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Personal information
collected when you
interact with us

We may collect and use personal information when you:

• Name and contact information (such as email address) when you contact us, subscribe to investor alerts, or request that we contact you.
• Contact us with a comment, question or complaint.
• Any other information you include when submitting inquiries or feedback.

Information collected about your device and usage of our services

Information About Your Use of our Services. In addition to the information you provide to us directly, we (and our third-party service providers on our behalf) may collect information about your use of the Site. We use this information for analytics to better understand our users as well as to improve users’ experience on the Site. For example, we may collect:

• Device information - such as your hardware model, IP address, other unique device identifiers, operating system version, and settings of the device you use to access the Site.
• Usage information - such as the time and duration of your use of the Site, what portions of the Site you use, how often you use them, what links or materials (including advertising) you click when using the Site, whether you open the emails we send, what materials you view when using the Site, and other information about your interaction with content offered through the Site, and any information stored in cookies and similar technologies that we have set on your device.
• Location information - such as your computer’s IP address or general location (e.g. city/town/province/country), or with your express consent, your mobile device’s GPS-based location. Your location information is used to provide you with relevant information that relates to your location. You can adjust your location preferences at any time in your device settings.

As with many online services, certain limited data is required for the Site to function on/with your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the Site access our servers. In addition, we may use third-party service providers to collect analytical information about your use of the Site, such as the feature you use and/or time spent on the Site, collectively for the purposes of helping us to improve the Site experience for all users and to manage and analyze data in order to better understand our users.
We may also monitor use of the Site to detect, investigate or prevent any actual or potential violation of this Privacy Policy or other applicable terms and conditions.
We may generate aggregated, non-identifiable data and use such information to monitor and improve the performance, use and stability of the Site.

Information to help us respond to you

To Respond to You. When you contact us, we may collect information that identifies you (such as your name, email address, phone number and country) along with any information you provide in your communications and additional information we need to help us promptly answer your question or respond to your comment. We retain this information to assist you in the future and to improve our products and services.

Other information collected
with your consent

Other Information We Collect. We also may collect and use other information about you, your device, or your use of the Site in ways that we describe to you at the point of collection or otherwise with your consent.

With our service providers

Service Providers. We may transfer information to companies providing services on our behalf, such as our affiliates, hosting vendors, and data analytics companies. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other unrelated purposes. Our service providers may be located across Canada, in the U.S., or other foreign jurisdictions.

When required by law or to protect our guests and legal interests

Other Parties When Required or Permitted by Law, or As Necessary to Protect Our Guests and Services. We, and the third parties we engage (including affiliates), may use and share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of RBI, its affiliates or business partners, our employees or agents or guests, to detect, suppress or prevent fraud or where otherwise required or permitted by applicable law or legal process, including responding to a search warrant or other legally valid requests from public and government authorities (which may include lawful access by Canadian, U.S., or other governmental authorities, courts or law enforcement agencies).

When necessary, in connection with a corporate transaction

Other Parties in Connection with a Corporate Transaction. We reserve the right to transfer any information we have about you in the event that we seek to sell or transfer all or a portion of our business or assets to a third-party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization or other change in corporate control.

With other parties, with your consent

Otherwise With Your Consent or at Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

Types of digital technologies we may use

Digital Technologies. We and other companies that provide us with services may use cookies, web beacons, and similar technologies (“digital technologies”) to facilitate administration and navigation of the Site, to better understand and improve the Site, and to provide you with a customized online experience, including by providing you with personalized content that are more relevant to you.

Information about cookies

Cookies. “Cookies” are small files that are placed on your computer or other device when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials, so you do not have to enter those credentials each time you visit the Site.
• Cookies can help us and third parties understand which parts of the Site are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt the Site and provide you with a better experience.
• Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you visit the Site.

Most browsers accept cookies automatically but can be configured not to do so. A banner may appear on the Site allowing you to manage your consent to collect cookies (“Cookies Banner”). The Privacy Preference Center section of the Cookies Banner provides a description of the categories of cookies collected on the Site. You may also manage your preferences, including disabling cookies within the Privacy Preference Center. However, if you disable cookies, it may interfere with the functioning of the Site.

If you prefer not to be recognized when you visit the Site, you can always connect using an incognito browser window. You can also remove traces of your visit by clearing your browser history.

Information about beacons

Beacons. We, along with third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of the Site and (in conjunction with cookies) to provide content and ads that are more relevant to you both on and off the Site.

