Newlook Capital Inc. (“Company” or “we”, “our” or “us”) values our customers, including you and we respect your privacy. This privacy policy (the “Policy”) describes the kinds of Personal Information (as defined below) we collect about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. “Personal Information” is defined as information, in any format, about an identifiable individual. This Policy also describes the decisions you can make about your Personal Information. You may require us to change, amend or delete the Personal Information that you have provided to us at any time. If you do not agree to the terms of this Policy, please do not use our website located at www.newlookcapital.com (“Website”).

If this Policy changes in the future, we will post an updated version on our Website. We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways in our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Website after the Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.

By voluntarily providing us with Personal Information, you are consenting to its collection, use and disclosure in accordance with this Policy. You acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Newlook Capital Inc. and authorized third parties referred to herein located in Canada or the United States.

  • 1. Information we collect

When you use our Website, we collect the following types of information.

  • (a) Personal Information you provide to us: We collect Personal Information you provide to us, including your name, phone number and email address as well as any login information such as account name and password created to access our investor portal and other restricted portions of our Website.
  • (b) General usage data: When you use our Website we may collect technical properties of hardware and software used in conjunction with our Website. For example, we may collect the type and model of hardware and/or web browser you are using, referring or exit web pages, and the operating system version you are using. When you use our Website, we may also collect your Internet Protocol (“IP”) address, information about the date and time of your access as well as how long you use our Website in each session, features you use in our Website, and how long you use our Website overall.
  • (c) Cookies: In addition, when you visit our Website, we collect certain information about your activity on our Website, as described below under the heading “Our Use of Cookies and Log Files”.
  • 2. Using Personal Information we collect

We use the Personal Information you have agreed to provide to us in order to: communicate with you; learn more about you and your preferences by looking at, among other things, the IP address of your computer and your activity on the Website; and address problems with, and improve, our Website. You may update your communication preferences anytime by contacting us.

We will not share, sell or rent your Personal Information in personally identifiable form with any third party, except if, and to the extent necessary, in our good faith judgment, doing so is required to: comply with laws or regulations; respond to a valid subpoena, order, or government request; establish or exercise the Company’s legal rights or defend against legal claims; investigate, detect, supress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person; or as otherwise required by law.

We will retain your Personal Information only for a time and to the extent necessary for the purposes for which it was collected as described in this Policy and for reasonable backup, archival, audit, or other similar purposes.

Notwithstanding anything to the contrary contained in this Policy, we may remove personal identifiers from your Personal Information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will be deemed to be owned by us and we shall have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information. We will retain your Personal Information as long as necessary for the fulfillment of the identified purposes or as otherwise necessary to comply with applicable laws.

  • 3. To whom we disclose your Personal Information

In accordance with this Policy, we may share your Personal Information:

  • (a) if we have your consent;
  • (b) within our Company and/or with our service providers in Canada or United States such as the provider of our investor portal and a cloud service provider for data storage;
  • (c) with our portfolio companies, affiliates, funds and managed entities;
  • (d) with our financial, insurance, legal, accounting or other advisors that provide professional services to us;
  • (e) to respond to a subpoena, order, legal process, government request or requests from regulatory authorities, including securities regulators;
  • (f) to protect, establish or exercise our legal rights or defend against legal claims;
  • (g) to investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person;
  • (h) as otherwise required by law; or
  • (i) if we are to be sold, merged, or amalgamated or substantially all of our assets are to be sold or disposed of, your Personal Information may be transferred to a potential purchaser if, and to the extent necessary, it is required for the purposes of deciding whether to proceed with the proposed transaction and completing it. If such a sale, merger, acquisition, or disposal is completed, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with this Policy. Following such a sale or transfer, you may contact the entity to which we transferred your Personal Information with any inquiries concerning the processing of that Personal Information.
  • 4. Your decisions about your Personal Information

At any time you can contact us to: stop receiving e-mails from us; review the Personal Information held by the Company; withdraw your consent for our use and disclosure of your Personal Information; request a list of third parties to which the Company may have provided your Personal Information; and amend your Personal Information, where possible, or by writing to us at the address provided below. You can always unsubscribe from receiving promotional e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional Company e-mail from us.

If you contact us to do any of the things listed above, we may require you to provide sufficient Personal Information to allow us to identify you and tell you about the existence, use and disclosure of your Personal Information and this Personal Information will only be used for this purpose.

Generally, you may withdraw at any time your consent for us to collect, use, and disclose your Personal Information in accordance with this Policy, subject to legal or contractual restrictions and reasonable notice. As such, we may continue to collect, use, and disclose your Personal Information as may be required to provide you with our Website, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your Personal Information, we may no longer be able to provide you with our Website.

  • 5. Our use of cookies and log files

We use browser tracking cookies (or “cookies”), which are small text files that are placed on the hard disk of a computer by a Website. Cookies are uniquely assigned to you, and can only be read by a Website or web server that issued the cookie to you. We also use browser “log files” which record certain information when you visit a Website, including your IP address. To improve your experience on our Website, we use cookies and logs files to: recognize you when you return to our Website; keep track of activity on our Website and remember what items you have clicked on or viewed; study how you navigate through our Website and which Website you request in site searches so that we can improve the design, content and function of our Website; and customize the message, content and delivery of online banner advertisements and e-mails that reflect how you navigate to and through our Website based on your online behavior. We call this “Browsing Data”. We may hire third-party service providers to assist us in the collection and analysis of this Browsing Data collected through cookies, but none of your Personal Information is disclosed to these third party service providers.

You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your internet browser. If you decide to turn off or block cookies, our Website might not function correctly.

  • 6. Security

We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards that are designed to protect the security and privacy of your Personal Information against loss, theft, and unauthorized access, disclosure, copying use or modification. Please note, however, that while we try to create a secure and reliable Website for users, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed.

We limit access to your Personal Information within the Company to individuals on a need-to-know basis.

Your Personal Information may be transferred, processed and retained on servers in countries outside of Canada, including the United States, and may therefore be subject to laws that do not offer the same degree of protection as Canadian law. While we undertake to protect your Personal Information when it is transferred to other jurisdictions, the laws of other jurisdictions may require the disclosure of your Personal Information to governmental authorities under circumstances that are different than those that apply in Canada and are contemplated under this Policy.

  • 7. Links to Other Sites

We may provide links on our Website to other, third party sites we think you will enjoy. These sites operate independently of us and have established their own privacy and security policies. Any Personal Information you provide on linked pages or other sites is provided directly to that third party and subject to that third party’s privacy policy. For example newlookcapital.exemptedge.com/login. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

  • 8. Age Restriction

The Website is not intended for use by individuals under the age of 13. Company does not knowingly collect or use any Personal Information from any individuals under the age of 13. If we become aware that we have unknowingly collected Personal Information from an individual under the age of 13, we will make commercially reasonable efforts to delete such Personal Information from our database.

  • 9. Questions or Comments

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact us by clicking Contact, or by delivery in person, by courier or by the mail, to Company at Newlook Capital Inc. 1550 Appleby Line Suite 100, ​​Burlington Ontario, ​​L7L6V1, or by calling us at 905.331.3697. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

Last Updated: 20-11, 2019

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