Privacy Policy
Last updated June 2023
Active Impact Investments (“we”, “us”, “our”) is committed to protecting and respecting your privacy in accordance with data protection laws that are applicable in Canada.
This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, that you provide to us, or we receive from others will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This website is not intended for children and we do not knowingly collect data relating to children.
Active Impact Investments Management Inc. is the controller and is responsible for this website. If you have any questions about this privacy policy, including any requests to exercise any of your legal rights, please refer to the contact information below. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Information we collect from you
Whether you are an individual investor or a director/shareholder of a company that we are thinking of investing in, or someone from within our network who wishes to have a relationship with us, we may collect and process different kinds of personal data about you, which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes home address, office address, email address and telephone numbers.
Financial Data includes bank account and payment details.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call us.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special category personal data
In certain circumstances, we may collect, store and use your sensitive personal data, known under the UK GDPR as ‘special category’ data. We will do this when you provide us with information about your racial or ethnic origin. Please see below for further details on how we process special category data.
How we collect your personal data
Personal data you give us. This may include Identity Data, Contact Data, and Financial Data about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes personal data you provide when you sign up to receive our newsletter, submit an Entrepreneur Form, and submit an Investor Form.
Personal data we collect about you. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
Personal data we receive from other sources. This includes personal data we receive about you from third parties including, for example: (i) business partners such as accountants and lawyers, located both inside and outside Canada; (ii) portfolio companies, investors and suppliers, located both inside and outside Canada; (iii) analytics providers such as Google; and (iv) publicly available sources such as LinkedIn.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
You may accept or decline our use of non-essential cookies when prompted upon visiting our site. If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.
Uses made of the personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email, certain introductions or using non-essential cookies on our website.
Investment evaluation
Active Impact is likely to receive and store personal information as part of its investment evaluation process. If you are involved in a transaction that Active Impact enters into, or a potential transaction that Active Impact considers, we may store personal information relating to you. This might include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence carried out. We collect and store this information for the purposes of:
Evaluating a transaction and your role in it;
Executing transactions;
Managing an investment once made;
Maintaining records of investments;
Meeting regulatory and legal obligations;
Safeguarding our legal rights and interests;
Seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
Providing periodic business updates, as described below.
We store and process information in this way because it is necessary to:
Perform a contract to which you are likely to be a party;
Comply with a legal or regulatory obligation; and/or
Protect our legitimate interests in running and promoting our business.
How we will use your special category personal data
We may collect information about your race or ethnic origin to ensure meaningful equal opportunity monitoring and reporting. We will only do this where you have provided us with your explicit consent, to allow us to collect and process this type of information.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing activities. If you are an individual, you will receive marketing communications from us because you have requested to receive them or previously entered into a relationship with us and, in each case, you have not opted out of receiving marketing.
If we are contacting you as a business then we are entitled to contact you on the basis of our legitimate interests (to develop and grow our business) with marketing information provided that you have not previously opted out of receiving such communications. In some circumstances you may receive marketing communications from us if we have collected your Identity Data and Contact Data from a publicly available source, however you will always be provided with the opportunity to opt-out of receiving these communications.
Third-party marketing
We will not share your personal data with any company outside Active Impact for marketing purposes.
Opting out
All email marketing communications have unsubscribe instructions included in the message. Alternatively, you can ask us to stop sending you marketing messages at any time by contacting info@activeimpactinvestments.com.
Disclosure of your personal data
Active Impact may have to share your personal data with select third parties including:
Business partners, including portfolio companies and investors, acting as processors or joint controllers based inside and outside Canada.
Suppliers and sub-contractors acting as processors based inside and outside Canada who provide IT and systems and administration services.
Professional advisers acting as processors or independent controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities, including HMRC acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal data to third parties:
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Active Impact, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
Under Canadian data protection laws, you have a general right to obtain access to your personal information held by organizations. You can exercise this right with us at any time by contacting info@activeimpactinvestments.com. Under certain circumstances, by law you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to another party. If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us.
Third party sites
Our site may, from time to time, contain links to and from the websites of our partner companies. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Changes to Our Privacy Policy
Our privacy policy is subject to regular review and this page will host the most up to date version.
Contact Information
Please direct questions, concerns, or requests for more information to info@activeimpactinvestments.com