Amalgamated Capital Corp. is a privately held investment corporation incorporated under the laws of the Province of Alberta on February 27, 2013 to conduct business as a diversified investment corporation focused on, but not limited to, investing in early stage, high growth companies offering capital appreciation potential. The Corporation’s investments may include the acquisition of equity, debt or other securities of publicly traded or private companies or other entities, financing in exchange for pre-determined royalties or distributions and the acquisition of all or part of one or more businesses, portfolios or other assets, in each case that the Corporation believes will enhance value for the shareholders of the Corporation in the long term.
The registered office of the Corporation is located at #12, 3620 - 29th Street NE Calgary, Alberta Canada T1Y 5Z8
E-mail: info@amalgamatedcapitalcorp.com
Phone: 1.866-266-3301
The Corporation’s initial term objectives are to: (i) identify investment opportunities in accordance with the objectives set out in the company’s Investment Policy and (ii) obtain a listing of its Shares and Warrants on a Canadian Public Exchange.
The Corporation has a knowledgeable and actively managed venture capital and merchant bank business operational team incorporating 25 plus years of seed financing and investing in early stage or underdeveloped venture companies. This vast professional experience and network held by the management and board members, brings early and informative access to private and public business operations which when combined with a wide range of capital expenditure programs our “due diligence” review process is capable of selecting only those opportunities that present the best potential returns.
In order to provide holders of Common Shares (the "Shareholders") long-term sustainable growth and capital appreciation the Corporation will seek to achieve its investment objectives and will concentrate its strategic pursuit through an actively managed portfolio (the "Portfolio") of corporate developed investments, joint ventures, and acquisitions of public and private companies. Such investee companies may be private or public companies and there will be no bias to sector and will be selected. based on economic, financial and market conditions. The Corporation expects its investments will include companies based and operating nationally across Canada and internationally.
The Corporation has adopted an Investment Policy to govern its investment activities. The Investment Policy sets out, among other things, the investment objectives and strategy of the Company based on certain fundamental principles.
SEE INVESTMENT POLICY SECTION
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Investment Objective
Amalgamated Capital Corp. (the “Corporation”) is an investment Corporation that carries on business with the objective of enhancing shareholder value. The Corporation will seek to accomplish this objective by making use of the experience, expertise and opportunity flow of its management and board of directors (“Board”) to opportunistically make investments in situations that the Corporation believes will provide superior returns, primarily nationally in Canada and selected business sectors internationally. Such investments may include the acquisition of equity, debt or other securities of publicly traded or private companies or other entities, financing in exchange for pre-determined royalties or distributions and the acquisition of all or part of one or more businesses, portfolios or other assets, in each case that the Corporation believes will enhance value for the shareholders of the Corporation in the long term.
While the Corporation does not anticipate the declaration of dividends to shareholders during its initial stages and plans to reinvest any profits of its investments to further the growth and development of the Corporation’s investment portfolio, its' management and board in certain circumstances, related to certain Funding Agreements and related to potential investee opportunities may include the issuance of dividends to shareholders specific to a specific Funding Agreement.
Investment Strategy
The following will be the guidelines for the Corporation’s investment strategy:
• The Corporation may invest in securities of both public and private companies or other entities that the Corporation believes have the potential for superior investment returns. The Corporation may provide financing of a private or public Corporation in exchange for pre-determined royalties or distributions (“royalty securities”), and also acquire all or part of one or more businesses, portfolios or other assets, in each case that the Corporation believes will enhance value for the shareholders of the Corporation.
• The Corporation will invest opportunistically in business operations, with a preference for securities in equity, equity related securities and royalty securities. The Corporation may also invest in a wide range of other instruments including, without limitation, preferred shares, warrants, convertible debentures, secured or unsecured debt, and bridge financing or other short-term capital.
• The Corporation will not be precluded from investing in any particular industry. The Corporation’s management and Board have experience and expertise in a wide range of industry sectors and will pursue opportunities in those sectors that the Corporation believes from time to time offer the best opportunities for the creation of enhanced value for the Corporation’s shareholders. Similarly, there are no restrictions on the size or market capitalization of companies or other entities in which the Corporation may invest, subject to the provisions hereof.
• The Corporation has no specific policy with respect to investment diversification. Each investment will be assessed on its own merits and based upon its potential to generate above market gains for the Corporation.
• Immediate liquidity will not be a requirement of any investment, but each investment will be evaluated in terms of a clear exit strategy.
• The Corporation will invest with a preference for opportunities in Canada and internationally, particularly the United States of America, but may from time to time also pursue opportunities elsewhere.
