Introduction
This Privacy Policy explains how Fengate Capital Management Ltd. (“Fengate,” “we,” “us,” or “our”) collect, use, disclose, store, and protect personal information in connection with our website (the “Website”) and related online interactions.
By accessing or using the Website, or by submitting personal information to us, you acknowledge that your personal information will be handled as described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Website or provide personal information to us.
This Privacy Policy applies to personal information collected through the Website and online communications related to the Website. It does not apply to personal information collected offline or through third-party websites that may be linked from our Website.
Information Collection
Personal information means information about an identifiable individual, such as your name, email address, telephone number, mailing address, or other information you provide that can reasonably be linked to you.
We may collect the following categories of personal information:
(A) Information you provide directly
When you submit an inquiry, complete a form, subscribe to communications, or otherwise contact us through the Website, we may collect:
- Name
- Email address
- Telephone number
- Mailing address (if provided)
- Organization/company and title (if provided)
- Any information you include in your message or attachments
You may browse the Website without submitting identifying information; however, certain information may still be collected automatically as described below.
(B) Information collected automatically
When you visit the Website, we (and service providers acting on our behalf) may automatically collect information such as:
- IP address,
- Device identifiers and browser type,
- Operating system and device characteristics,
- Date/time of access,
- Pages viewed, links clicked, referring/exit pages,
- Approximate location derived from IP address.
We use cookies and similar technologies to operate the Website, improve performance, understand usage, and support security.
Information Use
We may use personal information for the following purposes:
- To respond to your inquiries and communicate with you,
- To provide requested information, materials, or services,
- To personalize your experience (where applicable),
- To operate, maintain, protect, and improve the Website and our services,
- To analyze Website usage and performance, including through analytics,
- To administer our Website in accordance with its Terms of Use or other agreements,
- To send informational or promotional communications where permitted by law and in accordance with your preferences,
- To comply with legal and regulatory obligations and respond to lawful requests,
- For any other purpose that is disclosed to you at the time of collection or otherwise with your consent, where required.
We retain personal information only as long as necessary for the purposes described in this Privacy Policy, or as otherwise required or permitted by applicable law. Retention periods vary depending on the nature of the information and the reasons it was collected.
Marketing Communications
If you opt in to receive marketing or promotional communications, you may unsubscribe at any time by using the unsubscribe mechanism included in our emails or by contacting us using the contract information provided below. Unsubscribing will not affect service or administrative communications that are necessary to respond to you or provide requested information.
Use of Cookies
Cookies help us understand how visitors use the Website and allow certain features to function. You can manage or disable cookies through your individual browser settings. Please note that disabling certain cookies may affect Website functionality.
Third Party Information Disclosure
We may disclose personal information in the following circumstances:
(A) Service providers
We may transfer personal information to trusted third parties who assist us in operating our website, conducting our business, or servicing you, provided those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate or required to comply with the law, enforce our Website policies, or protect our or others’ rights, property, or safety.
(B) Legal, compliance, and protection
We may disclose personal information when we believe it is necessary to: (i) comply with applicable laws, regulations, or legal processes,(ii) respond to lawful requests from courts, regulators, or law enforcement, (iii) enforce our agreements or Website policies, (iv) protect the rights, property, security, or safety of Fengate, our users, or others.
(C) Business transactions
We may disclose personal information in connection with a proposed or completed business transaction, such as a merger, acquisition, financing, reorganization, sale of assets, or similar transaction. We will take reasonable steps to ensure appropriate confidentiality protections are in place.
(D) Non-identifiable information
We may share information that has been aggregated or de-identified so that it does not identify you, for business and analytics purposes.
(E) Cross-Border Transfers
Our service providers may process or store personal information outside of Canada (including in the United States or other jurisdictions). As a result, personal information may be subject to the laws of those jurisdictions and may be accessible to law enforcement and national security authorities in accordance with applicable laws.
Security
We use reasonable physical, organizational, and technological safeguards designed to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification.
No method of transmission over the internet or electronic storage is completely secure. While we strive to protect personal information, we cannot guarantee absolute security.
External Links
The Website may contain links to third-party websites or services. Those third parties have their own privacy policies and practices, and we are not responsible for their content, privacy practices, or handling of personal information. We encourage you to review the privacy policies of any third-party sites you visit.
Access and Rectification
Subject to applicable law, you may request access to, or correction of, the personal information we hold about you. You may also request deletion of personal information, where applicable.
We may need to verify your identity before processing a request. In some cases, we may be unable to provide access or make changes (for example, where the information includes personal information about another individual or where legal restrictions apply). If so, we will provide an explanation, as required.
Consent and Changes
By using our Website or by providing us with personal information, you consent to our Privacy Policy. We may update this Privacy Policy from time to time. Your continued use of the Website after an update constitutes acceptance of the updated Privacy Policy.
Contact Us
If you have questions about this Privacy Policy or wish to submit a privacy request, please contact our Legal Department at:
Fengate Asset Management
77 King Street West, Suite 3410
Toronto, ON, M5K 2A1
Attn: Legal Department