Privacy Policy.

Introduction

Power Sustainable recognizes the importance of transparent and responsible use of your Personal Information. This Privacy Notice ("Notice") outlines how Power Sustainable collects, uses, and processes your Personal Information.

We want to make sure that you fully understand the nature of the Personal Information we need from you to serve you better, how we use and protect your Personal Information, and why the collection and processing of your Personal Information is necessary when you interact with us.

What does this notice cover?

This Notice applies to all Personal Information collected during the course of Power Sustainable's business operations. This includes information obtained from business contacts, potential investors, job applicants, or visitors to our website. It also covers Personal Information collected when you communicate with us—whether over the phone, in person, or through email.

However, this Notice does not apply to Personal Information collected from our employees. If you are a current or former employee of Power Sustainable, please refer to our Employee Privacy Notice.

What is Personal Information?

For the purposes of the work that Power Sustainable performs and the regulations that Power Sustainable needs to comply with, “Personal Information” refers to any information related to an identified or identifiable individual such as name, address, date of birth, personal identification numbers, location or financial data.

Privacy regulations we need to comply with

As a global investment management firm with operations in multiple jurisdictions, Power Sustainable is obligated to comply with various privacy regulations, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Quebec’s Law 25 in Canada, the General Data Protection Regulation (GDPR) in the EU, the U.K. Data Protection Act 2018, U.S. state privacy laws such as the California Privacy Rights Act (CPRA), among others.

We respect your privacy rights and commit to protecting your Personal Information according to the expectations of the laws of where you are located.

How we collect and process your Personal Information

Power Sustainable collects Personal Information from several different sources, including:

  • Directly from you or your authorized representative for example an intermediary, lawyer;
  • From service providers or other third parties; and
  • Automatically through your activity on our website.

Personal Information collected Directly.

The business contact information you share with us

We collect Personal Information directly from you during communications with any of our employees or representatives, whether through phone, email, contact forms, or in-person interactions.

The Personal Information we collect includes your name, job title, email address, business address, telephone number, and a record of your communication with us.

We use the Personal Information collected to maintain and cultivate our relationship with you. This includes organizing meetings between you and our executives, sending you relevant investment materials or information, and responding to your requests and inquiries.

When you submit a whistleblowing report

We collect Personal Information directly from you when you report an incident through our whistleblowing system. When you make a report, we collect your name, email address, phone number, relationship to the organization, details of the incident, and any attachments you choose to include as evidence. You may also choose to remain anonymous, in which case we will not collect your contact details.

We use the information provided to investigate the reported incident and to maintain communication with you during the investigation process if necessary.

Information you provide to us in the course of business relations

We collect your Personal Information directly from you or through your authorized representatives. This collection takes place through various means, including submissions in virtual data rooms, completing subscription forms, and communications via phone, email, or in person.

For institutional investors and portfolio companies, we also process Personal Information related to your directors, officers, and beneficial owners.

The Personal Information we collect includes:

  • Contact information: Name, address, telephone number, email address.
  • Financial information: Bank details for transactions, the fund the investor is subscribing to, requested amount of commitment, and financial details like assets, liabilities, income, and investments.
  • Employment information: Job title and background.
  • Personal identification numbers: Social Insurance Number (SIN) and Social Security Number (SSN).
  • Know Your Customer (KYC)/Anti Money Laundering (AML) Information: Government-issued identification (e.g., valid driver’s license, passport, alien identification card, military ID card, or other government-issued identification bearing a photograph), proof of residential address, and executed tax forms.
  • Record of communication: contents of email, text messages and other communication.


We use the Personal Information collected to administer fund interests, manage subscriptions and distributions, conduct internal audits, support investor relations, and ensure compliance with KYC, AML, and other regulatory obligations.

