VAULTRA ASSET MANAGEMENT CORP.

Privacy Policy

At Vaultra Asset Management Inc. and our affiliated companies (“Vaultra”, “we”, “our” and “us”), we are committed to maintaining the accuracy, confidentiality and security of your personal and non-personal information obtained through our website. This Privacy Policy guides Vaultra in the collection, use, retention and disclosure of your personal and non-personal information.

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications.

What Information Do We Collect?

We collect and maintain different types of personal and non-personal information in respect of the individuals with whom we interact through our website.

As a general rule, Vaultra collects personal information directly from you. For example, if you request information through our website, we may collect your name, mailing address, telephone number and e-mail. If you communicate with us regarding our services, we will collect any information that you provide to us in any such communication.

We also automatically collect non-personal information from you. This information cannot be used to personally identify you. This information includes your browser type, the URL of the previous website you visited, your Internet Service Provider, your operating system, your IP address, clickstream patterns and the dates and times that you accessed our website. In addition, we may collect “cookie” information from your browser to identify your computer and provide us with a record of your visits to our website. The technology used to gather “cookie” information is provided by the Internet browser you use and is stored on your computer. You may set your browser to disable or refuse to accept “cookies”, although doing so may affect your viewing of certain portions of our website.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect, Use Or Disclose Your Information?

Vaultra collects personal information to enable us to manage, maintain and develop our business and operations. We use non-personal information to track your use of our website in an effort to evaluate, maintain and improve our website.

How Do We Use And Disclose Your Information?

Vaultra may use or disclose your information: for the purposes described in this Privacy Policy; or for any additional purposes for which we have obtained your consent to the use or disclosure of your personal and non-personal information.

When Do We Disclose Your Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Vaultra in the provision of services to you; and third parties whose services we use to conduct our business. In these circumstances, Vaultra discloses only the information that is necessary.

We will disclose non-personal information, usually in aggregate form, to potential strategic partners, advertisers, investors, customers and others.
Further, your personal and non-personal information may be disclosed: as permitted or required by applicable law or regulatory requirements; to report to and cooperate with local, provincial, territorial, national, and international authorities and investigations of improper or unlawful activities; to comply with valid legal processes such as search warrants, subpoenas or court orders; as part of our regular reporting activities; to protect the rights and property of Vaultra ;during emergency situations or where necessary to protect the safety of a person or group of persons; where the personal and non-personal information is publicly available; or where required by law, with your consent.

Your Content Is Important To Us

It is important to us that we collect, use or disclose your information where we have your consent to do so. Depending on the sensitivity of the information, your consent may be express, implied or deemed (using an opt-out mechanism). Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.

As we have described above, we may collect, use or disclose your information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Deemed Consent (Opt-Out)

Vaultra. We will let you know the implications of withdrawing your consent.

You may not opt-out of sharing non-personal information. Such information cannot be used to identify you personally.

Use Of Third Party Websites

Vaultra’s website may include links to third party websites. If you provide information to another organization on another website through a link available on our website, we will not be responsible nor liable for the collection, use or disclosure of such information. Vaultra encourages you to examine the other organization’s privacy policy.

How Is Your Information Protected?

Vaultra endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the information in question. These safeguards are designed to prevent your information from loss and unauthorized access, copying, use, modification or disclosure. While we will take commercially reasonable efforts to safeguard the privacy of the information you provide to us and treat such information in accordance with this Privacy Policy, in no event will the information you provide to Vaultra be deemed to be confidential, create any fiduciary obligations to you on our part or result in any liability to you on our part in the event such information is inadvertently released by us or accessed by third parties without our consent.

Confidentiality And Transmissions Over The Internet

Vaultra endeavours to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the information in question. These safeguards are designed to prevent your information from loss and unauthorized access, copying, use, modification or disclosure. While we will take commercially reasonable efforts to safeguard the privacy of the information you provide to us and treat such information in accordance with this Privacy Policy, in no event will the information you provide to Vaultra be deemed to be confidential, create any fiduciary obligations to you on our part or result in any liability to you on our part in the event such information is inadvertently released by us or accessed by third parties without our consent

Access To Your Personal Information

If you request access to your personal information, Vaultra will respond to your request within thirty (30) days. Acceptable proof of identification will be required before responding to such a request. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact Shawn Shanmuganathan – Privacy Officer at snathan@vaultra.ca. If you want to review, verify or correct your personal information, please contact Shawn Shanmuganathan – Privacy Officer at snathan@vaultra.ca. Please note that any such communication must be in writing.

Vaultra may not be able to provide you with access to your personal information where the information cannot be separated from the records of others, cannot be disclosed for reasons of security or commercial confidentiality or is protected by legal privilege. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Feedback

If you have any questions, comments, or concerns about this Privacy Policy or how we manage your information, please contact Shawn Shanmuganathan – Privacy Officer at snathan@vaultra.ca. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you.

Revisions To This Privacy Policy

Vaultra reserves the right to modify or amend the terms of its Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your information without notice or liability to you. We will post any revised version of this Privacy Policy on our website at www.vaultraselfstorage.ca and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on November 1st, 2016.

Interpretation Of This Privacy Policy

This Privacy Policy does not create or confer upon any individual any rights or impose upon Vaultra any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.