We've Got Your Back
This Privacy and Cookie Policy (“Policy”) describes the personal information that Western Wealth Capital Management Ltd. or its affiliates (collectively, “WWC”, “we” or “us”) collects from or about you when you use our website or inquire about, or invest in, our properties or the other services and opportunities that we offer (collectively, the “Services”). It also describes how we collect and use that information, and to whom we disclose it. “Personal Information” means information about an identifiable individual.
Please read this Policy carefully. If you do not agree with this Policy, you should not access or use our website, Services or invest in our property(s). This Policy should be read in conjunction with the cookies “banner.”
We may modify this Policy from time to time. We will provide you with notice of any material changes to this Policy by publishing or communicating the changes through our website, or by other reasonable means, so that you may review the changes before continuing to use our Services. Your continued use of the Services after we publish or communicate a notice about any changes to this Policy means that you are consenting to the changes unless you expressly indicate otherwise.
Generally, we collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose – Why We Collect, Use and Disclose Information), and only when we have a legal basis to do so. In most cases, we will collect personal information directly from you when you interact with us with respect to our website, Services, properties, investments or investment opportunities, or any other product or service that we offer. As a general rule, we collect personal information directly from you. However, in some cases, we may collect personal information from a third party including but not limited to your financial advisor, exempt market dealer, registered plan custodians, or affiliates. We will use all reasonable means to ensure that third parties who provide us with information about you have your consent, or are otherwise permitted by law to do so. Personal Information will always be collected using means that are fair and lawful. We will not knowingly collect or use personal information for which consent has not been provided, except where permitted or required by applicable law or regulatory requirements.
Information collected in connection with the use of our Services includes: name, email address, residential address, and other identification and contact information such as telephone numbers; work contact details; social insurance number; social security number; passport information; tax identification numbers; bank statements; real estate holdings; credit reports; financial information; information regarding investments, subscriptions and other funds and amounts paid by you from time to time; business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you; and any other information that you may submit to us through the submission of a request for information, subscription application, or the use of our website.
Device Information: We collect certain non-identifying information related to a user’s use of our Services including the Internet Protocol (IP) address of the user’s computer or device, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed the Service, and the operating system that the user is using. We make no attempt to link this information with the identity of individuals. We may, however, review server logs and anonymous traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving web services, and to monitor and compile statistics about usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
Cookies: “Cookies” are small text files that are placed on your computer by websites that you visit. They are used to identify you to the web server, and will tell the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system. Session cookies expire when you close your browser. Persistent cookies remain on your device until they are deleted or expire. We may use cookies to determine and facilitate your access privileges on our website, to complete and support a current activity, to track website usage, and to generally improve your experience.
When you use our website a banner informs you of the use of cookies, seeks your express consent to their use, and provides a direct link to this information page. Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. If you decline cookies, you will still be able to use the website or the Services, but your ability to access certain features and functions may be affected. To find out more about cookies, including how to see what cookies have been set and how to manage and remove them, please visit AboutCookies.org or All_About_Cookies.org.
Google Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services, and to report on activities, trends and user behavior patterns. We do this to obtain an overview of how people are accessing and using the website, as well as to provide marketing services to you. Information that we use from Google Analytics includes: IP address; time per page; pages per session; bounce rate; device information; browser and operating systems; network; frequency of use; language; demographic; and geography. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners. You can opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Constant Contact: We use Constant Contact to provide online marketing services. They collect and provide us with certain log data, including your IP address, browser type and version, so that we can optimize our campaigns, customize offerings to you, understand your level of engagement with us, and generally increase our marketing reach. They may also set cookies and beacons on your browser. For information about Constant Contact’s practices, including information about cookies and refusing Image Web Beacons, please see: https://www.constantcontact.com/ca/legal/service-provider.
Social Media Widgets. The Services may include social media features including without limitation to the Facebook “like” button and widgets, such a “share this” button, as well as various connection features though our LinkedIn page. These features may collect your personal information, track your use of the Services, collect your IP address, provide a means for third parties to view certain information about you and to contact you directly, and may set cookies to enable the features to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the third party providing it.
We do not track visitors to our website across third party websites to provide targeted advertising and, therefore, our websites do not respond to Do Not Track (DNT) signals. We do not support Do Not Track browser settings and do not currently participate in any Do Not Track frameworks that would allow any of our websites to respond to signals or other mechanisms from you regarding the collection of your Personal Information.
