Privacy Policy

We Respect Your Privacy

Last updated: October 2020

First Tracks Capital Ltd. and its affiliates (“Company,” “we,” “us,” “our”) respects the privacy of all of its users and is committed to protecting such privacy in accordance with this “Privacy Policy.”

This Privacy Policy explains our treatment of your information collected in connection with your activities at firsttrackscapital.com (and all sites hosted on these domains) (the “Website”). This Privacy Policy also explains how you can ask questions and make suggestions about our privacy practices and review and update your personal information.

We urge you to read this Privacy Policy carefully and to check back periodically it may change from time to time. Please note that this Privacy Policy does not apply to the practices of companies or websites which are not owned or controlled by Company.

  1. Information Collected

In the course of conducting services through the Website, and/or other means of communication with you, (a “Company Service”), we may collect Personal Information (as defined below):​

  • “Personal Information” is personally identifiable information or information that could be reasonably associated with you, such as your first name, last name, address, email address, birth date, gender, company name, phone number and any other related information that identifies you or can identify you.

Personal Information is collected when you choose to provide it to us when registering for a Company Service, filling out a form, or otherwise communicate such information directly to us. For example, if you choose to contact any of our employees or representatives, we may keep a record of that correspondence so that we may fully address the subject matter. We may also receive your Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information.

The Company may collect certain information electronically which may be deemed Personal Information when you visit the Website, email us, view online advertisements, or through third-party technologies, such as cookies.

  1. Consent to Collection, Use and Disclosure

As a result of receiving a Company Service and/or submitting information to us related to a Company Service, you are providing your consent for us to collect, use and disclose your Personal Information in accordance with this Privacy Policy and applicable laws. You may withdraw your consent at any time, subject to applicable laws. Personal Information may be used by us for the following purposes:

  1. Providing you with the Company Services and other services and information you have requested from us, including your use of the Website. We may from time to time use your Personal Information to contact you about changes, enhancements or similar notices related to the Company Services or other services that we feel may be of interest to you;
  2. If you indicated that you were interested in receiving information from our Company or certain affiliated companies, sponsors or advertisers, Company or such affiliated companies, sponsors or advertisers may send you email materials and other mailings about products and services that we feel may be of interest to you. If at any time you would like to end your subscription to any such email materials, follow the directions posted at the bottom of the email material to unsubscribe;
  3. The Company may also use Personal Information if it has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law or in order to protect or defend a legal interest;
  4. To manage the business operations of the Company;
  5. To generally enhance your experience with the Company; and
  6. As permitted or required by law.

In addition to the above: We use Google Analytics, a third party hosted tool to receive information from your browser that includes but is not limited to: the pages you visit on the Website, method of which brought you to our Website, your IP address, your geographical locations and the browser you are using.

  1. Disclosure of Personal Information

Subject to Section 4(e), we will not sell or rent your Personal Information to anyone. We may share your Personal Information internally within the Company or its affiliates. We will only disclose your Personal Information to third parties:

  1. where you have specifically given us your consent to disclose your Personal Information for a designated purpose;
  2. who are acting on our behalf as our agents, suppliers or service companies, solely to enable us to more efficiently provide you with the Company Services. Such entities act under contractual controls, requiring them to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of the Company Services;
  3. to facilitate the provision of such Company Service, such as fulfilling legal requirements;
  4. as required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest;
  5. in connection with a Company corporate reorganization, merger or amalgamation with another entity, or a sale of all or a substantial portion of the assets of Company provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information; and
  6. with your implied or express consent in accordance with applicable law.
  1. Links to Other Sites and Advertisements

A Company Service may contain links to other websites and services. While we try to link only to websites and services that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Policy applies only to the Company Services referencing this Privacy Policy.

  1. Security

(1) The security of your Personal Information is important to us. The Company takes technical, contractual, administrative, and physical security steps to protect Personal Information that you provide to us. We instruct our employees with access to your Personal Information that it is to be used only in adherence with the principles set forth in this Privacy Policy and applicable laws.

(2) In certain areas, such as when you provide payment details, banking details, credit card information to us, we work to help protect the security of your financial information.

(3) The Company will keep and store your Personal Information for a period of time that is necessary to fulfill its purposes for which it is collected, except as required or permitted by applicable law.

(4) You can help protect the security of your Personal Information as well. For instance, never give out your passwords for accounts you use to communicate with us, logging out of your account and closing your browser window when you finish using a Company Service and the internet so that other people using the same computer won’t have access to your information.

  1. Changes to this Privacy Policy

We may from time to time change our Privacy Policy as new Company Services are added or changed, or in compliance with applicable law. Changes will be effective when notice of such change is posted on the Website. If you continue to receive the Company Services after the changes have been posted to the Website, you are accepting these changes. It is your responsibility to read, understand and agree to the terms of this Privacy Policy and any changes made. If you do not agree to this Privacy Policy or any changes, it is your responsibility to cancel the Company Services and stop using any related service. First Tracks Capital Ltd. reserves the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice.

Please check this Privacy Policy regularly for updates by checking the date “Last Updated” at the top of this document.

  1. Accessing and Changing your Information

(1) You have a right to access your Personal Information. To do so, you can contact the Company to request your information on file to update, edit or delete any account or registration information you may have provided to us at any time.

(2) If you are unsure whether we have a record containing any of your Personal Information and would like to confirm whether or not we do, or if you would like to withdraw your consent to the use of your Personal Information as described in this Privacy Policy please send an email to our Privacy team at info@firsttrackscapital.com and indicate all email addresses that you may have given us.

(3) If you decide at any time that you do not want to receive any email materials to which you have subscribed, you may choose to unsubscribe to these emails by following the instructions at the bottom of the email material.

  1. Questions, Comments or Suggestions

If you have questions, comments or suggestions about this Privacy Policy or Company’s privacy practices that were not answered here, please send an email to our Privacy team at info@firsttrackscapital.com.