Junction Capital recognizes the importance of protecting personal and financial information when users visit the website or download a mobile application created or commissioned by Junction Capital (each a “Website” or “App” and together “Website and App”). This Policy including the Cookies Policy is designed to help users understand the information collection practices on a Website and App owned or operated by or on behalf of Junction Capital, including (but not limited to) www.Junction.Capital. Information collected on our Website and App is collected by Junction Capital Group but may be shared with other entities within the Junction Capital group of companies as set out below. Contact information is included in this Policy and on the Website.
We are committed to:
protecting the personal information provided to us;
informing users how the information gathered about them is used; and
ensuring that users know the circumstances under which Junction Capital may disclose users personal data
This Policy covers the privacy and data protection policies on the Website and App, and should be read in conjunction with any other applicable policies, terms, and conditions in place between users and Junction Capital .
This Policy is dated October 2018.
Contact the Team
For any questions or complaints about this Policy, or the privacy-related practices of Junction Capital or its service providers (including information regarding our policies and practices relating to services providers located outside of Canada), please contact us:
by email at email@example.com
Data Protection and Privacy
In the password protected section of the Website or App, or as a visitor who has entered the Website or App via a click through link in an email which has been sent, information about users, including information about the pages visited, the documents downloaded and other information which can help Junction Capital personalize future interactions and communications may be collected. Any information collected about users from this Website and App may be associated with other identifying information that Junction Capital has about users for the purposes set out above.
Users may contact Junction Capital to:
request that Junction Capital amend, rectify, delete or update the personal data held about a user;
amend or update user choices around processing (i.e., in relation to marketing);
request access to, or a copy of, personal information held by Junction Capital.
Where users would like to request access to or receive a copy of all personal information held, such request should be in writing (email) at the contact information above and should contain as much information as possible to facilitate our dealing with this request.
Junction Capital generally records certain usage information, such as the number and frequency of visitors to the Website and App. This information may include the websites that users access immediately before and after users visit to the Websites and Apps, the Internet browser users are using pages requests, operating system, average time spent on the Website, and users IP address. If Junction Capital uses such data at all it will be on an aggregate basis, and will not be disclosed to third parties for any information that could be used to identify users personally. Junction Capital uses this information to help understand the Website activity and to monitor and improve the Website.
Sharing user information with Service Providers (including other Junction Capital companies)
Users personal data may be collected and processed on our behalf for the purposes above:
By any of the companies within the Junction Capital; or
By a third party service provider engaged by us for these purposes
For example, Junction Capital may use service providers to send email or other communications that are tailored to user interests and host, manage, and analyze data. Junction Capital companies and service providers engaged may be based in countries outside of Canada. As such, users personal information may be maintained and processed by its affiliates and other third-party service providers in Canada, United States, United Kingdom, European Union, Israel or other international jurisdictions in countries having different standards of protection for personal information. Junction Capital service providers will be required by the Company to protect user information in accordance with applicable data protection and/or privacy laws and not use the information for any purpose other than providing the service to the Company.
Compliance with Laws
Users personal information will be held and processed by Junction Capital in accordance with applicable data protection and/or privacy laws. Junction Capital and its service providers will not provide any personal information to any other persons, except if it or its service providers are required to make disclosures by any applicable law (which may include lawful access by Canadian, U.S. or foreign courts, law enforcement and other governmental entities), any government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding or as otherwise required or permitted by applicable law.
E-mail and Marketing
Junction Capital does not sell its clients' personal information, nor will it provide users personal information to third parties for their marketing purposes without users consent. Junction Capital will not send users e-mail messages without first receiving users permission, unless it relates to servicing users account or unless users have consented to receiving electronic delivery of fund documents as part of the E-Delivery service. It is Junction Capital policy to include instructions for unsubscribing from these permission-based programs in each message.
If users consent to receive push notifications through an App, Junction Capital will send push notifications to users mobile device notifying users of new articles or other content available through the App. The push notifications may be tailored based on users interests and content that users have viewed on the App. If users do not want to continue to receive push notifications users can always withdraw user consent by changing user settings via the settings page of users mobile telephone.
Disclosure to Third Parties
Junction Capital has implemented reasonable physical, technical and administrative safeguards in an effort to protect personal information in its custody and control from theft, loss and unauthorized access, use, disclosure. Junction Capital recommends that users do not send any personal information via non-secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure. Junction Capital protects users personal information when users transact business on our Website and App by requiring the use of a browser software program that supports industry standard SSL encryption with 128- bit key lengths. The "128-bit" designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security.