Privacy Policy

Privacy Practices

Helios Fairfax Partners Corporation (“HFP”), Helios Investment Partners LLP (“HIP”) and their respective affiliates and subsidiaries (collectively, the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose Personal Information.

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. This Privacy Notice describes our processing practices of Personal Information that we collect and use in connection with:

• Websites operated by us from which you are accessing this Privacy Notice (the “Websites”);
• Our social media pages from which you are accessing this Privacy Notice (collectively, our “Social Media Pages”);
• Email messages that we send to you that link to this Privacy Notice or other communications with you; and
• Offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, and offline business interactions as the “Services.” By accessing the Services or otherwise providing us with Personal Information, you consent to the collection, use and disclosure of your Personal Information as set out in this Privacy Notice.

Collecting Your Personal Information

We collect the following categories of Personal Information:

Personal Information we receive from you:

Name & Contact Details: Such as first and last name, title, prefix, email address, telephone number, postal address, date of birth, gender, country of residence.

Business Contact Details: Such as company name, business email address, business telephone number, business postal address, country of business.

Account Information: Such as your chosen username and password, avatar, and other information you provide to us in connection with your account(s) on the Websites.

Billing Information: Such as bank account details and billing address.

User Content: Such as reviews about our products and Services and other content you may create or share, including posts on our Social Media Pages, blogs, and comment sections.

Preferences: Such as your language preferences, interests, and other feedback/preferences that you express during your use of our Services.

Marketing Data: Such as your choices regarding and engagement with our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication.

Relationship History: Such as details of your communications with us, and details of your claims, complaints and queries in general.

Transaction Information: Such as details of Services you have obtained from us.

Visitor and Event Information: Such as dietary restrictions, travel and accommodation details, issued identification pass to access the premises, and other details specific to a particular event or conference that you share with us.

User Photographs and Videos: Such as photos and videos submitted by you while using our Services.

Telephone Call Recordings: Such as audio recordings of telephone calls when you contact us.

Personal Information we collect through your use of our Services or from other sources:

Social Media Information: Such as profile pictures, social media account ID, and other social media profile information, including lists of friends/followers on social media.

Event Photographs and Videos: Such as photos and videos taken at one of our events/conferences.

CCTV and Site Security Information: Such as images or video footage captured or recorded by CCTV and other security measures on our premises.

Device Information: Such as information about your devices and your use of our Services. This includes data obtained through cookies and similar technologies (see the section below entitled “Cookies and Similar Technologies” for further details).

Credit Report Information: Such as consumer reports that we might obtain when you apply for an investment account.

Sensitive Information

Unless we expressly request it, we ask that you not provide us with any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services or otherwise to us.

Cookies and Similar Technologies

We may collect personal information through the use of cookies and other similar technologies.

• Cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html (http://www.allaboutcookies.org/manage-cookies/index.html). If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services (for example, certain Website features may not function correctly).
• Pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/ (http://www.google.com/policies/privacy/partners/), and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout (https://tools.google.com/dlpage/gaoptout).
  

Using Your Information

We use your personal information for the following legitimate business purposes:

• Providing the Services to you, such as arranging access to your online account and verifying your information and identity.
• Administering care services to facilitate and address inquiries, requests, comments and complaints about any of our services (such as in person, through phone lines, email, or on social media), for example, to send you documents or product information you request or assist you in using the services.
• Sending you important information regarding our relationship with you, our services, any changes to our terms, conditions, policies and procedures, and/or other administrative information.
• Administering and maintaining the online Services (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and services, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and the hosting of data).
• Facilitating and participating in conferences and events, and welcoming guests and visitors to our premises.
• Sending you promotional information about our services, newsletters, promotions, offers and other news about our businesses. Please note that you may opt out of receiving marketing or promotional communications from us at any time by contacting us using the information listed below under “Contact Us.”
• Conducting prize promotions, contests and other promotional offers. If you participate, we will use your information to administer such promotions and offers. Some of these promotions have additional rules containing information about how we will use and disclose your personal information, which we will communicate to you separately.
• Facilitating and responding to any reviews, social media sharing and posts.
• Personalizing our interactions with you, including by providing you with information and/or offers tailored to your interests, [such as targeted advertising tailored to your interests], on our online Services as well as our marketing partners’ platforms, and delivering content via our Services that we believe will be relevant and interesting to you.
• Conducting data analysis, for example, monitoring and analyzing usage of services and using data analytics to improve the efficiency of our services; develop new products and services; consider ways for enhancing, improving, repairing, maintaining or modifying our current products and services; identify usage trends, for example, understanding which parts of our services are of most interest to users; determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and operate and expand our business activities, for example, understanding which parts of our services are of most interest to our users so we can focus our energies on meeting our users’ interests.
• Aggregating and/or anonymizing personal information so that it will no longer be considered personal information, after which we may use it for internal analytics or other legitimate business purposes.
• Conducting audits, verifying that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements, monitoring for and preventing fraud, and maintaining our security, including system security and on-site security of our premises.
• Fulfilling our legal and compliance-related obligations [hyperlink to ‘other disclosures’], including complying with applicable laws, complying with legal processes, responding to requests from public and government authorities, and meeting national security or law enforcement requirements.
• Enforcing our terms and conditions; protecting our operations; protecting the rights, privacy, or property of the company; and allowing us to pursue available legal remedies, defend claims and limit the damages that the Company may sustain.
• Ensuring the safety of on-site personnel and visitors; responding to, handling and documenting on-site accidents and medical and other emergencies; actively monitoring properties to ensure adequate incident prevention, response and documentation (including CCTV); requesting assistance from emergency services; and sending notifications and alerts in the event of incidents or emergencies (such as via SMS, email, call, audio-visual device prompts, etc.).
  

