This Website is operated by NorthBrook Capital Corp. and its affiliates (the “Operators”). All trademarks, service marks and trade names displayed on this site are proprietary to NorthBrook or its affiliates except as otherwise specifically noted. The services and products described on this Website and any functionality that may be available through it are intended to be made available only to persons in Canada and the United States, and the information on this Website and any functionality that may be available through it is only for such persons. Nothing on this Website and any functionality that may be available through it shall be considered a solicitation to buy or an offer to sell a product or service to any person in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction.
OBJECT & SCOPE OF POLICY
NorthBrook Capital Corp. (“NorthBrook”) and its affiliates (the “Operators”) are committed to respecting your privacy and have prepared this memorandum to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.
This policy governs Personal Information collected from and about:
individuals who are or may become Clients of NorthBrook,
individuals or organizations who utilize NorthBrook’s Website functions, and
individuals or organizations with whom NorthBrook works.
Using contractual or other arrangements, NorthBrook shall ensure that agents, contractors or third party service providers, who may access Personal Information in the course of providing services to NorthBrook, shall protect that Personal Information in a manner consistent with the principles articulated in this policy.
This policy does not cover aggregated data from which the identity of an individual cannot be determined. NorthBrook retains the right to use aggregated data in any way that it determines appropriate.
In the event of questions about: (i) access to your Personal Information; (ii) NorthBrook’s collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact:
406 North Service Road East
THE COLLECTION, USE & DISCLOSURE OF PERSONAL INFORMATION
For the purposes of this Policy:
“Client” means an individual or organization who entered into a written contractual agreement with NorthBrook under which NorthBrook will provide products or services at that price agreed upon in the contractual agreement;
“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be specifically inferred or determined from such information
“Users” means individuals or organizations who utilize NorthBrook’s Website functions.
NorthBrook, its affiliates, employees, funding partners and third party servicers may use personal information for the purposes of aggregating, assessing and analyzing data that may be disseminated in the course of NorthBrook’s work on the basis the Personal Information is not disclosed within the aggregation.
NorthBrook’s use of Personal Information is limited to these purposes. NorthBrook does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no personal information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information. FOR CERTAINTY PROVIDING INFORMATION INTO THIS WEBSITE CONSTITUES YOUR CONSENT TO SUCH COLLECTION.
NorthBrook does not knowingly collect Personal Information from anyone under the age of 18 and does not use such information if NorthBrook discovers that it is has been provided by a minor.
Personal Information may also be transferred to another company in the event of a change of ownership of all or part of NorthBrook or the sale of select assets.
NorthBrook may disclose Personal Information of Clients to organizations that perform services on its behalf. This will only be done if such organizations agree to use such information solely for the purposes of providing services to NorthBrook and, with respect to that information, to act in a manner consistent with this policy.
NorthBrook may disclose Personal Information where it is required to so by law or regulatory requirements.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where NorthBrook is obliged to disclose information without consent. Such circumstances may include:
Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
Where NorthBrook believes, based upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
Where it is necessary to establish or collect monies owing to NorthBrook;
Where it is necessary to permit NorthBrook to pursue available remedies or limit any damages that NorthBrook may sustain; or
Where the information is public.
NorthBrook does not endeavor to ensure that any Personal Information provided by Clients or Users or that is in its possession is as accurate, current and complete as necessary for the purposes for which NorthBrook uses that data. NorthBrook is not obligated in any way to verify the completeness or accuracy of any Personal Information beyond what it determines to be adequate at its sole discretion. Information contained in files that have been closed or are not in use is not actively updated or maintained.
NorthBrook retains Personal Information as long as NorthBrook believes it is necessary to fulfill the purpose for which it was collected and for legal or business requirements. NorthBrook’s policy is to destroy all Personal Information not required by NorthBrook at the earliest opportunity convenient to our business processes.
NorthBrook endeavors to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.
NorthBrook further protects Personal Information by restricting access to it to those Employees and Contractors that the management of NorthBrook has determined need to know that information in order that NorthBrook may provide its services.
ACCESS TO PERSONAL INFORMATION
NorthBrook permits access to and review of Personal Information held by NorthBrook about an individual by the individual concerned.
If an individual believes any Personal Information concerning that individual is not correct, that person may request an amendment of that information by sending a request to the person indicated in this Policy. NorthBrook reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. Where not required to be retained by the NorthBrook, an individual may also request that NorthBrook delete an individual’s Personal Information from NorthBrook’s system and records. However, due to constraints of computer technology and the fact that NorthBrook backs up its systems, Personal Information may continue to reside in NorthBrook’s systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from NorthBrook’s systems in response to an accepted request for deletion.
NorthBrook reserves the right to decline access to Personal Information where the information requested:
Would disclose the Personal Information of another individual, organization or a deceased individual;
Would disclose confidential business information that may harm NorthBrook or the competitive position of a third party;
Is subject to solicitor-client litigation privilege;
Could reasonably result in: (i) serious harm to the treatment or recovery of the individual or organization concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual;
May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
Is not readily retrievable and the burden or cost of providing such information would be disproportionate to the nature or value of the information; or
Does not exist, is not held, or cannot be found by NorthBrook.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Where information will be disclosed, NorthBrook will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.
NorthBrook will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which the information is amended, the purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, NorthBrook will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
AMENDMENT OF PRACTICES AND THIS POLICY