Privacy Policy

Power Pacific Corporation Limited and Power Pacific Investment Management Inc. (collectively, “Sagard China”, “we”, “us”, “our”) are responsible for the personal information in our control. Sagard China is committed to maintaining the confidentiality and security of your personal information. This Privacy Policy (the "Policy") explains how we collect, use and disclose the personal information that you provide to us or that we otherwise collect about you. In this Policy, the term “personal information” means information about an identifiable individual or that allows an individual to be identified, as more particularly defined or limited by applicable privacy laws.

This Privacy Policy applies to our processing of personal information of visitors to our website and prospective investors. Details of our processing of personal information in relation to an investment in a fund that we offer are not covered by this Privacy Policy, but we will provide you with appropriate information when you invest in the fund or as otherwise required by law. Similarly, if you apply for a position with us and you are subsequently hired, the personal information you will have provided to us or that we will have otherwise collected about you will be retained, used and disclosed in accordance with our Employee Privacy Policy.


Personal Information We Collect and How We Use It

We collect, use and disclose personal information for the purposes described in this Policy or as we may otherwise indicate to you from time to time.

We collect personal information about prospective and former investors. The information we collect includes name, residential address, telephone number, email address and other contact information, social insurance number, date of birth and account holdings. Personal information may be collected from the individual concerned or through a third party with the consent of the individual concerned or as required or permitted by law. We use this information to communicate with you and to manage our relationship with you.

We collect personal information about you when you communicate with us through the “Job Opportunity” page of our website or otherwise. The personal information we collect may include your name, email address, telephone number, other contact details, any personal information contained in your application package or generated in relation to your application, including, without limitation, information about your employment history and qualifications, and any other personal information you provide in your communication. We use this information to communicate with you; to manage our relationship with you; to maintain our information about you; to evaluate any job application you may submit and assess whether to offer you a position; where you have previously applied for a job, to keep in touch with you about available job positions which we think may be of interest to you; and to address the subject matter of your communication.

Through the use of cookies, we may automatically collect information from our website visitors, including IP address, the date and time of the visit and the pages visited. We would use this information to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage to our website or other assets; to compile statistics regarding the use of our website;to ensure that our website runs smoothly; and to improve the functionality of the website to better serve your requirements.

We also use personal information to meet legal, regulatory, industry, audit, security or ethical requirements.

If you are a prospective investor, you are not required to provide us with any information although please note that our website may automatically collect certain data as explained above.


Disclosure of your Personal Information

We may share your personal information with:

International Transfers of Personal Information

In some circumstances, the sharing of personal information with third parties or other group companies may involve the storage or processing of personal information outside Canada and the European Economic Area (EEA), including in the United States, China and Hong Kong. We will take reasonable steps to ensure that any international transfer of personal information is carried out in accordance with applicable privacy laws. The protection of such personal information will be subject to the legal requirements of the jurisdictions where the information is transferred, including lawful requirements to disclose information to government authorities in those countries. If you have any questions about the collection, use, disclosure or storage of personal information, please contact us as indicated below.


Consent

We collect, use and disclose your personal information with your consent, or as may be permitted or required by law. Your consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. Subject to applicable law, if you provide personal information to Sagard China, we assume that you consent to the collection, use and disclosure of your personal information as outlined to you at the time of collection or thereafter or as otherwise described in this Policy.

In some circumstances, you may refuse to consent to our collection, use and disclosure of your personal information, or you may withdraw your consent to further collection, use and disclosure of information about you, subject to contractual and legal restrictions and reasonable notice, where permitted under applicable law. Withdrawing your consent to certain uses of your personal information may mean that we may no longer be able to provide you with certain services. We may continue to process your personal information even if you withdraw your consent if we are permitted to do so by applicable law.

If you provide us personal information about another individual, you represent and warrant to us that you have provided a copy of this Privacy Policy to that individual and have obtained the consent of the individual concerned to the collection, use and disclosure of this personal information for the purposes described in this Policy or otherwise at the time the personal information is collected.


Security

We take reasonable steps to protect your personal information from misuse, interference and loss, unauthorised access, modification or disclosure.


Retention

We do not keep your personal information for longer than necessary for the purposes for which we collect it unless we believe that law or regulation requires us to preserve it. If you apply for a position with us and you are not offered or you do not accept a position, we may retain the personal information you have provided to us or that we have otherwise collected about you for a reasonable period in the event an appropriate position becomes available or that you re-apply.

When it is no longer necessary to retain your personal information, we will delete it from our systems, or put it beyond use.


Your Rights

The file containing your personal information will be kept at our offices or on our servers or those of our service providers and will be accessible to employees who require it for the purposes of their duties.

If you wish to request access to, or correction of, your personal information in our custody or control, or if you wish to withdraw your consent to the collection, use and disclosure of your personal information, please make your request in writing to Power Pacific Investment Management Inc. at 751 Victoria Square, Montréal, Québec, H2Y 2J3, Canada, Attention: Secretary. In some circumstances, we may not be able to provide you with access to your personal information or parts of it. We will advise you at the time of the request.


Further information or Complaints

This Policy was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of personal data. Inquiries or complaints about this Policy and our personal information practices may be directed to Power Pacific Investment Management Inc. at 751 Victoria Square, Montréal, Québec, H2Y 2J3, Canada, Attention: Secretary.


Policy Changes

This Policy may be revised from time to time. You may contact us to obtain a current copy of this Policy. Your continued provision of personal information or use of our services following any changes to this Policy constitutes your acceptance of any such changes

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