TorQuest Partners and our affiliated entities (​“TorQuest”,​“we”,​“us” or​“our”) respects your privacy choices and is committed to the protection of your personal information.

This Privacy Policy outlines how TorQuest collects, uses and discloses your personal information gathered about you, in conformance with its applicable privacy law obligations.

This privacy policy applies to personal information we collect, use or disclose when you:

use our website located at https://​torquest​.com/ (“website”),

submit personal information to TorQuest, including on a voluntary basis,

apply for a job with us,

authorize us to obtain personal information from other sources, or

interact with us in any other way (by telephone, email, and in person).

Accordingly, by visiting our website, submitting personal information to us, or otherwise interacting with us, you agree to this Privacy Policy and our Terms and Conditions.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE OR PROVIDE US YOUR PERSONAL INFORMATION.

About TorQuest

TorQuest is a Canadian-based manager of private equity funds.

What is personal information?

“Personal information” or ​“your information” is any information, whether factual or subjective, about an identifiable person. This includes information such as your name, address, telephone number, birth date, and e‑mail address.

This Privacy Policy does not cover information other than personal information, such as business or anonymous information.

Information we collect about you and how we collect it

The type of personal information we collect depends on various factors, such as any applicable legal and regulatory obligations and the channel through which you communicate with us. This information includes:

• Contact information that allows us to communicate with you or facilitate your attendance at an event, such as your name, address, telephone number, email, or other electronic address;
• Identity information that allows us to establish and verify your identity, including government-issued identification, date of birth, occupation, and similar details;
• Online activity information, like your IP address and how you use our website, which is obtained from your online interactions with us. See ​“Interacting with us online” below for details; and
• Any other information you choose to provide us.

In addition to the purposes identified in this Privacy Policy, we may inform you of other purposes from time to time, either in writing or orally.

While navigating our website, during an email, in-person or telephone interaction or through your interactions with our third-party partners or service providers, we may ask that you provide us with your personal information for certain purposes. We may also collect your personal information when you request information from us, register to participate in an online forum or for one of our events or otherwise communicate with us in the ordinary course of our business.

TorQuest strives to limit collection, use and disclosure of personal data in the course of transactions. However, where reasonably necessary for business transactions, we may collect personal information from, or disclose personal information to third parties. This may include information for background checks (including criminal and credit checks) or for proposed or actual purchase, sale, financing, investment or other type of transactions.

We may also collect information from third parties to manage business and credit risk; collect outstanding debt; detect, prevent, manage, and investigate or protect against fraud or other unauthorized or illegal activity.

In all cases where you voluntarily provide personal information to us, we undertake to collect, use and/or disclose it in accordance with this privacy policy and applicable laws.

Interacting with us online

TorQuest collects personal information such as your IP address, and information obtained through cookies and similar technologies. 

Collection Through Cookies

A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and to record your preferences for future visits.

We use cookies and related technologies to collect information to understand how you use our website. In addition, TorQuest may use third party cookies that track how you use the website and the websites you link to when you leave our website.

Any information gathered from the website via cookies is used solely to improve the content of our website and to enhance the user experience.

You may block cookies by adjusting your internet browser settings, although this may interfere with the functionality of the TorQuest website. For more information on blocking cookies or targeted advertising, visit the Digital Advertising Alliance of Canada page at http://​yourad​choic​es​.ca/​c​h​o​ices/.

Do Not Track

Some internet browsers may be configured to send ​“Do Not Track” signals to the online services that you visit. We currently do not respond to ​“Do Not Track” or similar signals. To find out more about ​“Do Not Track,” please visit http://​www​.allaboutd​nt​.com.

How we use your information

We use personal information to:

• communicate with you, including to authenticate your identity and ensure that your information is correct and accurate;
• provide you with information that you request from us;
• keep you informed about news items, investment prospects, fund developments and relevant business opportunities that may be of interest to you;
• track website usage, transaction history and patterns;
• evaluate, establish and maintain commercial relationships and fulfill contractual obligations;
• facilitate business transactions, including evaluating, effecting, monitoring and managing investments;
• monitor and support our portfolio companies;
• conduct research, perform analytics and improve our business operations;
• manage our business and day-to-day business and operational needs;
• protect us, including investigating and protecting against fraudulent, harmful, unauthorized, or illegal activity, and protecting our property, interests, and legal rights;
• comply with our legal obligations; and
• fulfil other purposes related to any of the above.

Job applicants

If you apply for employment, TorQuest, in order to process your job application, may collect and process data about your career interests and employment history (“job applicant data”). Job applicant data is used for staffing and recruitment activities, and to maintain an inventory of candidates for current and future work opportunities. In processing your job application, we may collect personal information from third parties, including references you provide.