Our use of do-not-track signals

Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, the Site currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

Our use of other technologies

Local Storage & Other Tracking Technologies. We, along with third parties, may use other kinds of technologies in connection with the Site. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.

Our use of analytics services

Analytics. We may use a third-party such as Google Analytics to help us gather and analyze information about the areas visited on the Site (such as the pages most read, time spent, search terms and other engagement data) to evaluate and improve the user experience and the Site. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

• https://policies.google.com/technologies/partner-sites
• https://support.google.com/analytics/topic/2919631

Your decisions about digital technologies

Choices With Respect To Digital Technologies. You may block digital technologies in your browser or device settings, as and if permitted by such device, but in some circumstances, disabling these features may interfere with your ability to access the Site.

Making changes to your account

Manage Your Account. You may request to access, modify or delete your data by contacting the Privacy Officer at privacy@rbi.com with such request. In addition, you may contact us at 1 (888) 601-1616 (Canada and United States). Whichever way you elect to contact us, we may ask that you confirm and verify your identity. When you email us, please reference the Site’s URL in the subject line, and please provide a detailed description of the nature of your request.

How to Exercise Your Privacy Rights

Your Rights. Subject to certain exceptions prescribed by law, you may have the right to access, update, correct inaccuracies, and where appropriate, request deletion of your personal information in our custody and control and withdraw your consent to our collection of your personal information. As required or permitted by law, you may be entitled to additional rights, including: (i) the right to control the dissemination of your personal information; (ii) the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization; (iii) the right to be informed of and submit observations regarding automated decision-making; and (iv) the right to request information about data processing. You may request access, updating and corrections of inaccuracies in the personal information we have in our custody or control, withdraw your consent to the collection, use or disclosure of your personal information or exercise any additional privacy rights available to you, by writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records. Please note that if you withdraw your consent to our collection, use or disclosure of your personal information, we may not be able to provide some or all of our services to you.
If you believe that applicable data protection laws have not been complied with, you may lodge a complaint with us by using the contact information provided below. You also have the right to complain directly to the appropriate data protection authority.

Our data retention and security practices

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out in this Privacy Policy or as otherwise required to meet legal or business requirements. We have in place physical, electronic, and managerial procedures in an effort to safeguard personal information in our custody and control against loss, theft and unauthorized access, use, modification and disclosure.
We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements

Children’s privacy

Children’s Privacy. We do not knowingly collect any personal information from children under the age of 13 (or such other age as specified under applicable law) without parental consent. If we learn that a child for whom parental consent is required has provided us with personal information, we will use reasonable efforts to delete it in accordance with applicable law. If you are a parent or guardian of a child under the legal age of consent, and you believe your child has provided us with personal information, please contact us by following instructions at the “Contact Us” section below.

Third-party sites

Links to Third-Party Sites. The Site may link to third-party websites and services that we do not operate and are outside of our control. For example, hyperlinks appearing on the Site may direct you to third parties. We are not responsible for the security or privacy of any information collected by other websites or other services. We are not responsible for the products or services offered by any third parties. Please exercise caution and review the privacy statements applicable to the third-party websites and services you use.

We transfer your information outside of your home jurisdiction

International Transfers. We are organized under Canadian law and headquartered in Canada; however, please be aware that information you provide to us or that we obtain as a result of your use of our services may be collected in your jurisdiction and subsequently transferred to, maintained and/or processed outside of your jurisdiction (including for residents of the province of Quebec, outside of Quebec), including in the United States or another jurisdiction by us or our service providers for the purposes mentioned above, in accordance with applicable law. Personal information processed and stored in another country may be subject to disclosure or access requests by the governments, courts or law enforcement or regulatory agencies in that country according to its laws. We take reasonable steps to ensure that your personal information will only be used for purposes mentioned above and is communicated to service providers acting on our behalf, except where authorized by law.

Updates to this privacy policy

Changes to Our Privacy Policy. We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Site. Your use of the Site or your provision of personal information to use our services or the Site following such changes indicates your acceptance of the revised Privacy Policy.

How to contact us about privacy-related matters

Contact Us. Please contact our Privacy Office at privacy@rbi.com with any questions about this Privacy Policy or the manner in which we or our service providers treat your personal information (including outside of Canada). In addition, you may contact us at 1 (888) 601-1616 (Canada and United States). Whichever way you elect to contact us, we may ask that you confirm and verify your identity. When you email us, please reference the Site’s URL in the subject line, and please provide a detailed description of the nature of your request.