PRIVACY POLICY

Welcome to the Fox & Co Ltd website!
At Fox & Co Ltd ("FOXCO"), we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that FOXCO collects from or about you, how we use it, and to whom we disclose that information.
If you disagree with the practices described in this policy, you should take steps to remove any cookies from your computer after leaving our website, and discontinue your use of our website and our services.
Our products and services are not directed to individuals under the age of eighteen (18), and we request that they not provide any personal data to FOXCO.
Privacy Policy Effective for Canada

It is FOXCO's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.
Our store may be hosted by third party service providers. They may provide us with an online e-commerce platform which allows us to sell our products and services to you. Your data is stored through the data storage, databases and the general application of any such service provider. They store your data on a secure server.
If you choose a direct payment gateway to complete your purchase, the gateway may also store your credit card or debit card data. Payments and related information are typically encrypted through the Payment Card Industry Data Security Standard (or similar). We will refer to all such applicable standards in this policy as "PCI-DSS". Your purchase transaction data is typically stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is typically deleted. All direct payment gateways adhere to standards such as PCI-DSS. For example, the PCI Security Standards Council, a joint effort of brands like Visa, MasterCard, American Express and Discover, sets these standards. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service. When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
What Is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than an individual's business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
contact and identification information, such as your name, address, telephone number, e-mail address, gender, and date of birth;
any survey responses that you provide to us;
product and service related information concerning the products and services that we provide to, or receive from, you;
browser and device data, such as IP address, device type, operating system and internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and versions;
transaction data, such as purchases, purchase amount, date of purchase, and payment method;
cookie and tracking technology data, such as time spent on our website, pages visited, language preferences, and other anonymous traffic data;
credit and financial information such as your credit card or debit card number, direct deposit and banking information; and
business relationship information, including feed-back and information requested by or provided to you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial and other advisors.
FOXCO's operations may also include activities related to the provision of online or other rewards programs. As such, FOXCO may also collect personal information from individuals participating in and / or impacted by those activities, including information related to obtaining permits and licenses, emergency planning and environmental stewardship.
As a general rule, FOXCO collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources. Such permission may be given directly by you, or implied from your actions.
From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Our Website
We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.
We may place a "cookie" on the browser of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.
Finally, our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. FOXCO is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.
Online Behavioral Advertising
FOXCO may from time to time engage in online behavioral advertising. This may involve collection of behavioral data which is not connected to your personal information, such as your inferred age group, your inferred gender and your inferred purchase interests, among other things.
Additionally, FOXCO may automatically receive and store certain types of information about you through the data sources listed above.
As mentioned above, a cookie may be placed on your computer when your web browser accesses our website. We use cookies for tracking transactions and the user characteristics explained in detail throughout this Privacy Policy. If you choose, there are utilities available for purchase from independent software providers to install on your computer as well as tools or preferences you can choose through most web browsers to make website visits anonymous.
We may also add third party cookies. Cookies contain anonymous, segmented data about a user’s demographics (like age, gender, and location), interests, lifestyle, household details, social media memberships, and online influences. The date in the cookies does not contain individual-level information, but rather general audience segments.
In visiting this site, a third-party advertiser (or its partners) may place or recognize a unique cookie on your browser. These cookies enable more customized ads, content or services to be provided to you. To trigger these cookies, we may pass an encrypted or “hashed” (non-human readable) identifier corresponding to your email address to a Web advertising partner, who may place a cookie on your computer. No personally identifiable information is on, or is connected to, these cookies. To opt-out of these cookies, please go to http://www.privacychoice.org/choose.
We may also collect information through our web server applications. This information includes your Internet Protocol or IP address, date/time stamp, browser type, and referring URL.
Additionally, we may use pixel tracking technology to track the completion of transactions with us or our advertisers, the source information for those transactions, and your IP address, date/time stamp, browser type, and referring URL.
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access our websites, based on data relating to your access to and use of our websites on any of your devices, as well as data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop, and to make decisions about the advertisements you see.
You may be able to download the AppChoices app or a similar app in order to opt out in mobile apps. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that you have visited our website or seen one of our advertisements, and we may provide that data to one or more third party advertising networks. The data we provide may include the time and date of your visit to our website, pages viewed, links clicked and other information that does not disclose your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with your visit to our website when you visit other websites on which they serve advertising, and they may make decisions about the advertisements you see based on it.
We may choose to work with Google AdWords, Doubleclick, AdRoll or other advertising networks. Each of these companies has its own privacy policy, which we encourage you to review. For more information about advertising and tracking online, visit the Network Advertising Initiative. This website allows consumers to “opt out” of the behavioral advertising delivered by member companies. At present, there is no industry standard for recognizing Do Not Track browser signals, so we may not respond to them.
Why Do We Collect Personal Information?
FOXCO collects personal information to enable us to manage, maintain, and develop our operations, including for example:
to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;
to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
to enable us to undertake our environmental, health and safety activities, including incident planning, response and investigation
to protect FOXCO against error, fraud, theft and damage to our goods and property;
to enable us to comply with applicable law or regulatory process (for example, we may collect personal information to satisfy the obligations imposed on us by our various regulators); and
any other reasonable purpose to which you consent.

How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
for the purposes described in this Privacy Policy; and
for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When do we Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.
For example, our third party service providers may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada, the United States of America or elsewhere.
Our products and services may be available globally and data (including personal data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer data to countries outside of your country of residence, including Canada and the United States of America, which may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.
In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of FOXCO or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
Further, your personal information may be disclosed:
as permitted or required by applicable law or regulatory requirements;
to comply with valid legal processes such as search warrants, subpoenas or court orders;
as part of FOXCO's regular reporting activities to its parent and affiliated companies to protect the rights and property of FOXCO;
during emergency situations or where necessary to protect the safety of a person or group of persons;
where the personal information is publicly available; and
with your consent.

Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into a transaction or agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that transaction or agreement, and for any other purposes identified to you at the relevant time.
Typically, we will seek your consent where required to do so at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.
How is Your Personal Information Protected?
FOXCO will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, use, disclosure, copying, modification, disposal or destruction.
The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.
Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Privacy Officer
Fox & Co Ltd.
53 Turner Road
Toronto, Ontario
M6G 3H7

Revisions to this Privacy Policy

FOXCO, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website, and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on 18 July 2015.
Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples. For instance, where the word "including" is used, it shall mean "including without limitation".
This Privacy Policy does not create or confer upon any individual any rights, or impose upon FOXCO any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.