• In general, the investment activities of the Corporation are expected to be passive. However, the Corporation may, from time to time and in appropriate circumstances, seek a more active role in regard to investment situations and investee companies where the involvement of the Corporation is expected to make a significant difference to the success of the Corporation’s investment. In appropriate circumstances, this may involve the Corporation, either alone or jointly with other shareholders, seeking to influence the governance of public or private issuers by seeking board seats, launching proxy contests or taking other actions to enhance shareholder value, or becoming actively involved in the management or board oversight of investee companies.
• The Corporation may also make investments in special situations, including event-driven situations such as corporate restructurings, mergers, spin offs, friendly or hostile take-overs, bankruptcies or leveraged buyouts. Such special situations may include, without limitation, investments in one or more public companies, by take-over bid or otherwise, where there is an opportunity to invest to gain control over the strategic direction of such public companies, whether using the shares of the Corporation as currency or otherwise. Such situations may also involve the Corporation lending money, directly or indirectly.
• Depending upon market conditions and applicable laws, the Corporation may seek to sell any or all of its investments when it concludes that those investments no longer offer the potential to generate appropriate gains for the Corporation, or when other investment opportunities reasonably available to the Corporation are expected to offer superior returns. This may include the disposition of any or all of the Corporation’s investments in a particular sector or of a particular nature, or any or all of the Corporation’s investments more generally, without prior notice to the Corporation’s shareholders.
• Subject to applicable laws and regulatory requirements, the Corporation may also from time to time seek to utilize its capital to repurchase shares of the Corporation.
• The Corporation may, from time to time, use borrowed funds to purchase or make investments or to fund working capital requirements, or may make investments jointly with third parties.
• Depending upon the Corporation’s assessment of market conditions and investment opportunities, the Corporation may, from time to time, be fully invested, partially invested or entirely uninvested such that the Corporation is holding only cash or cash-equivalent balances while the Corporation actively seeks to redeploy such cash or cash-equivalent balances in suitable investment opportunities. Funds that are not invested or expected to be invested in the near-term, while the Corporation actively seeks to redeploy such funds in one or more suitable investment opportunities, may, from time to time as appropriate, be placed into high quality money market investments, each with a term to maturity of less than one year.
• All investments will be made in compliance with applicable laws in relevant jurisdictions and will be made in accordance with the rules and policies of any applicable regulatory authorities.
From time to time, the Board may authorize such additional or other investments outside of the guidelines described herein as it sees fit for the benefit of the Corporation and its shareholders.
Implementation
The management and Board will work jointly to uncover appropriate investment opportunities that meet the Corporation’s investment strategy as outlined above and the Corporation’s objective of enhancing shareholder value. These individuals have a broad range of business and investing experience and networks through which potential investments are expected to be identified.
Prospective investments will be channeled through an advisory committee, which may include members of management, the Board and external advisers (the “Advisory Committee”). The Advisory Committee will make an assessment of whether the proposal fits with the investment and corporate strategy of the Corporation in accordance with the investment evaluation process below, and then proceed with preliminary due diligence, leading to a decision to reject or move the proposal to the next stage of detailed due diligence.
This process may involve the participation of outside professional consultants. Once a decision has been reached to invest in a particular situation, a short summary of the rationale behind the investment decision should be prepared by the Advisory Committee and submitted to the Board. This summary should include guidelines against which future progress can be measured. The summary should also highlight any finder’s or agent’s fees payable.
All investments will be submitted to the Board for final approval. The Advisory Committee will select all investments for submission to the Board and monitor the Corporation’s investment portfolio on an ongoing basis and will be subject to the direction of the Board. One or more members of the Advisory Committee may be designated and authorized to handle the day-to-day trading decisions in keeping with the directions of the Board and the Advisory Committee.
Negotiation of terms of participation is a key determinant of the ultimate value of any opportunity to the Corporation. Negotiations may be on-going before and after the performance of due diligence. The representative(s) of the Corporation involved in these negotiations will be determined in each case by the circumstances.
Investment Evaluation Process
In selecting securities for the investment portfolio of the Corporation, the Advisory Committee will consider various factors in relation to any particular issuer, including:
• inherent value of its assets;
• proven management, clearly defined management objectives and strong technical and professional support;
• future capital requirements to develop the full potential of its business and the expected ability to raise the necessary capital;
• anticipated rate of return and the level of risk;
• financial performance; and
• exit strategies and criteria.
