Privacy Notice – New
Last updated on: June 14, 2016
Aileron Capital Inc. as Financial Services Agent of the Beacon Trust Note Issuer, appreciates your interest in the use of the beaconconsumerholdings.com website.
Our Commitment to You
At Aileron Capital Inc. (“ACI”) we are committed to keeping your personal information accurate, secure, confidential and private. Your privacy is important and we want you to understand our practices on gathering information from visitors to https://beaconconsumerholdings.com (the “Website”) and the uses we make of that information. This Privacy Notice outlines how we collect, protect, use and disclose your personal information and your rights to access your information.
BY USING THE WEBSITE, YOU AGREE TO BE BOUND BY THE ACI PRIVACY NOTICE. IF YOU DO NOT AGREE WITH THE PRIVACY NOTICE, YOU MUST DISCONTINUE ALL USE OF THE WEBSITE IMMEDIATELY.
Please note that ACI reserves the right to modify the policies contained in this Privacy Notice at any time. Whenever we modify this Privacy Notice, we will notify you by posting the new version on our Website. We invite you to periodically consult this Privacy Notice for possible updates and changes.
Notice to All Users of the Website
Anonymous Browsing and Use of the Website
Visitors to our website, who are not Investors, may browse the website anonymously. Below, we describe the types of data that we collect from all our website visitors and the purpose of such collection.
- Information and Uses – when someone visits the Website, our web servers automatically gather information that allows the Website to communicate with the visitor’s computer during the visit. We also track the number of visits to the Website and which parts of the Website visitors select. We use that information for statistical purposes that help us improve and administer the Website. That information does not include personal information that would permit us to identify or locate individual visitors.
- IP Address – ACI employs software programs that monitor network traffic. These programs record the Internet Protocol (“IP”) addresses of computers that visit the Website. They also record the date and time of visits, the pages viewed, and the browsers and operating systems used by visitors. We do not attempt to link this information to the identities of individual users. Hyperlinks – The Website has links to third party websites that ACI does not own or maintain. Links to other websites or other resources which are not created or controlled by ACI (“Linked Sites“) are intended for convenience only. Linked Sites are wholly independent from ACI therefore ACI has no control over any products, services, materials, or other information contained in or available through these third party websites. We make no representations or warranties about the privacy practices of those websites. Therefore, access to any third party websites through the Website, regardless of whether the third party website is a Linked Site or not, is entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive devices, programs. ACI makes no representation or warranty regarding, nor endorses, any Linked Sites or the information appearing thereon or any of the products or services described thereon.
- Cookies, Web beacons and related technologies – Portions of the Website use statistical tools that may be operated by third party providers (collectively, the “Analytical Tools”). The Analytical Tools may use “cookies” and/or web beacons. A cookie is a small piece of information that a website transfers to the hard drive of a visitor’s computer for record-keeping purposes. A web beacon, also known as a “clear GIF” (a common format for image files), is an invisible file located on web pages that you visit. They are often used in combination with a cookie to track navigation of a website. If you visit a page on the Website that contains a web beacon, it communicates with your computer to determine, among other things, whether you have been to that page before or viewed a particular advertisement.
A cookie is used to help a website distinguish a user’s browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing that website. Cookies can also be used to collect information about how websites are used and help to manage online advertising by enabling us to understand which ads bring users to our website and tailor offers on this and other websites on which we advertise.
Cookies do not contain information that identifies you personally. A cookie cannot retrieve any other data from your hard drive, pass on computer viruses or capture your e-mail address or other personal information. Some of the Analytical Tools may use both session cookies and permanent cookies in connection with the Website.
Notice to Investors Using the Website
Those website visitors who chose to view the Beacon Consumer Holdings Inc. monthly reports through this website must provide us with certain personal information in order to help us identify you when accessing the login to the secure site. Such users will no longer be anonymous to us. The information below describes the kinds of personal information that we collect from “Investors” and the purposes for such collection.
Terms Used in this Notice
- Investor– an approved party to the securitization agreements or an individual who has made an investment in Beacon Consumer Holdings Inc. Asset-Backed Notes.
- When we refer to “ACI”, “we”, “our” or “us”, it encompasses all affiliates within the Aileron Group of Companies. If we make reference to sharing information within the Group of Companies, it means disclosure by one member of the group to some or all of the others.
- Third Party Service Provider – an ACI approved partner who provides services on behalf of Beacon Consumer Holdings Inc. or another member of ACI.
- Third Party Network Administrator – an ACI approved partner who provides services to the website of Beacon Consumer Holdings Inc. or another member of ACI.
- Permitted or required by applicable laws and legal and regulatory requirements – this includes law, regulation, rules or requests in general investor compliance.
- Personal information – information about an identifiable individual that you submitted as part of your investment subscription agreement. Personal Information collected through this website from Investors includes only name, email address and phone number.
The following are ACI’s governing Privacy Notice principles:
- Accountability – we are accountable for any personal information we receive and also that we disclose to our Third Party Service Providers. The Data Protection Office is a member of our management team and their responsibilities include compliance with privacy governance, dispute resolution, education and communication activities.
