further information on our personal information handling practices.
There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in actually providing you with access. If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Laws, to correct that information if you so request. We may need to verify the accuracy of new information you provide us before making corrections to your personal information held by us.
We will respond to all requests for access and/or correction within a reasonable time within the timeframe required under applicable Privacy Laws.
If you would like further information about how we manage your personal information, have any queries or feedback relating to this policy, or wish to lodge a complaint, you may contact the office of our Privacy Officer at:
1155 René-Lévesque Blvd. West, Suite 3300
Montréal, QC H3B 3X7
Tel: +1 514 316 4858
Fax: +1 514 418 8117
Our Privacy Officer is accountable for compliance with the Privacy Laws and is responsible for coordinating the investigation of any complaints and resolving privacy-related issues. The Privacy Officer will manage any complaints received in a timely manner and provide you with a response to your complaint.
You have the right to make a complaint at any time to the relevant privacy regulator. We would, however, appreciate the chance to deal with your concerns before you approach the relevant privacy regulator so please contact us in the first instance. In Canada, you can contact the Office of the Privacy Commissioner of Canada or the relevant provincial privacy commissioner for your province of residence. In Australia, you may take your complaint to the Office of the Australian Information Commissioner, contactable by telephone on 1300 363 992, via the OAIC website at www.oaic.gov.au, or by email at firstname.lastname@example.org.
If you are located in Australia, this Section 8 applies to you.
The third parties to whom we may disclose your personal information that are described above at Section 3 may be located outside of Australia. If we do so, we will take reasonable steps to ensure that the overseas recipient does not breach the Privacy Laws in its handling of the personal information. However, it is not practicable for us to specify in advance every location where your personal information may be sent. It is possible that information will be transferred to a jurisdiction where you will not be able to seek redress under the Privacy Laws and that does not have an equivalent level of data protection as Australia. We will not be accountable for how these overseas recipients handle your personal information. By providing your personal information to us, you consent to our disclosure of your personal information to these parties. If you have any concerns regarding the transfer of your personal information overseas, please contact us using the details provided in Section 7.