We will identify the purposes for which we collect personal information before or at the time we request the information. We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes, but only when there is a legal basis to do so. The business purposes for which information may be used include:
• to evaluate and process your application to subscribe to our investments opportunities;
• to authenticate your identity;
• to manage your investment;
• to enable you to access, participate in and/or use the Services (see: What Information is Collected and How);
• to improve the business, internal programs and operations of our corporate group;
• to process, track and communicate with you about usage of the Services, including your participation in our investment opportunities;
• to establish, maintain and manage business relations with you so that we may provide you with the information, products or services that you request;
• to administer or otherwise carry out our obligations in relation to any agreement you have with us;
• internal business purposes, such as administering or improving the Services and managing our business and investments;
• to perform internal market research; to conduct polls, surveys and promotional activities;, and for statistical purposes;
• to obtain feedback regarding the Services and our ability to address the needs of our investors and other interested parties;
• to alert you to updated information and other services from us, or third-parties, or to forward promotional materials to you, where you have consented to receive such information;
• to provide our investors and potential investors with information and promotional materials regarding WWC and WWC’s properties, investment opportunities and services, and to otherwise administer the relationship between our investors and ourselves;
• to customize and optimize our websites so as to better serve the needs of our investors and potential investors;
• to protect us against error, fraud, theft or damage to our business or our property, including our financial interests;
• to collect debts owed to us;
• to manage or transfer our assets or liabilities, such as in the case of an acquisition or merger, or refinancing;
• to comply with any legal, accounting and regulatory requirements, including reporting requirements and other requirements imposed by securities commissions and stock exchanges, applicable laws, and any search warrants, subpoenas or court orders; and
• any other reasonable purpose for which you provide consent.
Where Personal Information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.
We will only process your personal information where we have a legal basis to do so. The legal basis will depend upon the reason or reasons that we collected and require the use of your information. The legal bases upon which we will use your information will generally be one of the following:
• The performance of the contract that we have with you, including for the purpose of allowing you to investigate and invest in our investments, and otherwise access and use our Services.
• Our legitimate interests, such as providing you with investment information, emails and newsletters; to enhance your business experience when interacting with us; to improve and promote our services and investments; and for administrative, financing, fraud detection, debt collection and legal purposes.
• To comply with legal obligations.
• To protect your vital interests, or those of another natural person.
• Because you have consented to our use of your personal information for particular purposes, such as the creation of an investment account in order to access our investment opportunities, and to manage those investments. You may withdraw your consent at any time by contacting the Privacy Officer at the address set out in this Policy (see: Accountability and Openness / Compliance)
Your personal information is never sold and, except as specifically provided in this Policy or permitted by law, will not be shared with third parties unless we provide you with both prior notice and choice.
You acknowledge that, in the course of providing the Services to you, we may delegate our authority to collect, use or disclose your information to third party subcontractors. Third party subcontractors may include, without limitation, web hosts; investors’ portal services; payment or other data processors; credit verification services; banks and other financial institutions; file sharing and storage services; delivery and logistics providers; and legal, financial and human resources advisors. If we transfer any personal information to a third party subcontractor, we will provide the subcontractors only with the information needed to perform the subcontracted service, and will use appropriate contractual means to provide a comparable level of protection while the information is being used or processed by them. Without limitation, we will ensure that our third party subcontractors are bound to adhere to this policy, appropriate confidentiality provisions and all applicable laws. Details regarding the personal information that we make available to our third party contractors, and how it is used, is available by contacting the Privacy Officer at the address set out in this Policy (see: Accountability and Openness / Compliance). Any request made by you to correct, change or erase your personal information will be promptly communicated to any third party subcontractors in possession of that information. We may disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based on our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to protect our business or assets, other users of the Services, or the public.
Certain of our subsidiaries, affiliates, services providers and other parties with whom we share information under this Privacy Policy may perform activities outside of Canada or the United States. As a result, your personal information may be collected, used, processed, stored or disclosed in another jurisdiction. In such cases, your information may be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.
Subject to certain restrictions and unless prohibited by law, WWC may also use and disclose your personal information without your knowledge or consent where necessary in connection with a proposed or completed business transaction. “Business transaction” includes those transactions described in the Personal Information Protection and Electronic Documents Act, S.C. 200, c. 5, as amended. In each such case, WWC and the other part(ies) to the transaction or proposed transaction will enter into an agreement limiting the purposes for which the personal information may be used and disclosed, ensuring its protection by means appropriate to the sensitivity of the information, and providing for the return or destruction of the information if the transaction does not proceed, or if the transaction does proceed, to notify you within a reasonable time that your personal information has been disclosed.
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us using the methods described in this Policy.
We have implemented reasonable physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive personal information. We use user IDs, passwords, and encryption technology; secure websites; store personal information in secure electronic folders; and restrict the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by using our Services, and/or communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.
WWC has a responsibility to ensure that all personal information contained in our records or which is disclosed to third parties for the purposes described in this Policy is accurate, complete and up-to-date. You may make a request in writing for access to your personal information by contacting the Privacy Officer at the address set out in this Policy (see: Accountability and Openness / Compliance). You may also request that any personal information in our possession be transferred to yourself or to another data controller. Including “Request personal information” in the subject line of your email will facilitate compliance with your request to access or transfer your information. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed.
Your right to access your Personal Information that we maintain is not absolute. 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. In some circumstances we may not agree with your request to change your Personal Information and will instead append an alternative text to the record in question.
If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, or if your personal information changes. Except as provided by applicable law, you have the right to require that we erase any of your personal information without undue delay, particularly in cases where the information is no longer required by us, you no longer consent to our use of your personal information, or if our use was in violation of this Policy or applicable law. You acknowledge that the erasure of your information may affect our ability to provide the Services to you. All notices and requests regarding inaccuracies, changes or erasure should be in writing and sent to the Privacy Officer at the addresses set out in this Policy (see: Accountability and Openness / Compliance).
