Terms & Privacy Policy

 

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:

  1. protecting the personal information provided to us;

  2. informing users how the information gathered about them is used; and

  3. 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.

Junction Capital may amend this Privacy Policy at any time to reflect changes in is personal information practices. The updated Privacy Policy will be posted on the Website and App. The current version of this Policy can be accessed from the link on the homepage, or at the bottom of our other website pages. We strongly encourage users to please refer to this Privacy Policy often for the latest information about our personal information practices. Where necessary, Junction Capital  will obtain additional consent for material changes to this Privacy Policy.

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:

Data Protection and Privacy

Personal Data

The personal data and other information submitted to our Website and App is used to service users account, provide users with the product or service requested, to improve the services to users and/or to provide information on Junction Capital products and services (which may be tailored to specific interests and content that have viewed on the Website and App). The types of personal information that may be collected at our Websites and Apps include: name, address, email address, telephone number, username, and password. Junction Capital will not sell, share or rent personal information to others in contravention of this Privacy Policy.

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.

User Rights

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.

Aggregate Information

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:

  1. By any of the companies within the Junction Capital; or

  2. 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.

Business Transfers

If the business, stock or assets of Junction Capital are acquired or merged with another business entity, it will share all or some of users information with this entity to continue to provide service to users. Users will receive notice of such an event and the new entity will inform users of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of users information, users may decline such use at such time. Junction Capital may also share personal information in connection with a prospective business transaction.

App Notifications

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

The personal information users provide to Junction Capital will only be disclosed to third parties if it has users permission, or as set out in this Privacy Policy. Junction Capital may disclose aggregated information about the general use of its Website and App to third parties – for example, to demonstrate patterns of use to advertisers and other business partners. Information passed on for this purpose will not include any personal information by which users may be identified. We endeavour to prevent unauthorized disclosures of users personal information by third parties but we are not responsible for any unauthorized disclosures or other breaches of security or for the actions of others if the information was passed to them with users authority.

Junction Capital may establish links between the Website and App and one or more websites operated by third parties. Junction Capital has no control over any such other websites, the contents therein or the products/services offered. Users access to and use of such linked websites is governed by the terms of use and privacy policies of those sites, and shall be at users own risk. Junction Capital disclaims responsibility for the privacy policies and customer information practices of third-party internet websites hyperlinked from our Website and App or this Privacy Policy.

Security.

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.