Introduction and scope
Beacon Holdings (Beacon Acquisition Corp.) (“Beacon”, “we”, or “us”) values and respects your privacy. This Privacy Policy (“Policy”) applies to the personal data collected by Beacon when you interact with our website and services that link to this Policy (“Personal Data”).
In the Policy, “you” means:
- A visitor to www.beaconholdings.com;
- Sub-domains of the above, or any of our other websites or applications that link to this Policy or (collectively “Site(s)”), and
- Individuals who interact with us through our social media channels or at events or webinars,
- Individuals who apply for a job at Beacon,
- Individuals who participate in our surveys or research, and
- Individuals whose Personal Data we receive in connection with a prospective or completed investment in, or acquisition of, a business (such as employees, shareholders and customers of that business).
This Policy explains how we collect, receive, use and share your Personal Data. This Policy also describes your choices and rights concerning your Personal Data. Please read this Policy carefully to understand what we do with your Personal Data and what your rights are.
Sometimes, we may act as the processor of personal data collected by/on behalf of our affiliates and/or their clients. If you have entered into a separate agreement with us or our affiliates, such as a data processing agreement, that agreement shall control, and only those terms within this Policy that do not conflict with such separate agreement shall apply.
INFORMATION WE COLLECT FROM YOU
We collect Personal Data from you when you visit our Site, submit Personal Data to us through our Site, request information via our Site, or otherwise interact with our social media channels or communicate with us (including through our web form or chat feature, by phone, email or video communication, at events or webinars, or otherwise).
We may also receive Personal Data about you from third parties, for example from businesses we are considering investing in or acquiring, and their shareholders and advisers, in connection with a prospective or completed transaction.
The types of your Personal Data we collect depends on the choices you make and the features you use, and may include the following categories:
- Contact information: First name, last name, company name, email address, telephone number and postal address.
- Marketing information: Details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
- Enquiry information: The content of your comments, questions or complaints, and any additional information you provide so that we can respond to you.
- Application information: Information contained in your resume, cover letter or similar employment-related materials, and other information you provide in connection with a job application.
- Survey and research information: Your responses and other information you provide if you choose to participate in our surveys or research. We will provide you with specific information about our practices for each survey or research project before collecting any information from you.
- Transaction information: Where we assess or complete an investment in, or acquisition of, a business, information about that business’s employees (such as name, compensation and other job-related information), shareholders (such as name, address and shareholdings) and, to a limited extent, customers.
INFORMATION WE COLLECT AUTOMATICALLY
As with most websites, when you visit our Sites, we automatically receive and collect information from your device. This information may include the following:
- Device Information – information about your device, such as the operating system, browser type, hardware, system version, the Internet Protocol (IP) address, device ID, and device language.
- Website Actions – specific actions that you take when you use our Sites, including but not limited to the pages and screens that you view or visit, search terms that you enter, how you interact with our Sites. Including, the time, frequency, connection, type, and duration of your use of our Sites.
- Communications – information regarding your interactions with email messages, for example whether you opened clicked on or forwarded the email.
- Cookies, Pixel and Web Beacons – please see Cookies, Pixels and Web Beacons section below.
HOW WE USE PERSONAL DATA
In general, we collect Personal Data from you so that we can operate our business, our Sites, as well as provide information that you request from us. This includes the following uses and purposes:
- Provide, operate and maintain our Sites.
- Provide you with technical and other support related to our Sites.
- Communicate with you.
- Respond to your comments, questions and complaints, and improve our customer service.
- Send you updates, marketing communication and information about Beacon and our services.
- Organise events and webinars, communicate with you about them and invite you to future events and webinars.
- Conduct research and analysis, monitor and analyse trends and usage of our Sites.
- Enhance or improve user experience, our business, and our Sites, including the safety and security thereof.
- Personalise our Sites to you by, for example, customising content that you see.
- Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Sites.
- Take action as necessary to comply with any applicable law, regulation, court order, legal process, or governmental request.
- Enforce our contracts and applicable terms, including investigation of potential violations thereof.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property or safety of Beacon, our users, or the public as required or permitted by law.
If you choose to participate in our surveys or research, we use the information you provide in aggregated, de-identified form to help us understand our users, enhance our Sites, and for auditing and data analytics.
In connection with a prospective or completed investment in, or acquisition of, a business, we use transaction information to evaluate and determine whether to proceed with, or complete, the transaction.
In addition to the above, in connection with an application or related inquiry for a job at Beacon, we may use Personal Data you provide to us about yourself in connection with the application or inquiry (such as Personal Data contained in a resume, cover letter, or similar employment-related materials) for the purpose of reviewing your suitability for the position, managing the application process and responding to your application for current and future career opportunities at Beacon.
AGGREGATE INFORMATION
We may use de-identified, anonymised or aggregated Personal Data which cannot be used to identify an individual for our internal business purposes and development of the Sites and services.
HOW WE SHARE PERSONAL DATA
- Our Affiliates - We may disclose Personal Data to our affiliated entities and group companies. As allowed by applicable law, those entities may market their products and services to you, but their use of your Personal Data will remain subject to this Policy.
- Service Providers – We use third parties to assist us with operating our business and providing our Sites, such as our third-party technology vendors that help us maintain our Sites, and partners that assist us with our marketing and communication.
- As Directed by You and With Your Consent – Except as otherwise provided in this Policy, we share information with companies, organisations or individuals outside of Beacon only at your direction or when we have your consent to do so.
