This Policy applies to our collection, use and disclosure of your personal information as: (1) a user of this Website (a “User”); (2) as an investor in the A&W Revenue Royalties Income Fund (an “Investor”), or (3) as a trustee of the Fund (“Trustee”), a director of TMI (“Director”), or employees of either the Fund or TMI (together, “Employees”).
This Policy does not impose any limits on the collection, use, or disclosure of certain business contact information or certain publicly-available information, as permitted by applicable law.
User, Investor, Trustee, Director and Employee personal information obtained in the conduct of our business will not be collected, used or disclosed except in compliance with governing legislation, including the federal Personal Information Protection and Electronic Documents Act and British Columbia's Personal Information Protection Act.
As an Investor or User, the information we may collect from you when you provide it to us currently includes the following:
We may also collect certain non-personal information from Users on an anonymous basis, such as the operating system you are using, the sections of the Website that you visit, the Website pages read and images viewed, and any content downloaded from the Website. This non-identifiable information is used an on an aggregate basis:
The information that we may collect from Trustees, Directors and Employees currently includes the following:
As a User or Investor, we may collect, use and disclose your personal information for the following purposes:
The above list depends entirely on what requests you make.
If you do not wish for us to use your personal information in any or all of the ways described above, you can choose not to provide such information, and request that any brokerage that you own units of the Fund through designate you as an Objecting Beneficial Owner pursuant to National Instrument 51-101 Communication with Beneficial Owners of Securities of a Reporting Issuer. Sharing of your personal information in any or all of the ways described above is at your option.
As a Trustee, Director or Employee, we may collect, use and disclose your personal information as necessary for the purposes of establishing, managing and maintaining our relationship with such persons (e.g., personal information may be disclosed to the Canada Revenue Agency as necessary to comply with tax laws, banking information will be used as necessary to compensate such individuals for their services, etc.).
All individuals authorized by us to collect, record, store, disclose, amend or dispose of personal information collected on our behalf must abide by the guidelines described in this Policy.
If you request to receive press releases from us, your personal information will be shared with the third party service provider that disseminates press releases on behalf of the Fund. This service provider is prohibited from using your personal information for any purpose other than to disseminate the press releases, and is required to protect personal information collected on our behalf.
However, we have no control over how this service provider collects, uses or discloses personal information that you may provide to them directly (i.e., information they collect from you, not from us).
Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory so we can recognize you when you return.
Most browser settings can be adjusted to accept or reject the use of some or all of these cookies, although you must take additional steps to control these.
Our Website may use a technology called “tracer tags” or “web beacons”. This technology allows us to understand the pages you visit, which helps us optimize and tailor our Website for you and other future visitors.
We will not collect personal information indiscriminately, but will limit collection of personal information to that which is reasonable and necessary for the purposes described in this Policy.
We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where the information is publicly available (as defined by statute or regulation), we are obtaining legal advice, or we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may apply.
Except where applicable law specifically provides otherwise, your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.
By using the Website or by interacting with the Fund as an Investor, Trustee, Director or Employee, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Policy.
You may withdraw consent at any time, subject to any legal and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. Upon our Privacy Officer's receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include the inability of us to provide certain services for which that information is necessary.
We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us. Some specific safeguards may include, for example:
We will store your personal information on our internal services and/or with our service providers. Our service providers may store and/or process personal information outside of Canada (including in the United States). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. We have taken appropriate technical, organizational and legal steps to secure this information.
When an Investor contacts the Fund to request information, the Fund uses the Investor's contact information to reply to the request, then destroys the information after 90 days if the Investor has not indicated that they want to receive an ongoing distribution of press releases.
Note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication.
Our Privacy Officer is responsible for investigating all complaints received and notifying a User, Investor, Trustee, Director or Employee of the outcome of the investigation clearly and promptly. Where appropriate, the Privacy Officer must take steps to improve information handling practices and policies.
We retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.
We may modify this Policy at any time without notice. The Policy posted at any time or from time to time via the Website will be deemed to be the Policy then in effect.
A & W Food Services of Canada Inc., Privacy Officer
300 - 171 West Esplanade
North Vancouver, B.C.