CVCA PRIVACY POLICY

Last updated: March, 262024.

At the Canadian Venture Capital and Private Equity Association (“CVCA”), one of our main priorities is the privacy of our visitors. This Privacy Policy describes how CVCA collects, uses, and discloses personal information through our website, https://​www​.cvca​.ca/. This Privacy Policy does not apply to other means through which CVCA may collect, use, and disclose personal information, unless CVCA states otherwise. 

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact our team using the contact information provided below.

PRIVACY POLICY EFFECTIVE FOR CANADA

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/​or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact us for more information.

WHAT IS PERSONAL INFORMATION?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

CONSENT

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (e.g., using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law.

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our team using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to CVCA, 1201- 372 Bay St., Toronto, ON M5H 2W9, or by email: membership@​cvca.​ca

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

INFORMATION WE COLLECT

You can visit our website without telling us who you are or revealing any information about yourself, including your e‑mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website. 

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes contact and identification information, such as your name, address, telephone number and e‑mail address, and any other contact or other information that you choose to provide by: 

registering as a member of CVCA;

  • using the contact us” portion of this website;
  • applying for a position with CVCA through this website; 
  • by corresponding with a representative of CVCA via e‑mail using the hyperlinks created for that purpose; or
  • registering for CVCA related events.

Where you request information from us, we may use the contact information that you provide to send you information about offers on products and services that we provide to, or receive from, you, or that we believe may be of interest to you. We may also contact you to provide you with, or collect from you, business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and other information requested by or provided to you.

If you have asked us to put you on an e‑mail mailing list, we may e‑mail you our newsletter. Each of our newsletter e‑mails includes an unsubscribe link that you can use to remove yourself from such mailing lists. If you are interested in subscribing to our newsletter, promotion notices, and other electronic mailings, please visit https://​www​.cvca​.ca/.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.

As a general rule, CVCA collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may use the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

HOW WE USE YOUR INFORMATION

We use the personal information we collect in various ways, including to:

provide, operate, and maintain our website;

improve, personalize, and expand our website;

understand and analyze how you use our website;

establish, maintain, and manage our relationship with you so that we may provide you with, or receive from you, the products and services that you have requested; 

develop new products, services, features, and functionality;

communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes;

comply with your requests;

protect us against error, fraud, theft, and damage to our goods and property; or

any other purpose to which you consent.

LOG FILES

CVCA follows a standard procedure of using log files. These files log visitors when they visit websites. The information collected by log files includes IP addresses, browser type, Internet Service Provider (ISP), date and time, referring/​exit pages, and clicks. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

COOKIES AND WEB BEACONS

CVCA uses cookies. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/​or other information.

Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.

For more general information on cookies, please read What Are Cookies”.

WHAT ABOUT LINKS TO OTHER WEBSITES?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. CVCA is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

ADVERTISING PARTNERS PRIVACY POLICIES.

Third-party ad servers or ad networks use technologies like cookies, JavaScript, and/​or Web Beacons that are used in their respective advertisements and links that appear on CVCA, which are sent to your browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/​or to personalize the advertising content that you see on websites that you visit.

Note that these cookies are controlled by the applicable third-party advertisers and other third parties, not the CVCA.

HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?

We may use and disclose your personal information:

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes for which we have obtained your consent to use or disclose your personal information.

We may use or disclose your personal information without your knowledge or consent where permitted or required by applicable law.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

The personal information we collect is used and disclosed for our business purposes, including for those purposes explained in this Privacy Policy.

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you and otherwise to achieve the purposes for which the information was collected.

We may disclose your information to third parties, including: third parties that provide services to us or on our behalf; third parties that assist CVCA in the provision of services to you; and third parties whose services we use to conduct our business.

For example, Cloudways, CraftCMS, WordPress, Cloudflare, and others may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada, the United States of America, and other global locations. In these circumstances, the governments, courts, law enforcement, national security, or regulatory agencies of such other jurisdictions may be able to obtain access to your personal information through the laws of the foreign country.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of CVCA through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise. 

Further, your personal information may be disclosed:

  • as permitted or required by applicable law;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • as part of CVCA’s regular reporting activities to its parent and affiliated companies;
  • to protect the rights and property of CVCA;
  • during emergency situations or where necessary to protect the safety of a person or group of persons;
  • where the personal information is publicly available; or
  • with your consent. 

If you use interactive functions of the Website, your information may be available to the public. For example, if you make a post to a public area of the Website, the contents of your post, as well as information about you, like your username, may be accessible by other users of the Website. Furthermore, if you participate in virtual meetings or conferences over the Website, information you transmit, including audio/​video information and your name and contact information, may become available to other participants. 

HOW IS YOUR PERSONAL INFORMATION PROTECTED?

CVCA endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.

The security of your personal information is important to us. Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

UPDATING YOUR PERSONAL INFORMATION

It is important that the information contained in our records is accurate and current. If your personal information happens to change, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

ACCESS TO YOUR PERSONAL INFORMATION

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

CALIFORNIA CONSUMER PRIVACY ACT PRIVACY RIGHTS (DO NOT SELL MY PERSONAL INFORMATION) 

This section applies to you if you are a resident of California. Under the California Consumer Privacy Act, among other rights, California consumers have the right to:

Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

Request that a business delete any personal data about the consumer that a business has collected.

Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

GENERAL DATA PROTECTION REGULATION DATA PROTECTION RIGHTS 

This section applies to you if you are a resident of the European Union. We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

CHILDREN’S INFORMATION

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/​or monitor and guide their online activity.

CVCA does not knowingly collect any personal identifiable information from children under the age of 18. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e‑mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

REVISIONS TO THIS PRIVACY POLICY

From time to time, we may make changes to this Privacy Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website https://​www​.cvca​.ca/​p​r​i​v​a​c​y​-​p​olicy and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on the date provided above.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word including” is used, it shall mean including without limitation.”

This Privacy Policy does not impose upon CVCA any obligations, or create or confer upon any individual any rights, outside of, or in addition to, those imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.