Intent

PIRET Management LP and its affiliates, doing business as, Pure Industrial (“Pure”, the “Company”, “we” or “us”) takes steps intended to meet privacy principles and requirements with respect to personal information under applicable privacy legislation. This Privacy Policy (the “Policy”) applies to products and services offered by Pure (the “Products and Services”), the use of Pure website (the “Site”) and in the context of recruitment either through our internal channels or through online recruitment platforms. Pure cares about your privacy and is committed to protecting it by adhering to the Policy.

This Policy describes how we collect, use, store and disclose your personal information and how your personal information can be accessed, rectified, and deleted when necessary. Your continued use of the Site, Products and Services means you agree to our Policy, so please take a few minutes to read and understand it. 

By using our Products and Services you   consent to the collection, use and disclosure of your personal information in accordance with this Policy.

How we Collect Information

Personal information includes any information about an identifiable individual.

We use different methods to collect information from and about you including through:

• Information you give us. This is information that you consent to giving us about you by accessing our Site and/or Products and Services, by corresponding with us (for example by email), or by applying for a position at Pure. It includes information when you purchase our Products and Services, and when you contact us through our Site. If you contact us, we will keep a record of that correspondence.  

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate certain of your usage data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.  

Type of Personal Information Collected and Purposes

In order to deliver our Products and Services, we may request that you provide certain personal information. We only collect personal information that is necessary to provide you with our different Products and Services. Where possible, we indicate which fields are required and which fields are optional.

• If you wish to use our Products and Services, we may collect your name, business email address, phone number, and other information about your company. Information from your account will be used to facilitate the Product and Services you request. Amongst other things, we use your information to detect and protect us against error, fraud, and other criminal activity. We may compare and review your personal information for errors, omissions and for accuracy.

• If you use the Contact feature on our Site, we may collect your name, email address, object of your communication and your message. We use this information to respond to your request or comment. If you send us emails or letters, we may collect such information in a file specific to you.

• If you apply for a position at Pure with respect to an employment opportunity posted on our Site or posted on an External recruitment platform, or as a spontaneous application, we will collect your name, email address, and any other information you provide, including employment history. We use this information to review and respond to your application. In limited instances during the recruitment process, decisions on candidates and/or employees may be made on the basis of automated processing of information, without any human input.

• If you subscribe to our Mailing list, we will collect your name and email address to send you emails about various news and promotions. Even after subscribing to one or more newsletters and/or opting in to one or more offers to receive marketing and/or promotional communications from us, you may elect to modify their preferences by following the “Unsubscribe” link provided in an email or communication received. 

We may also use the personal information we collect to communicate with you, including through tailored marketing messages and transactional emails, to conduct, process and complete transactions with clients, to meet legal, regulatory, insurance, security and processing requirements, and otherwise with your consent, or as permitted or required by law.

Collection and Use of Customer Data

Certain services or products may require our customers to provide us with their clients’ personal information. When we collect and use personal information on the instructions of our customers, we are acting as a service provider/data processor to that client, processing personal information on their behalf, and we refer to this data as “Customer Data”. We may also use Customer Data on an aggregated and non-identifiable basis to improve and enhance our product and service offerings.

We rely on our clients to comply with all applicable privacy laws when collecting, using, or disclosing personal information through the services, including by obtaining appropriate consent prior to collecting, using, and disclosing personal information through the services. Where required by law, we sign agreements framing this sharing of personal information. 

If you have any questions regarding the personal information we process on behalf of a client, please contact the client directly and/or review their applicable privacy policy.

Disclosure of Personal Information

Pure will only disclose your personal information with your consent or if it has legal authority to do so, such as in the following contexts:

• Pure may transfer personal information to third-party service providers (including affiliates acting in this capacity) that perform services on our behalf, such as data hosting and processing, customer services, third-party technology, or software developers and to complete transactions. When we disclose your personal information to third parties, we take reasonable contractual measures to ensure that such third parties comply with applicable laws. These third parties will obtain only the personal information that is necessary for the purpose for which Pure has employed them.