De-identified, aggregate or anonymized information

We may also de-identify, aggregate or anonymize information to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products, services or offers. 

Sharing your information

To perform the activities identified above, we may share your information with our affiliates, business partners, and third parties who perform services on our behalf. We use service providers to:

• Support our internal business operations (like our compliance and human resources functions);
• Assist with IT functions, such as operating and protecting our website and other IT assets;
• Improve our ability to communicate and manage our relationship with you; 
• Assess and manage business transactions (including potential transactions) and existing investments; and
• Obtain professional advice and services, such as from lawyers or accountants.
• In addition, TorQuest may disclose your personal information to:
• third parties in connection with a potential business transaction (such as a merger, sale of all or part of its business, transfer of assets, bankruptcy, or similar event), or as part of completing such a transaction;
• any third party we deem appropriate to comply with legal obligations, enforce our policies, protect our or others’ rights, interests, property or safety, and prevent, investigate or otherwise address any other harmful, unauthorized, fraudulent or illegal activity; or
• anyone else to whom you authorize us to disclose it.

In certain circumstances, TorQuest may have a legal duty or right to disclose personal information without your knowledge or consent. For example, TorQuest may need to disclose personal information in order to comply with tax or corporate governance legislation, to assist law enforcement or for debt collection purposes, for loss and fraud prevention, or as part of supervisory examinations by regulatory or other governmental authorities with jurisdiction over us or our affiliates.

Retention and international storage of your information

TorQuest retains personal information only for the amount of time needed to fulfil the purposes for which it was collected or as permitted by law, after which the personal information is destroyed or made anonymous. Unless you tell us otherwise, your consent remains valid after termination of our relationship with you.

TorQuest, our affiliates, and our service providers may transfer, store or access your personal information across Canada, the United States, or other countries. This means that your personal information may be transferred or stored outside your province, state, or country of residence. Additionally, some of our service providers may store personal information in the United States or other countries and will be subject to the laws of the local jurisdiction. We take measures to protect your information wherever it is handled. However, like in Canada, we and our service providers may disclose your information in response to valid demands or requests made by governments, regulators, courts and law enforcement authorities in these other regions or as otherwise required by local law.

Europe and the United Kingdom

If you are dealing with us within the European Economic Area (“EEA”) or the UK, please note that any personal information (sometimes called ​“personal data”) that we hold may be transferred to, and stored at, a country outside of the EEA or the UK. Where we transfer data to our affiliates or service providers in countries outside the EEA or the UK, we will do so in accordance with applicable data protection laws.

Safeguarding your information

Personal information under TorQuest’s control is protected by physical, organizational and technological safeguards appropriate to the sensitivity of the information.

TorQuest will take steps to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. TorQuest maintains physical security over its premises and also maintains computer and network security. TorQuest requires its employees to respect the confidentiality of any personal information held by TorQuest. We also have policies for the destruction and retention of your information (see ​“Retention and international storage” above) and the handling of privacy-related questions and complaints (see ​“Your privacy options” and ​“Contact us” below).

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

Hyperlinks

TorQuest website may contain hyperlinks allowing users to visit other sites operated by other companies. TorQuest is not responsible for the privacy practices or content of any of such websites to which we link. If you access such third-party websites, either directly or via the website, you should review the privacy policy of each site.

Your privacy options

Withdrawing consent

Subject to legal, business or contract requirements, you can withdraw your consent to our collection, use and sharing of information at any time by giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products and services.

Accessing and correcting your information

We take all reasonable steps to ensure that your personal information is accurate, up-to-date, complete, relevant and updated as necessary to fulfil the purposes for which it is used. You can contact TorQuest to request access to your personal information to review its accuracy or to update your personal information. Please make a request in writing using any of the contact methods outlined below.

TorQuest does not interact with children under the age of 18. If you believe that a minor under your guardianship has provided personal information to TorQuest, please contact us.

Submitting questions and concerns

If you have any questions about privacy and confidentiality or any concerns regarding your privacy, please contact us in writing using the information below.

Contact us

To submit an access or correction request, exercise your privacy choices, ask a question, or submit a complaint, please contact us at:

TorQuest Partners
161 Bay Street, Suite 4240
Toronto, ON M5J 2S1
Attn: Jason R. Galbraith, Chief Legal Officer

Or email us at:

info@​torquest.​com

Please note that we may need to confirm your identity or request additional details in order to process your request.

Changes to our Privacy Policy 

We reserve the right to modify this Privacy Policy at any time, without notice, in our sole discretion, so please review it frequently. This Privacy Policy may be updated periodically to reflect changes to our personal information practices and services. The revised Privacy Policy will be posted on this website. 

Last Modified November 2023