Data Privacy Notice for Website Users
(the “Privacy Notice”)
The protection of your personal data is important to us. We process your data in accordance with applicable data protection laws in the jurisdictions where the QEMP conducts its business.
This Privacy Notice applies to QEMP website (the “Website”). It has been prepared to provide you with information on the processing of your personal data in the context of the QEMP. We reserve the right to change this Privacy Notice at our sole discretion without prior notice. Any amendments become applicable from the time they are published on our Website. Your continued use of our website after amendments are made is deemed acceptance of those changes.
Data protection related queries may be directed to the privacy officer for QEMP at Carolyn.Cartier-Hawrish@innocap.com.
References in this notice to “QEMP”, “we”, “us” or “our” are references to the parties linked to the Quebec Emerging Managers Program.
We are committed to processing your personal data in a responsible and transparent manner.
References in this notice to “you” or “your” are references to individuals whose personal data are processed in connection with the QEMP.
For the avoidance of doubt, any reference in this policy to our “clients” or “third party/ies” includes their employees or other staff whose personal data we might process.
2. Why we process your personal data, the lawful basis for processing your personal data, retention and recipients of your personal data
The scope of information collected and the basis for processing will vary depending on the purpose for such processing.
QEMP relies on the following lawful bases for the processing of Personal Data:
- where necessary for the performance of a contract.
- where necessary for compliance with a legal obligation to which the QEMP is subject.
- Your consent (e.g. when you sign up for marketing material or ask us to contact you, this consent can be withdrawn at any time)
- where necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom your personal data is provided. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
- Conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
- Preventing, investigating or detecting theft, fraud or other criminal activity;
- Pursuing our corporate and social responsibility objectives
For website visitors, cookies use is limited to language preferences only. In addition, Google Analytics and the hosting server are collecting certain data for statistical and error log purposes only. For more information on how Google Analytics collects and processes data you may refer to: https://policies.google.com/technologies/partner-sites.
For current and potential clients, Personal Data may also be collected from you and processed as part of our due diligence and onboarding process and to comply with our legal and regulatory obligations. Such data may include some or all of the following: name, signature, postal address, email address, date and place of birth, nationality, professional or employment related information, source of funds details, tax identification, signatures, other contact details, account numbers (or functional equivalent) and transaction details, your tax or social security ID number or equivalent, utility bills for the purposes of address verification, photographic identification and verification such as copies of your passport, passport number and driver’s license, information relating to your status as an ultimate beneficial owner of an entity, a politically exposed person or a designated individual on a sanctions list.
We process your Personal Data for the purposes of delivering a service to you, for the purposes of maintaining appropriate business records, including maintaining appropriate registers and documentation required under applicable law and regulation, for the purposes of quality control, business and statistical analysis.
We may collect and process Personal Data relating to you in connection with our on-going relationship with you, such as via correspondence and calls, and in connection with the administration of our relationship with you.
We will retain all data in accordance with our policy and to the extent permitted by law. Retention periods will vary depending on the purpose for which we are using your data and applicable laws and regulations.
3. Cross boarder transfers of data
Considering our various business partners, your personal data collected in one jurisdiction may be transferred, stored and processed in another jurisdiction. Such transfer will only occur in compliance with applicable data privacy regulations and may be subject to safeguards, including but not limited to inclusion of confidentiality clauses in the agreements between relevant entities.
4. Your rights relating to personal data
Data privacy regulations applicable to our activities have several key common principles including lawfulness, fairness and transparency in the processing of personal data, purpose limitation, storage limitation, integrity, confidentiality and accountability. Key rights for individuals are presented below.
The applicable regulation includes the following rights for individuals in relation to their personal data, in certain circumstances and subject to certain exemptions:
- right to access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- right to rectification – you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
- right to restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
- right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
In order to exercise any of the rights set out above, please contact QEMP’s Privacy Officer: Carolyn.Cartier-Hawrish@innocap.com.
If we are processing personal data based on your consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal.
If you are unhappy with how we process personal data, we ask you to contact us so that we can rectify the situation.
You may lodge a complaint with a supervisory authority. The Quebec supervisory authority is the Commission d’accès à l’information du Québec (Commission d’accès à l’information).
5. Requirement to process personal data
You may browse our website without providing us with any personal data and this will not affect your ability to view our website.
However, if you do not provide us with your information for the purposes described above, we may not be able to provide you with requested services, including access to client portal.
6. Automated decision-making and profiling
We do not use any personal data for the purpose of automated decision-making or profiling.
7. External links
Our website may contain links to external websites. If you click on one of these links, please refer to their own data privacy notices. We do not accept any responsibility or liability for those notices. Please refer to such notices prior to sharing any personal data on such external websites.