Conflicts of Interest
The Corporation has no restrictions with respect to investing in companies or other entities in which a member of the Corporation’s management or Board may already have an interest or involvement. However, prior to the Corporation making an investment, all members of senior management and the Board will be obligated to disclose any such other interest or involvement. In the event that a conflict is determined to exist, the Corporation may only proceed after receiving approval from disinterested members of the Board.
The Corporation is also subject to the requirements of Multilateral Instrument 61-101 – Protection of Minority Security-holders in Special Transactions, which mandates minority shareholder approval for certain transactions.
The management and directors of the Corporation may be involved in other activities which may on occasion cause a conflict of interest with his or her duties to the Corporation. These include serving as directors, officers, promoters, advisors or agents of other public and private companies, including of companies in which the Corporation may invest, or being shareholders or having an involvement or financial interest in one or more shareholders of existing or prospective investee companies of the Corporation. The management and directors of the Corporation may also engage from time to time in transactions with the Corporation where any one or more of such persons is acting in his or her capacity as financial or other adviser, broker, intermediary, principal or counter party.
The management and directors of the Corporation are aware of the existence of laws governing the accountability of directors and officers for corporate opportunities and requiring disclosure of conflicts of interest, and the Corporation will rely upon such laws in respect of any conflict of interest. Further, to the extent that management or directors of the Corporation engage in any transactions with the Corporation, such transactions will be carried out on customary and arm’s-length commercial terms.
Monitoring and Reporting
The Corporation’s Chief Financial Officer will be primarily responsible for the reporting process whereby the performance of each of the Corporation’s investments is monitored. Quarterly financial and other progress reports will be gathered from each corporate entity, and these will form the basis for a quarterly review of the Corporation’s investment portfolio by the Advisory Committee. Any deviations from expectation are to be investigated by the Advisory Committee and, if deemed to be significant, reported to the Board.
With public Corporation investments, the Corporation is not likely to have any difficulty accessing financial information relevant to its investment. With private Corporation investments, it will endeavor in each case to obtain a contractual right to be provided with timely access to all books and records it considers necessary to monitor and protect its investment in such private enterprises.
A full report of the status and performance of the Corporation’s investments is to be prepared by the Advisory Committee and presented to the Board at the end of each fiscal year.
Amendment
This investment policy may be amended from time to time with the prior approval of the Board.
This privacy policy (this “Policy”) describes the practices of Amalgamated Capital Corp. and its corporate affiliates (“Amalgamated”, “we”, “us”, “our”) with respect to our collection, use, storage and disclosure of personal information provided to us from users of our website operated at https://amalgamated-capital.com related services, and other websites operated by us from time to time (collectively, the “Website”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
1. Introduction and General Concepts
We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information.
The Website is intended solely for Canadian users at least 18 years of age (or the age of majority in your jurisdiction) or older. We do not knowingly collect personal information about any person under the age of majority (usually the age of 18 or 19, but it varies in different jurisdictions), and no such person, nor any parent or guardian as it relates to such person, should submit their personal information to us for any reason. Please do not submit personal information about minors to us, whether through the Website or otherwise.
(a) Personal Information
For the purposes of this Policy, “personal information” means information about an identifiable individual, in other words meaning information that is, or can be, used (directly or indirectly by reference to other information) to identify a natural person. Personal information includes, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, as described below, or any information that is not regulated by Applicable Privacy Laws (defined below). We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us (“Applicable Privacy Laws”).
(b) Non-Personal Information – Outside of this Policy
On the other hand, “non-personal information” is any type of information other than personal information and is excluded from this Policy. For example, non-personal information would include business information, information that does not relate to an identifiable individual, or aggregate or anonymized information that eliminates the possibility of recovering underlying data about identifiable individuals. We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This Policy, however, only covers our collection, use and disclosure of personal information.
2. Collection and Use of Personal Information
As indicated above, we collect two types of information through our Website: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Website.
(a) Information we collect from you
We may collect the following personal information from you:
• contact information such as name, email address, mailing address, phone number;
• billing information such as credit card number, and billing address;
• unique identifiers such as user name, account number, password;
• user content generated by you, such as audio, video, text and images as provided by you on the Website, which may contain personal information as provided by you;
• the geo-location of your mobile or location-enabled device;
• preferences information such as request history and marketing preferences;
• any other information provided about you by the referrer through which you accessed the Website; and
• any information that you voluntarily enter, including personal information, into or through the Website.
(b) Information we automatically collect
We may also automatically gather information about your mobile device or computer (as applicable) such as your unique mobile device ID, device type, IP address, browser type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. Some of this may be personal information, but in typical cases it is non-personal information.