You acknowledge and agree that your personal information may be transmitted, transferred, processed, and/or stored outside of Canada, including in the United States. We will use reasonable means to ensure that your information is protected, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada or the United States. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada or the United States.
The Services may contain optional links to third party Internet websites and services. You acknowledge that these third parties may collect data from users or their computers. The accessing and use of third party websites or services is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites or services, including with respect to their collection, use or disclosure or your personal information. This Policy applies only to the WWC Services, and we encourage you to review the privacy policies of any third parties when using their websites or services.
You agree that your access to and use of the WWC Services and websites, and this Policy, are governed exclusively by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles). You attorn to the exclusive jurisdiction of the courts of British Columbia for all matters arising under or in connection with this Policy, your use of WWC websites, and the Services. In case of any inconsistency between this Policy, and applicable law, applicable law shall prevail and this Policy shall be interpreted so as to apply only to the extent permitted by law.
WWC is responsible for personal information under our control. We have established policies and procedures to effectively safeguard any confidential personal information that we have on file or which we collect, and to deal with complaints and inquiries. We only collect Personal Information when it is voluntarily submitted by you through the use of our Services, and we are committed to maintaining the accuracy, confidentiality and security of your Personal Information. We will ensure that you have access to information regarding the policies and procedures that we use to manage your Personal Information.
WWC has designated a chief privacy and data protection officer (“Privacy Officer”) who is accountable for the protection of data containing personal information and for our compliance with this Policy generally, as well as for ensuring that information about our policies and practices relating to the management of Personal Information is easily accessible. All questions or concerns regarding this Policy, and our compliance with it, must be directed to the Privacy Officer by mail to: Privacy Officer at Western Wealth Capital, 201 – 2400 Dollarton Highway, North Vancouver, BC V7H 0B3 or by email to privacy@westernwealthcapital.com.
Every complaint or challenge regarding our compliance with this Policy will be investigated and, where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user.
You have the right to contact the relevant regulatory or data protection authority should you have concerns regarding our compliance with applicable privacy regulations. Please refer to the website of your local regulatory or data protection authority in order to obtain their contact information.
In the event of a security breach concerning personal information, we will notify affected individuals within 72 hours of discovering the breach. In any event, if a breach is likely to affect the rights and freedoms of the affected individual, we will ensure that the notification is made without undue delay.
Except as expressly provided in this Policy or as otherwise permitted by law, consent is required for the collection of Personal Information and the subsequent use or disclosure of that information. Consent may be express or implied, except in the case of sensitive personal information – such as information about race, ethnicity, religion, health, or sexuality – in which case consent must always be explicit. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time. For consent to be meaningful, it must be specific, informed, unambiguous and freely given. Consent will only be valid if it is reasonable to expect that the individual understands the nature, purpose and consequences of the collection, use or disclosure of the personal information to which they are consenting. Typically, consent will be sought for the use or disclosure of your personal information at the time of collection, and reasonable efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed. In certain circumstances, consent regarding use or disclosure may be sought after the information has been collected, but before use, such as when we wish to use personal information already in our possession for a purpose that was not previously identified. We try to limit the circumstances under which we collect and process sensitive personal information.
By voluntarily submitting your personal information or otherwise using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal information in accordance with this Policy. You may make inquiries, or change or withdraw your consent to the collection, use and/or disclosure of your personal information at any time by contacting the Privacy Officer in writing at either of the addresses listed in this Policy (see: Accountability and Openness / Compliance). In some circumstances, particularly where our use of your information is integral to the provision of a Service, a change or withdrawal of consent may affect your ability to use and/or our ability to provide you with certain information, products or services. In case of personal information disclosed in connection with an investment or potential investment, withdrawal of consent to use your personal information may result in financing, investment opportunities and/or other Services becoming unavailable, and/or our inability to provide you with information, updates and other communications regarding your investments or other interactions with us.
Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media. You may request the erasure of your personal information at any time which, subject to our need to invoke any exceptions permitted under applicable law, we will endeavor to do without undue delay as required by applicable law. Written requests should be sent to the Privacy Officer at the address set out in this Policy (see: Accountability and Openness / Compliance).
We do not intend our websites to collect personal information from children under the age of 13 or from persons under the age of majority as defined in your jurisdiction (“Minors”). Minors are not eligible to use the Services or to invest in WWC offerings, and we request that Minors do not submit any personal information to us. If you are under the age of majority in your jurisdiction, you may only use the Services in conjunction with and under the supervision of a parent or guardian. WWC does not knowingly collect personal information from Minors without parental consent.
BY ACCESSING OR USING THE WEBSITE, YOU DECLARE YOU ARE OF LEGAL AGE TO AGREE TO THIS PRIVACY POLICY OR, IF YOU ARE NOT OF LEGAL AGE, THAT YOU HAVE OBTAINED PARENTAL/LEGAL GUARDIAN CONSENT TO DO SO.