• We may use and disclose personal information in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of Pure, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. Assignees or successors of Pure, or our business or assets, may use and disclose your personal information for similar purposes as those described in this Policy.

• Pure may disclose personal information as necessary to meet legal, regulatory, insurance, audit, and security requirements, and as otherwise with your consent, or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to us or our service providers). Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your name, city, province, telephone number, email address, and purchase and communication history with Pure without a subpoena. However, in an effort to balance your right to privacy and the ability to keep the community free from bad actors, we will not disclose additional information to law enforcement or other government officials without a subpoena, court order, or substantially similar legal procedure, except when the additional disclosure of information is necessary to prevent imminent physical harm or financial loss.

International Storing and Transfer of Personal Information

In order for us to offer our Products and Services, the personal information may be processed by us or our third-party service providers. Pure or our third-party service providers may collect, use, disclose, store or process personal information on servers located in other jurisdictions, including the United States or another Canadian province, for the purposes described within this Policy. Please note that the privacy laws in such jurisdictions may differ from Quebec and Canada privacy laws. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to applicable foreign legal requirements, including lawful requirements to disclose personal information to government authorities and law enforcement in certain circumstances. By submitting your personal information or engaging with the Site, you consent to such transfer and storage.

Links to Other Sites

We may offer links to other websites controlled by other entities. We are not responsible for, nor do we accept any liability for how such other entities collect, use, and disclose personal information. You should consult the privacy policies of these other websites before providing any personal information.

Security

The security of your personal information is very important to us. We take reasonable steps to protect the personal information in our custody or control using physical, electronic or procedural security measures, including firewalls and encryption, that are appropriate having regard to the nature and sensitivity of the information. We take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to perform, develop or improve our Products and Services. However, please note that no security measures can offer absolute security.

Safety and security of your information is also your responsibility. If you have chosen a password to access certain Products and Services, you are responsible for keeping this password confidential. We ask that you do not share your password with anyone.

Accessing, Correcting, Withdrawing Consent and Deleting Personal Information

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes. By law, you have the right to request access to and/or correction of the personal information we hold about you.

If you wish to review, verify, correct, or withdraw your consent to the use of your personal information, you may also send us an email to privacy@pureindustrial.ca to request access, correction, or deletion of any personal information you have provided to us. We may not accept a request to change information if we believe that the change would violate a law or legal requirement or result in incorrect information.

Before providing you with access to your information, we may ask you for specific information to help us confirm your identity and right of access, and to provide you with the personal information we hold about you, or to make the requested changes. In some cases, applicable law requires us to refuse to provide you with access to some or all of the personal information we hold about you, or that we may have destroyed, erased or made anonymous in accordance with our legal record-keeping obligations and privacy best practices.

Please note that if you request deletion of certain information, we may not be able to provide you with certain services. We will explain the consequences of deletion at that time to assist you in your decision.

If we are unable to provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their personal information or confidential business information or would be prohibitively costly to provide.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Furthermore, Pure does not sell your information to third parties.

Additional Rights

Applicable laws may give you additional rights that are not described in the Policy.

Privacy Policy Changes

This Policy is effective as of the last updated date above and may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this Policy, we will make reasonable efforts to notify you of this, including by posting the revised Policy on our Site. Your continued provision of personal information, use of our Site or Product and Services following any changes to this Policy constitutes your acceptance of any such changes.

Contact

If you have any questions about this Policy or wish to make a complaint, you may contact our Privacy Officer using the following contact information:

121 King Street West, Suite 1200
Toronto, Ontario M5H 3T9
Phone: (416) 479-8590
Facsimile: (416) 598-0435
Email: privacy@pureindustrial.ca
Attn: Privacy Officer

Administration

This Policy will be interpreted and applied consistent with the Company’s obligations under the applicable legislation.  Subject to compliance with applicable legislation, the Company shall have full discretionary authority to interpret and administer this Policy. The Company reserves the right to modify, amend, suspend, or terminate this Policy at any time, in its sole discretion, without advance notice.

This page was last amended on: July 13, 2023