Specific examples follow:
• Device Identifier, etc.—When using our Website, we may collect the unique device identifier of your mobile device, the type of device, the date and time you access our Website, the operating system you are using, the sections of our Website that you visit, and information about how you use the Website including content downloaded or otherwise viewed. This information is used for Website and system administration purposes, and to improve the Website.
• Cookies—We may use “cookies”, a technology that installs a small amount of information on a user’s mobile device to permit the Website to recognize future visits using that mobile device. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to offer personalized content and information for your use, to track your activity on the Website, to respond to your needs, and to otherwise facilitate your Website experience. You may choose to decline cookies if your mobile device permits, but doing so may affect your use of the Website and your ability to access certain features of the Website or engage in transactions through the Website.
• Tracking Information—We may use software or other means to compile tracking information reports regarding Website user demographics, Website traffic patterns, Website purchases and other aggregated Website statistics, and the same may be used in our emails to determine which emails and links have been used by recipients. We may then provide these reports to advertisers and others. Once such a link is made between that information and other information that makes you identifiable, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy. We may use Google Analytics, which is a web analysis service provided by Google Inc. (“Google”). Google utilizes the personal information collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the personal information collected to contextualize and personalize the ads of its own advertising network, and you should visit Google’s website for information about its handling of your personal information.
• Geo-Location Information—When you use the Website, we track or collect your geo-location information via the geo-location functionality of your mobile device on a real time basis only to provide you with more accurate information on the Website. We may also use this real-time geo-location information to address support, technical, or business issues that may arise in the course of your use of the Website. If you do not consent to the tracking of your geo-location, you may still be able to use some features of the Website, but it is intended to be used with geo-location information. You may at any time opt out of the collection of geo-location data by uninstalling the application in accordance with the standard uninstall process made available via your mobile device or the mobile application marketplace or network.
We do not knowingly collect information about minors.
All personal information is kept for the time necessary to provide Website and/or the service requested by you, or stated by the purposes outlined in this Policy.
3. Use of Personal Information
We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:
• respond to customer service requests;
• respond to your questions and concerns;
• send you a confirmation, if applicable;
• send you requested information;
• administer your account, if applicable;
• send new product or service information;
• fulfill your request or order;
• carry out contests or promotions;
• send you marketing communications;
• improve our Website and other products and services;
• conduct research and analysis, including in our business but also in the use of our
Website;
• enforce our Terms of Use;
• display content based upon your interests;
• for distribution to our payment processor for the provision of payment services;
• facilitate your transactions with other users, as applicable; or
• for other purposes as described in this Policy, such as for disclosures permitted under Section 6 below.
4. Your Consent
We will collect, use, or disclose your personal information only with your knowledge and consent, or where we are permitted to do so by Applicable Privacy Laws, such as where we have a legitimate business purpose that allows us to do so. When you use the Website there may be an opportunity for you to provide us with your personal information, and if you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.
(a) Express Consent
Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada’s anti-spam laws, or where the use of the information requires your express consent.
(b) Implied Consent or Legitimate Business Purposes
Other times, you may provide your implied consent to our collection, use or disclosure of personal information, or we may have a legitimate business purpose permitted by Applicable Privacy Laws to do so, when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take in connection with the use of our Website or in connection with our business. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you use our services, or when provide us with your address through a form or email seeking information, you provide us with implied consent to use that address in order to respond to your request and we have a legitimate business interest to know and use it.
(c) Withdrawing Your Consent
You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your personal information. We will accommodate your request subject to legal and contractual restrictions. The most common way of indicating this withdrawal of consent is by (i) stopping use of the Website and uninstalling the Website in accordance with the standard uninstall process made available by your mobile device, (ii) changing your privacy preferences to the extent such functionality is made available through the Website, or (iii) deleting your account with the Website and stopping use of the Website. In other situations, you may be able to opt out of the use of your personal information. For example, if you have “opted in” or subscribed to one of our mailing lists, we will always provide you the opportunity to “opt out” or unsubscribe. For example, if you receive emails from us, we will provide a link in the email which you can use to unsubscribe from that mailing list, or you may contact our Privacy Officer as set out below.
You may also choose not to provide us with your personal information. However, if you make this choice, we may not be able to provide you with the Website, or information that you have requested.
5. Information Obtained from Third Parties
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and in accordance with this Policy and such policy under which that information was collected. If you believe someone has provided us with your personal information without your consent, please contact at info@amalgamatedcapital.com.
6. Disclosure and Sharing of Your Information
We will share your personal information with third parties only in the ways that are described in this Policy. We will not sell your personal information to third parties; however, the use of our Website necessarily requires some sharing or disclosure of your personal information. Some of these activities may result in personal information collected by us being stored or processed in the United States or elsewhere outside of Canada and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the laws of such jurisdictions.