Personal Information we obtain from others

We collect your Personal Information from various third-party sources for specific purposes:

  • Banks, credit reporting agencies, and other financial institutions: To verify your financial profile, assess risks, and ensure compliance with financial regulations.
  • Corporate Group and Affiliates: We receive Personal Information from other businesses and partners within the same corporate family or those with whom Power Sustainable has a business relationship.
  • Public Records and Databases: for compliance with anti-money laundering obligations, background screening and to comply with our legal and regulatory obligations.
  • Event Organizers and Conferences: We collect contact details, areas of interest, and professional affiliations through participation in or sponsorship of industry events. We use this information to send you promotional materials, and other communications you may be interested in.
  • Subscription Services and Marketing Databases: We obtain contact details and other relevant information about individuals from companies specializing in marketing data.
  • Social Media Platforms: Information is indirectly obtained through social media interactions and public postings on platforms like LinkedIn, where individuals share their professional and personal interests.
  • Third-Party Recruiters: These entities provide us with Personal Information of potential candidates, including resumes, contact details, employment history, and professional qualifications, to identify and evaluate potential candidates for employment, ensuring they possess the necessary qualifications.
  • Background Check Services: To verify the qualifications and backgrounds of potential hires, we collect employment history, criminal records (where permissible under law), and educational background.

Personal Information obtained automatically

We automatically log information about you, your computer or mobile device, and your activity when you use our website. This includes details of your visit such as your IP address and the location from which you access the website.

We use cookies and Google Analytics to gain insights into how our visitors navigate the website in order to provide you with a better web experience.

Who has access to your Personal Information?

We will not disclose your Personal Information to any party not authorized to process it. To manage our relationship with you, we will share your Personal Information internally with members of our management team, business units, and technical support staff on a need-to-know basis.

We will only disclose your Personal Information to the following parties under specific circumstances:

  • Power Sustainable’s Parent Company, Subsidiaries and Affiliates: Power Sustainable is a subsidiary of Power Corporation of Canada, ("PowerCorp") and as such, we utilize certain systems owned or managed by PowerCorp. We also share Personal Information with our affiliates and subsidiaries, where it is reasonably necessary or desirable for us to carry out our identified Personal Information processing purposes.
  • Service Providers: We partner with various service providers to support our business operations. These providers offer services that include, but are not limited to, hosting and maintenance, data storage and management, marketing and analytics.
  • AML/KYC Obligations: We share your Personal Information with relevant parties in connection with our anti-money laundering, anti-bribery, anti-fraud or “know your client” requirements including third party service providers which carry out sanctions checks on our behalf.
  • Professional Advisors: We share your Personal Information with our professional advisors such as our auditors, accountants, insurers, brokers, and legal or financial advisers as necessary for the professional services they provide to us.
  • Legal Processes and Obligations: We disclose your Personal Information in response to lawful requests by regulators, government authorities, public authorities (e.g., tax authority), courts, or law enforcement.
  • Business Transfers: We also disclose your Personal Information in the event of a contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets.

What rights do you have regarding your Personal Information?

Privacy regulations, such as PIPEDA, Quebec’s Law 25, GDPR, and the CPRA, grant you rights concerning the Personal Information that organizations like Power Sustainable collect and manage about you. To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Information:

  • Access the Personal Information we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
  • Request an update or correction of your Personal Information so that it is always accurate.
  • Receive your Personal Information in a structured, commonly used and machine-readable format, including the right to transfer your Personal Information to another data controller.
  • Request the deletion of your Personal Information if you believe that retention is no longer necessary for the purposes indicated above.
  • Restrict the processing of your Personal Information.
  • Withdraw your consent at any time if your Personal Information is processed with your consent.
  • Object to the processing on specific grounds relating to your particular situation.
  • Right to opt-out of sharing your Personal Information for cross-context behavioral advertising or to opt-out of targeted advertising;
  • Right to opt-out or request we limit the processing of your sensitive Personal Information;
  • Right to appeal the denial of a request.


For individuals in California, once we receive your request to disclose how Power Sustainable has collected, used, and shared your Personal Information in the last twelve months, we will verify your identity and provide the following information:

  • Categories of Personal Information collected about you by Power Sustainable.
  • Sources from which we obtained your Personal Information.
  • Purposes for using your Personal Information.
  • Third parties with whom we shared your Personal Information.
  • Whether we sold or shared your Personal Information for the benefit of Power Sustainable.

Exercising your rights

To exercise any rights you have regarding your Personal Information, please contact us using the details provided in the 'How to contact us' section of this Notice. We may need additional information from you to verify your identity and process your request. We will respond to your requests within the time frames mandated by applicable law.

