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TorQuest Partners Privacy Policy

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 its applicable privacy law obligations.

This privacy policy applies to 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, and
  • interact with us in any other way (by telephone, email, and in person).

Accordingly, by visiting our website, submitting information or applying for a job you acknowledge that you accept the terms of this privacy policy and website Terms of Use.

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 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 is not intended to cover information other than personal information, such as business or anonymous information.

Your consent

TorQuest will obtain your consent (through this privacy policy or other means) to collect, use and/or disclose personal information except where we are authorized or required by law to do so without consent. From time to time, we may wish to use or disclose your personal information for new or additional purposes. We will obtain your consent to use or share your personal information for such new or additional purposes before doing so.

Information we collect about you and how we collect it

TorQuest will inform you of the purposes for which we collect, use and share personal information before or at the time the information is collected. In addition to the purposes identified below, 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 data from, or disclose personal data 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 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.

Often it is optional for you to provide your personal information, but other times some personal information is required to serve you. You may choose not to provide your personal information even in such cases, but that may result in our inability to serve you.

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.

In general, TorQuest does not collect personal information that can identify you when browsing our website. However, certain non-identifying information such as an IP address, cookies, Internet tags and navigational data may be automatically collected using cookies and similar technologies. This information is used to improve the content of our website and to enhance the user experience.

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/.

Collection Through Google Analytics

TorQuest also uses Google Analytics, a web analytics tool from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses information obtained by the cookies to evaluate your use of our website for us, to create reports on website activities and to provide further services related to the website and the internet usage for us. This information may be transmitted to a server in the USA and stored there. Please note that Google Analytics information may be disclosed to marketing agency partners that use the data to optimize marketing campaigns. Google will not associate your IP address with any other data held by Google. For more information on Google’s privacy policy in general and Google Analytics, please visit their website at www​.google​.ca/​p​o​l​i​c​i​e​s​/​p​r​i​vacy/ and www​.google​.com/​a​n​a​l​ytics. You can deactivate the Google Analytics function with a browser add-on, which you can download at https://​tools​.google​.com/​d​l​p​a​g​e​/​g​a​o​ptout. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.

TorQuest will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the purposes it was collected or as authorized by law.

How we use your information

We use information that we collect about you or that you provide to us, including any personal information:

  • to communicate with you, including to authenticate your identity and ensure that your information is correct and accurate;
  • to provide you with information that you request from us;
  • to keep you informed about news items, investment prospects, fund developments and relevant business opportunities that may be of interest to you;
  • to track website usage, transaction history and patterns;
  • when you engage with TorQuest online, including through our website and through social media;
  • evaluating, establishing and maintaining commercial relationships and fulfilling contractual obligations;
  • facilitating business transactions, including evaluating, effecting, monitoring and managing investments;
  • monitoring and strategic oversight of our portfolio companies;
  • for researching, analyzing, developing, managing, protecting and improving our business operations;
  • to manage our business and day-to-day business and operational needs;
  • establish and maintain communication with employees, investors, and business partners;
  • 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.

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. Such information may also be shared with third parties for other analytical purposes but will not personally identify any individual and therefore is not subject to this privacy policy.

Disclosure of your information

TorQuest may disclose your personal information to:

  • our affiliates (including investment funds under management and their respective portfolio companies), other companies, investors, business partners, consultants, vendors or individuals who assist us in providing services, who perform functions on TorQuest’s behalf or for our internal business purposes;
  • third parties in connection with the potential merger, sale of all or part of its business, transfer of assets, bankruptcy (or similar event) and as part of completing such a transaction. By providing your personal information to us, you agree that we may disclose your personal information, on a confidential basis, to any prospective transferee and its professional advisors for the purposes of their due diligence investigations, the completion of any such transaction and the continued operation of the acquired business;
  • our affiliates for internal management and administrative purposes on our behalf;
  • comply with the law, enforce our site policies, protect ours or others’ rights, property or safety, prevent other harm or loss or in connection with an investigation of suspected or actual fraudulent or illegal activity and/or
  • anyone else to whom you authorize us to disclose it.

If TorQuest discloses personal information to third parties engaged to perform services for us, TorQuest prohibits the third party from using personal information for any purpose other than the specific purpose for which TorQuest supplies it. TorQuest requires third parties who receive personal information to use safeguards equivalent to those in place at TorQuest to protect that information.

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 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 may store your personal information in its databases located in the United States, Canada, or other countries. 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. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the personal information collected and held by TorQuest. In addition, if you are visiting our website from a country other than Canada, your communication through our website or any of our services may result in the transfer of information across international boundaries. By using our website or any of our services, you consent to the collection, storage, and processing of your information in Canada, United States and in any country to which we may transfer your information in the course of our business operations.

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 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 take reasonable steps to seek to ensure that those transfers take place 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 all commercially reasonable steps to ensure that your personal information is protected 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.

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.

Accessing or correcting personal 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.

Resolving privacy issues

If you have any questions about privacy and confidentiality or any concerns about the way a request for personal information was handled, please contact us in writing using the contact methods listed below.

Contact us

If you have any questions or concerns about this privacy policy or about TorQuest’s handling of your personal information, please contact us in writing at:

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

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. We will treat your personal information in accordance with the privacy policy in place at the time of collection of such information, or as you otherwise consent. Whenever you need to refer to this privacy policy you should refer to this website to ensure you have the most up to date version.

Last Modified August 2020