Privacy policy

Last Updated February 2022

CP Capital (US) Partners LP (“CP Capital”, “Company”, “We”, “US”) respects your privacy and are committed to protecting it through our compliance with this policy and all applicable laws.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.cpcapitalus.com(our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.

When you interact with our applications on third-party websites and services, if those applications include links to this policy, It does not apply to information collected by:

• Us      offline or through any other means, including on any other website      operated by Company (including when you log into your account via our Investor      Portal).

• or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you may not use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified such as name, company, phone number, and e-mail address (“personal information”);
• That is about you but individually does not identify (whether directly or indirectly), you, such as the date and time you visited the Website; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

From time to time, it is necessary for you to supply us with personal information in connection with the provision of services that you may require us to provide from time to time or for us to comply with the laws, regulations or guidelines issued by regulatory or other authorities. Failure to supply such personal information may result in us being unable to provide such services or comply with any laws, regulations or guidelines issued by regulatory or other authorities.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through and interact with the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From third parties, for example, our business partners, including Google Analytics.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide to us if you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us (including via filling out information through our Contact Form).

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
• Information about your computer (or mobile phone) and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Third-Party Use of Cookies

Some content, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used and the use of your information by the third parties will be governed by the privacy policy of those third parties. Access to and use of such other third parties’ platforms is at your own risk and you are advised to review their privacy policies. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We may collect, use, disclose, process and storage the information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To comply with laws and regulations, court order or other legal process;
• For any other purpose when we have your consent.

We use online tracking technologies (i.e., cookies) to engage in data analytics, research, reporting, and debugging on our Website. For example, we use Google Analytics for such purposes.

Disclosure of Your Information

We may disclose aggregated information about our users and information that does not, and cannot be used to, identify any individual without restriction.

We may disclose personal information that we collect, or you provide to satisfy the purpose as set forth in the above section (How We Use Your Information) as described in this privacy policy to the following parties:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business to the extent necessary for the purposes for which the personal information was provided.

In all cases where we share your personal information with a third party and to the extent permitted by law, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use .
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CP Capital, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CP Capital’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CP Capital about our Website users is among the assets transferred.
• When we have your consent.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Our employees have access to your personal information only on a strict need-to-know basis and are required to keep such personal information confidential and use it only for the purposes for which it was provided.

Where we use contractors or service providers who might have access to your personal information in order to perform their services to us, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our contractors and service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any other purpose.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Transfers

Our servers are either located in the United States or, if located in other jurisdictions, may be accessed from the United States. Please note that in jurisdictions outside your own jurisdictions, and in particular outside the EU, EEA, Mainland China, Hong Kong and UK, standards of data protection might apply which are different from those which apply in your own jurisdiction.

By sharing Personal Information with us, including via our website, you acknowledge and consent that your data may be transferred across national borders.

Accuracy and Retention of Personal Information

We do our best to keep your personal information accurate and up to date, to the extent that you provide us with the information we need to do so. If your personal information changes (for example, if you have a new email address) or is inaccurate, you are responsible for notifying us of those changes by email at clientservice@cpcapitalus.com.

We will retain your information for as long as needed to provide you with our services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes and enforce our agreements.

Your Rights in relation to your Personal Information

Depending on where you live, including if you are resident in Canada, the EU, UK, Mainland China or HK, you have a number of rights in relation to your personal information, including the right to:

• Be informed about how we use your personal information
• Obtain access to your personal information that we hold
• Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
• Request that we erase your personal information where:

o    We process your personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected

o    If we rely on consent as the legal basis for processing and you withdraw consent

o    If we rely on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing

o    If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)

o    If it is necessary to delete the personal information to comply with a legal obligation

• You may ask us to restrict our data processing activities where you consider that:

o    Your personal information is inaccurate

o    our processing of your personal information is unlawful

o    where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim

o    where you have raised an objection to our use of your personal information.

• You may request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information;
• You may object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
• You have the right not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of these rights, please contact us using the details below.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address you have provided to us or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, including our use of service providers outside your jurisdiction of residence, contact us at:

clientservice@cpcapitalus.com.