This policy applies to personal information we collect:
- when you use our website, located at https://www.imperialcap.com/ (the “website”);
- when you submit your personal information to us through our website. For example, when you use the “Contact” section of our website;
- when you apply for a job at Imperial;
- when you make requests for information about our products and services; and
- as part of your interaction with us by telephone, email, through social media and in person.
What is personal information?
Personal information is any information by which you may be personally identified or is about you. For instance, it includes information such as your name, address, telephone number, birth date, and e-mail address.
This policy is not intended to cover information other than personal information, such as business or anonymous information.
Obtaining and withdrawing your consent
By engaging us or by submitting information to us in connection with our products and services, you are indicating your consent to our collection, use and disclosure of your personal information in the manner described below.
You can withdraw your consent to the collection, use or disclosure of your information at any time. However, in some cases withdrawing consent will mean that we can no longer provide you with certain services or perform certain tasks where the information is required to do so.
You may withdraw your consent to the collection, use or disclosure of your personal information at any time by writing to us (see the ‘Contact information’ section below or contact us at https://www.imperialcap.com/contact and, subject to any legal constraints, we will comply with your request.
Information we collect and where we get your personal information
We do not collect personal information indiscriminately and will limit collection of information to that which is reasonable and necessary for the purposes it was collected or as authorized by law.
Often it is optional for you to provide your personal information, but other times some personal information is required to serve you. You may choose not to provide your personal information even in such cases, but that may result in our inability to serve you.
In all cases where you voluntarily provide personal information to us, we undertake to collect, use and/or disclose it in accordance with this policy and applicable laws.
We collect personal information in the following ways:
- Directly from you. You may give us information about you by filling in forms or by corresponding with us by phone, e-mail, through the website or otherwise. Other interactions where we may collect your information include:
- When you attend an Imperial event;
- When you apply for a position with us;
- If you contact us, such as with a complaint or query;
- When you engage with us over social media; and
- When you do business with us, for example, by investing in or alongside us, accepting investments from us or otherwise working with us to complete and/or manage investments (note that information we collect in connection with any investments you make with us is also governed by the legal documentation pursuant to which you made such investment).
- Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see ‘Cookies and other Technology section below for more details).
- Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, our business partners, collaborators or service providers.
How do we use your personal information?
We use information that we collect about you or that you provide to us to:
- communicate with you, including to authenticate your identity and ensure that your information is correct and accurate;
- to send you information regarding changes to our policies, other terms and other administrative information;
- to perform background screening of investors, investment partners, and employees to comply with our anti-money laundering, “Know Your Client” (KYK”) and other related internal policies and procedures;
- employment information including title/rile, institution/company, location, compensation, work history, education, qualification/training and if the individual is registered under local securities laws;
- account/financial information including contact information, date of birth, bank account information, wire transfer information, expense details, beneficiary designation, investor commitments, ledgers, positions, balances, percentages of fund, credit information, social insurance number (or similar), inside status, financial information and history, and tax information;
- government identification information including social insurance number (or similar), taxpayer identification number, date of birth, driver’s license, passport, other official government identification and numbers, legal work status;
- fulfill the purposes for which you provided the data or that were described when it was collected;
- facilitate requests they you have made, including for electronic content (e.g., newsletters);
- understand your needs, the suitability of our products and services, and assess future needs;
- administer surveys, or request feedback to improve and manage our relationship with you;
- address your inquiries and complaints;
- present, operate, maintain, enhance, and provide all of the features of our website;
- to market, advertise and promote our products, services and events to you and to other prospective customers;
- keep you informed about our programs and services, including notifying you about updates to our website, products, or services;
- understand and analyze the usage trends, behaviours, and preferences of our users and prospective users, to improve the way the website works and looks, and to develop new features and functionality;
- research, analyze, develop, manage, protect and improve services, including our website;
- manage our organization and day-to-day organizational and operational needs;
- protect our website, employees and operations;
- establish and maintain communication with service providers;
- comply with our legal and regulatory obligations; and
- fulfil other purposes related to any of the above.
If you submit a job application to us, we will use the information relating to that application (such as your employment history) to assess your suitability to any of our job postings. We may also collect information from third parties about you, such as references you list, for the same purpose.
De-identified, aggregate or anonymized information
How and when we may share your information?
We do not sell your personal information to third parties.
We may share your information with our affiliates, collaborators, business partners and service providers to assist us in providing you services, perform functions on our behalf or for our internal business purposes. We contractually require these third parties to keep that personal information confidential and use it only for the contracted purposes.
We may also disclose your personal information to third parties:
- In the event that we sell or buy any business or assets or to pursue a partnership or investment opportunity, in which case we may disclose your personal information to the prospective seller, buyer, investor or partner of such business, assets or partnership;
- To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal information we hold;
- To comply with any court order, law, or legal process, including responding to any government or regulatory request;
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
Cookies and other technology
Information that is automatically collected
We, and our third-party service providers, may automatically collect information related to your use of our website and other online resources through cookies and similar tracking technologies. We do not collect personal information that can identify you directly, such as by name, when browsing our website.
How we use information gathered from cookies and other technologies
- Make your website experience personalized and efficient; and
- Understand and improve our digital services and offerings.
Cookies are small text files that are stored on the browser of your computer that assign an anonymous identifier to your browser and provide information to the cookie sender. Cookies may be placed on your computer by us when you our website or other digital offerings. In addition, we may use third party cookies that track how you use our website or other online resources.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. Please note that if you disable or delete cookies, the website may not function fully or as intended. For more information on cookies and how to manage them, check the support pages for your browser, such as Firefox, Safari, Chrome or Internet Explorer.
International storage and transfers of information
We are based in Canada. We may process, store, and transfer the personal information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Additionally, some of our service providers, collaborators and business partners may be based in different countries. This means your information may be accessible to law enforcement authorities outside of your jurisdiction, in accordance with the laws of that jurisdiction. By using our programs or our website, you consent to the collection, storage, and processing of your information in Canada, United States and in any country to which we may transfer your information in the course of our operations.
The security of your personal information is very important to us. We protect your information by limiting access to it on a strict “need-to-know” basis, and we implement reasonable physical, organizational and technological safeguards as appropriate.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the website.
We only keep your personal information as long as it is operationally or legally necessary. After that, we will either securely and permanently destroy or make the information anonymous.
Accessing your information
When requested in writing, we will inform you of the existence, use, and disclosure of your personal information that we maintain.
To access your personal information, submit a written a request that identifies yourself, the information you want to review and how we can contact you (see ‘Contact information’ below for how to contact us or contact us at https://www.imperialcap.com/contact). We may not be able to provide you with all the information you request, depending on the circumstances.
Correcting your information
We will make reasonable efforts to keep your information accurate and up-to-date. If a change or correction is required, let us know right away. We’ll make any appropriate updates needed. You can review your personal information by reviewing the correspondence we send to you or by requesting access to your personal information, as described above. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect
Children's online privacy
We do not direct our website to minors and we do not knowingly collect personal information from children under 16 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal information from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us using the information outlined in the ‘Contact information’ section below or at https://www.imperialcap.com/contact.
Because of the rapidly changing state of technology, we cannot make any guarantees that our systems will be able to honour Do-Not-Track requests sent by your browser.
Inquiries and complaints
Address: 200 King Street West, P.O. Box 57, Suite 1701, Toronto, Ontario M5H 3T4.
Please note that we may need to confirm your identity or request additional details in order to process your request.
Last updated: April 25, 2022.