- Identifying the purpose of collecting personal information – reasons for the collection of personal information include:
- to provide you with secure online access to Beacon Consumer Holdings Inc. monthly reports
- to protect both of us from error and fraud
- to offer additional financial products that may benefit you
- to provide ongoing services
- to comply with federal and provincial legal and regulatory requirements
- Obtaining consent – we obtain your express or implied consent when you visit the Website and before or when we collect, use or disclose your personal information, except where permitted or required by applicable laws. In particular, if you are an Investor or Trustee, then by consenting to this Notice, you are accepting our collection of your Personal Information for the purposes identified above. Should a new purpose arise, we will ask for your consent. Subject to legal or contractual restrictions, you may withdraw your consent at any time as long as you provide reasonable notice. The withdrawal of consent does not preclude you from fulfilling contractual obligations.
- Limit the collection of personal information – the collection of personal information is limited to that which is required by law or for our identified purposes.
- Limit the use, disclosure and retention of personal information – we will only use or disclose your personal information for the reason(s) it was collected, unless you provide ACI with consent to use or disclose for another reason or unless we have a regulatory duty or right to disclose personal information without consent.
We may disclose your Personal Information on a need‑to‑know basis to Third Party Service Providers that provide services on our behalf. For example, Olympia Trust will be provided with Personal Information including your name, address and social insurance number. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose. We may disclose your Personal Information in the context of certain business transactions, such as the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving ACI. Finally, we may also disclose your Personal Information where otherwise required or authorized by law.
We will keep your personal information only for as long as it fulfills its intended purpose or as legally required. Moreover, as explained in the Opt out/modify information section, you may request that we remove your personal information from our records so you will not receive future communications from us.
- Keep personal information accurate – we are committed to keeping your personal information as accurate and as complete as possible. Please notify us immediately if your personal information changes so that our systems can be updated. We will update personal information only if it is necessary for the purpose for which it was originally collected. Please see Response to concerns to address any issues regarding the accuracy or completeness of your personal information.
- Use appropriate safeguards – we have secure systems and controls in place to safeguard your personal information and protect our systems. Examples include limiting the access of personal information to employees or Third Party Service Providers on a “need to know” basis and only when they have been authorized to access the information. We ensure any Third Party Service Provider has executed an agreement with us that governs the use of any personal information that they may obtain from us.
- Transparency – we are open as to how we manage your personal information. Our Privacy Notice outlines why we ask for your personal information and who we may share or disclose it with. Please see Response to concerns should you need to report a concern.
- Individual access – should you wish to review or verify your personal information that we have in our possession or to find out what it has been used for or whom it has been disclosed to, please contact us at privacy@AileronCapitalInc.com. There will be no charge for us to provide this information. There may be instances when we are unable to provide you with some of the information we hold about you, in which case, we will let you know the reasons why. We will need to authenticate the identity of the requestor, for example by copy of driver’s license. In most provinces you have the right to access and verify the personal information held about you by credit bureaus. Upon your request, we will provide you with the name and location of any credit bureau that has provided us with a report on you.
- Opt out/modify information – by contacting privacy@AileronCapitalInc.com, you may remove your personal information so you will not receive future communications, or you may modify your personal information that we have previously gathered. We will update personal information only if it is necessary for the purpose for which it was originally collected. Please see Response to concerns to address any issues regarding the accuracy or completeness of your personal information.
- Response to concerns – to the extent, a perceived violation or issue of non compliance has been found, it should be immediately addressed to the Data Protection Office at privacy@AileronCapitalInc.com. ACI will log the issue, notify internal personnel and if necessary, report to the appropriate Provincial Consumer Services branch (i.e. Ministry of Consumer Services – Consumer Protection Branch). ACI will address such issue with utmost confidentiality and urgency.
Helpful tips on protecting your information
- Username selection – your Username is what other Third Party Service Providers use to identify you. In order to protect your privacy, you should choose a Username that does not resemble your real name.
- Password reminder – it is a good practice to select a password for your account that is unique, a combination of letters, numbers and symbols, and isn’t predictable or easy to guess. For instance, “Rocky” may be your pet’s name and easy to remember, but “!Rocky2” would be difficult for someone to guess. Another good practice is to change your password periodically (e.g. every 90 days).
- Communications – if you post any communications on the Website, you should be aware that any personally identifiable information you submit may be read, collected, or used by other Third Party Service Providers and could be used to send you unsolicited messages. We do not monitor or mask personally identifiable information that may appear in communications you post, so if you choose to include personal information you do so at your own risk.
Note Regarding Children under the Age of Majority
In order to use the ACI Website you must have reached the age of majority in the province in which you are normally resident. Persons under the age or majority are not eligible to participate in Beacon Consumer Holdings Inc. offerings.
This Privacy Notice is drafted to help ensure compliance with the federal Personal Information Protection and Electronics Documentation Act (PIPEDA) and the CSA Model Code for the Protection of Personal Information. You may have additional privacy rights under applicable provincial law in addition to those outlined in this Privacy Notice.
The individual at ACI that is responsible for this Privacy Notice and the information governed under it is through the Data Protection Office. The Data Protection Office may be contacted at:
Data Protection Office