(a) Third Party Processors
We may provide your personal information to companies that provide services to help us with the Website such as web hosting providers, payment processors, or customer service agencies or, as set out above, Google analytics (“Third Party Processors”). These Third-Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this Policy. We have selected Third Party Processors who will only use your information in compliance with this Policy, but they may have their own specific policies regarding the collection, use and personal information. We will use commercially reasonable efforts to identify such Third-Party Processors when we are collecting your personal information, as well as providing links to the relevant privacy policies that may apply.
(b) Further Disclosures – Affiliates, Legal Requirements, Safety, Acquisitions
We may also disclose your personal information (i) to our affiliates and subsidiaries, as they may be from time to time, in connection with the purposes set out in this Policy, (ii) as required by law such as to comply with a subpoena, or similar legal process, (iii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, (iv) to an acquirer of us or our business (provided that we have appropriate confidentiality obligations with such acquirer in place), or (iv) to any other third party with your prior consent to do so.
(c) Third Party Links
Our Website may contain links or other external references to other websites, applications, social media or Internet resources which are provided solely for your convenience and information. When you follow any linking mechanism to one of those resources you are contacting another party and not us. We have no responsibility or liability for, or control over, those other resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other resources to learn how they collect and use your personal information.
7. Risk of Harm and Security of Personal Information
Anytime you share personal information there is a risk that privacy may be breached, and such information may become public. Privacy breaches may lead to reputational harm, fraud and even identity theft. For this reason, it is important that you consider what personal information you are sharing and ensure that you are comfortable doing so.
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them. The safeguards that we have in place are appropriate to the sensitivity of the information.
When you enter sensitive information (such as credit card number or other sensitive personal information) on our online forms, we encrypt the transmission of that information using secure socket layer technology (SSL). SSL encrypts information entered on our site before it is sent over the Internet, and we use SSL in an industry-recognized standard manner to encrypt our Internet transmissions to and from you.
While we follow generally accepted industry standards to protect personal information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet. If you have any questions about the security of our Website. you can contact our Privacy Officer as set out below.
8. Requests for Access to and Correction of Personal Information
Applicable Privacy Laws allow, to varying degrees, individuals the right to access or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
• identification of personal information under our custody or control;
• information about how personal information under our control may be or has been used by us; and
• the names of any individuals and organizations to which the individual’s personal information has been disclosed.
We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.
In certain exceptional circumstances, we may not be able to provide access to certain personal information we hold about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
9. Removal of Your Information
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous. If you would like use to remove your personal information, please contact our Privacy Officer as set out below.
10. CASL Policy
We are committed to compliance with the law known as Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication sent by us to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message we send (a “CEM”), which is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting this Policy, and to provide transparency about our compliance, we have undertaken various initiatives in order to ensure we are compliant with CASL in various respects:
• Consent—We do not send CEMs without your consent. This consent typically must be “express” (or expressly acknowledged by you), but in certain circumstances, consent can be “implied” and in other messages are specifically exempt from consent requirements. We have modified or adopted our sign-up, registration and consent forms in order to ensure that the express consent obtained from you is in compliance with CASL. When we are collecting your electronic contact information, you will know what purposes we want to use it for.
• Content—We have adopted processes to ensure that our CEMs contain the prescribed content of CASL. On any CEM from us (usually in the footer), we will clearly:
- identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- provide you contact information where you can readily contact us; and
- set out a clear, working unsubscribe mechanism (or preference centre) that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
• Clarity—We have ensured that each constituent element of a CEM (including its header, its content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you have received a CEM from us, and you believe that you should not have or you do not wish to receive them (even if we are allowed to send them), we will endeavour to respect your inbox preferences. Without limiting our legal rights or obligations, we try to ensure that our messages all contain useful identity information and unsubscribe or preferences link—if you check the CEM itself, you will find clear instructions on how to stop receiving CEMs from us or manage your mail preferences. When you unsubscribe, it should happen very quickly – but as required by CASL we will make sure it occurs within 10 business days. If you have any questions or concerns about our unsubscribe methods, you may contact us at the address indicated below.
11. Updates or Changes to Privacy Policy
We may update this Policy to reflect changes to our information practices. If we make any material changes, we will endeavor to notify you (a) by email (sent to the e-mail address specified in your account), or (b) through the Website prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Any change to this Policy will become effective on the date so indicated and will apply to information collected from the date of the posting of the revised privacy policy and to existing information held by us. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this privacy policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website signifies your acceptance of any changes to this Policy.
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