We are committed to resolving any requests, concerns, or complaints you may have in a fair and reasonable manner, and we will not discriminate against you for exercising your Personal Information rights.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority. We ask that you reach out to us to resolve your complaint before contacting a data protection authority.

Canadian Residents

If you are located in Canada, we comply with applicable Canadian federal and provincial privacy legislation. We ensure that our privacy practices align to the Fair Information Principles as stated in Canadian privacy laws.

You may direct any complaints, questions, or enquires with respect to the privacy principles outlined here or about our practices by using the contact information at the end of this Notice. You may also make a complaint to the Office of the Privacy Commissioner of Canada.

United States (US) Residents

This section of the Privacy Notice describes the practices that we follow regarding the collection, use, and disclosure of Personal Information of individuals in US states that have enacted privacy laws including but not limited to California, Colorado, Virginia, Utah, and Connecticut collectively referred to as “US State Privacy Laws”:

Categories of Personal Information collected and disclosed

For the purpose of our business or for the purpose of your interactions with our website, the categories of Personal Information we have collected and used in the past twelve months include identifiers, characteristics of protected class, commercial information, Professional or Employment Information, customer records information, Internet or other electronic network activity information, sensitive Personal Information and inferences drawn from such information.

For examples of specific pieces of Personal Information collected, please see the “How we collect and process your Personal Information” section above.

Power Sustainable has shared Personal Information in the last twelve months on all the categories identified above for the purposes described in the “Who has access to your Personal Information” section of this Privacy Notice.

Sale of Personal Information

We have not sold Personal Information to third parties during the 12 months prior to the Effective Date of this Privacy Notice, and do not plan to do so without further notice (except for a sale in connection with the sale or transfer of the business or our assets, as noted in the section above about sharing).

European/UK Residents

If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), we only process your Personal Information when we have a valid “legal basis”. We will only process your Personal Information if:

  • We have obtained your explicit consent prior to the processing of your Personal Information.
  • If we need your Personal Information to perform a contractual obligation.
  • If we need to process your Personal Information to fulfill our legal and regulatory obligations.
  • If we have a legitimate interest that will not put your rights and freedoms at risk.

Where is your Personal Information stored?

The Personal Information that we collect from you for the purpose of our business operations is stored on servers in the US and Canada. We will take appropriate steps to ensure that transfers of Personal Information across borders are in accordance with applicable law, and we only transfer Personal Information to partners and other third-party organizations where we are satisfied that adequate levels of protection are in place to protect your information.

For Personal Information transferred out of the EU or the UK into countries that are not considered to have an adequate level of Personal Information protection, we obtain contractual commitments from third party organizations to protect your Personal Information. These contractual commitments include the use of standard contractual clauses approved by the EU Commission to ensure that we have a valid data transfer mechanism in place.

Personal Information from minors

We do not knowingly collect Personal Information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us using the details in the “How to contact us” section of this Notice.

If we become aware that we have collected Personal Information from children without verification of parental consent, we take steps to remove that information from our servers.

How do we keep your Personal Information safe?

Power Sustainable is committed to protecting the Personal Information we collect, process, and disclose about you. We maintain appropriate safeguards and take reasonable steps to protect your Personal Information, ensure that we limit its use and that we disclose it only to the parties that have a legitimate reason to have access to it.

We ensure that all the parties that we disclose your Personal Information to, internally and externally, have contractual obligations to protect the security and the confidentiality of your Personal Information.

How long do we retain your Personal Information?

We are expected to retain your Personal Information for an established period of time for regulatory, legal, tax or business requirements.

We retain your Personal Information for no longer than reasonably necessary to fulfill the purposes for which we collected it or to comply with the law, prevent fraud, facilitate an investigation, defend against legal claims, or exercise our legal rights and in compliance with our internal record retention schedule.

How to contact us

If you have any further questions regarding the Personal Information that Power Sustainable or any of our partners collect and process or if you have feedback regarding this Privacy Notice, you may contact us at Compliance@powersustainable.com

How we update this Privacy Notice

We reserve the right to modify this Notice at any time in accordance with applicable law. If we do so, please look at the “Last Updated” legend at the top of the Notice to see when this Privacy Notice was last revised. Any changes to this Notice will become effective when we post the revised Notice on the website.