Sharing Your Personal Information

Service providers and partners

We may share your information with trusted third party recipients, including service providers that assist us with providing the Services and fulfilling our obligations by performing services on our behalf. Third-party service providers include information technology service providers, event coordinators and organizers, marketing and analytics partners, external auditors, and financial and professional services providers, such as consultants and legal counsel.

Other third parties

We may disclose your information to other third parties, such as law enforcement agencies, regulatory and government authorities, courts, tribunals, and emergency services for reasons that include, but are not limited to, the following:

• if we are required to do so by law;
• if a request is made by law enforcement authorities, regulators and/or other government entities and/or other competent authorities;
• in connection with the evaluation or performance of a sale or business transaction, such as a sale of part or all of the Company, a corporate reorganization, or other change in corporate control of the Company;
• when we believe disclosure is necessary or appropriate to prevent harm or financial loss, to detect and prevent fraud, to respond to emergencies, to protect the safety of any person, or in connection with an investigation of suspected or actual fraudulent or illegal activity or the breach of an agreement; or
• when we have obtained your consent, or as otherwise permitted by law.

Security

We use reasonable organizational, technical and administrative measures to protect the Personal Information that we handle. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Choices and Individuals’ Rights

Access, correction, and other privacy rights

Depending on where you live, you may have the right to request to:

1. access, correct, update, suppress, restrict, or delete the Personal Information we maintain about you;
2. object to or opt out of the processing of Personal Information;
3. withdraw your consent to the collection, use and/or disclosure of your Personal Information (which will not affect the lawfulness of processing prior to the withdrawal); or
4. receive a copy of your Personal Information for purposes of transmitting it to another company.

Please note that withdrawing your consent to, or objecting/opting out of, the collection, use and/or disclosure of your Personal Information may affect our ability to provide you with the Services.

How to exercise your rights

Please submit such requests to us in writing in accordance with the “Contact Us” section below. We will respond to your request consistent with the laws that apply in your region.

In your request, please make clear what Personal Information your request pertains to and which privacy right(s) you are intending to exercise. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.

If you are a resident of the European Economic Area (“EEA”), you may lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at https://ec.europa.eu/newsroom/article29/items/612080

Retaining Your Information

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law, for example, for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Once we no longer need to retain your Personal Information, it will be securely disposed of.

The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) other legitimate legal, business or operational needs of the Company.

Where a legal obligation arises or retention is advisable in light of our legal position, in some circumstances, we will retain certain Personal Information, even after your account has been deleted and/or we no longer provide the Services to you; for example:

• To cooperate with law enforcement or public, regulatory and government authorities:
  If we receive a preservation order or search warrant, related to your Services account, we will preserve Personal Information subject to such order or warrant after you delete your Services account.
• To comply with legal provisions on tax and accounting:
  We may retain your Personal Information, such as Billing Information, Relationship History, and/or Transaction Information after you delete your Services account, as required by tax law and to comply with bookkeeping requirements.
• To pursue or defend a legal action:
  We may retain relevant Personal Information in the event of a legal claim or complaint, including regulatory investigations or legal proceedings about a claim related to your Personal Information, or if we reasonably believe there is a prospect of litigation (whether in respect of our relationship with you or otherwise) after the dispute has been settled or decided by a court or tribunal from which there is no further right of appeal.

Third Party Services

This Privacy Notice does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Jurisdiction and Cross-Border Transfer

Your Personal Information may be stored and processed outside of your current province, state, or country, including where we have facilities or in which we engage service providers. By using the Services you understand that your Personal Information will be transferred outside of your current jurisdiction or country of residence, including to the United States, Canada, UK, and the EEA, which may have data protection laws that are different from those of your region. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other jurisdictions may be entitled to access your Personal Information. We use various measures, including contractual requirements, to ensure your Personal Information receives a similar degree of protection when it is transferred outside your current jurisdiction.

Where this will involve transferring your Personal Information outside the [UK and/or] EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Adequacy Decisions: Some non-EEA countries are recognized under the UK GDPR and by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

Standard Contractual Clauses: For transfers of Personal Information from the UK and/or EEA to relevant third countries which are not considered adequate under the UK GDPR and/or by the European Commission, we will put in place standard contractual clauses adopted under the UK GDPR and/or by the European Commission to protect your Personal Information.

Updates to this Privacy Notice

The “Last Updated” legend at the top of this Privacy Notice indicates when this notice was last revised. Any changes will become effective when we post the revised Privacy Notice on the Services. If we make a change to our Privacy Notice, depending on the nature of the change, we may seek to notify you, or obtain your consent, as required by applicable law.

Contact Us

Helios Fairfax Partners Corporation
200 Bay Street, Suite 1301
Toronto, ONM5J 2J2
Canada

If you have any questions about this Privacy Notice, please contact HFP at notices@heliosfairfax.com.

Helios Investment Partners LLP
2nd Floor, 12 Charles II Street, St James’s
LondonSW1Y 4QU
United Kingdom

If you have any questions about this Privacy Notice, please contact HIP at compliance@heliosllp.com.