- Regulatory Disclosures and Legal Proceedings – We may share information with third-party companies, organisations, governmental authorities, or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (a) comply with applicable law, regulation, legal process or an enforceable governmental request, such as a search warrant or court order, (b) investigate a breach of an agreement or a contravention of law, (c) detect, prevent or otherwise address fraud, security or technical issues, (d) establish, exercise or defend legal claims, or (e) protect against actual or suspected loss or harm to the rights, property or safety of Beacon, our users, other persons or the public.
- Sale or Merger – We may share information about you as part of a merger or acquisition. If Beacon is involved in a merger, asset sale, financing, liquidation or bankruptcy, acquisition of all or some portion of our business by another company, or a corporate reorganisation or other change in corporate control, we may share your Personal Data with that company before and after the transaction closes. In such a case, unless permitted or otherwise directed by applicable law, your Personal Data would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.
COOKIES, PIXELS AND WEB BEACONS
Cookies are small text files that are placed on your hard drive by a web server when you access our Sites. Cookies may either be first party cookies (placed by us) or third-party cookies (placed by third party vendors). You can learn more about cookies and how they work at www.allaboutcookies.org. Pixels and Web beacons are small pieces of code that are placed by third party vendors, on Sites or email for several purposes.
Beacon uses cookies, pixels, web beacons and similar tools (collectively “Cookies”), to collect information about how people use our Sites and improve visitors’ experience. Cookies are used for more than advertising and analytics, they also provide our Sites with necessary, functional, and performance duties.
You can manage your Cookie preferences through the cookie manager on our Sites. You can also set your browser to notify you when you receive a cookie or to refuse certain cookies. If you do not accept certain Cookies your website or browsing experience may be affected. At the present time our Sites do not respond to “Do Not Track” signals or similar mechanisms.
LAWFUL BASES
We will only collect and process Personal Data about you where we have a lawful basis or legal ground to do so. Our processing of your Personal Data is either based on consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you) or our legitimate interests, including improving our Sites. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and, where we rely on legitimate interests, you have the right to object.
If you have any questions about the lawful bases we use to collect and process your Personal Data, please contact us at the email address as listed at the end of this Policy.
YOUR RIGHTS AND PRIVACY CHOICES
Depending on your jurisdiction you may have the right to:
- To know if we are collecting, using or sharing your information and to request access to this information.
- To request that we correct your information if it is inaccurate or incomplete.
- To ask us to erase your information if
- Your information is no longer necessary for the purposes for which it was collected, used or shared.
- You withdraw the consent on which the collection, use or sharing is based.
- You object to the collection, use or sharing and there is no overriding legitimate interest for continuing the collection, use or sharing.
- You object to the collection, use or sharing of your information for direct marketing purposes.
- Your information was unlawfully collected, used or shared.
- Your information has to be erased in order to comply with a legal obligation.
- Your information was collected in order to offer online services to children.
- To obtain from us a restriction on the collection, use or sharing of your information if
- You contest the accuracy of your information.
- You have objected to the collection, use or sharing based on legitimate interest and we are considering whether our or a third party’s legitimate interest ground overrides your interest.
- The collection, use or sharing is unlawful, and you oppose erasure and request the use be restricted instead.
- We no longer need your information, but you require your information to establish, exercise or defend a legal claim.
- To be able to take with you the information you provided to us and to transmit that information to another organisation where our collection, use or sharing of that information is carried out by automated means and is based on your consent or the performance of a contract.
- To object to collection, use or sharing based on the purposes of legitimate interest or performance of a legal task, direct marketing and scientific/historical research and statistics.
- Not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.
- To opt out of the sale of your Personal Data, the sharing of your Personal Data for cross-context behavioural advertising, and targeted advertising.
- To limit our use and disclosure of your Sensitive Personal Data to the purposes permitted by applicable law.
- Not to receive discriminatory or retaliatory treatment for exercising any of these rights, and to appeal our decision on your request.
- To be informed of, and to submit observations on, any decision about you based exclusively on automated processing of your Personal Data, and to request that we cease disseminating your Personal Data or de-index any link giving access to it where the dissemination contravenes the law or a court order.
- To use an authorised agent to submit a request on your behalf. Before we act on a request, we may ask you to verify your identity and, where an agent submits the request, to confirm that you have authorised the agent to act for you.
- To lodge a complaint with your state Attorney General, the Office of the Privacy Commissioner of Canada, or your other relevant regulator or supervisory authority.
You can exercise your rights by emailing us at privacy@beaconholdings.com. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law.
You can opt out of our marketing communications at any time, and you have the right to be removed from our email list at any time, using the opt-out link provided in our outreach. If you opt-out, we may still send you non-promotional communications, such as those about your account or about our ongoing business relations. Beacon does not endorse or take responsibility for content on other websites accessed from links on our Sites.
INTERNATIONAL TRANSFER
If you decide to use our Sites, or share your Personal Data with us, please note that your Personal Data may be transferred across international borders to third countries outside of the country in which you are located. To ensure adequate protection for your information, we enter into data processing agreements with our suppliers, including the ones who process your Personal Data outside of the country in which you are located, including but not limited to Canada, the UK or an EU member state. When necessary, we also utilize approved transfer mechanisms (such as adequacy decisions, UK International Data Transfer Addendum or standard contractual clauses) for the transfer of Personal Data and will make details of the transfer mechanisms available upon request.
CHILDREN
Our Sites are not directed at children under age 18, and we do not knowingly collect information from children under age 18. If you are under age 18, please do not attempt to use our Sites or send any information about yourself to us. If you are the parent of a child under the age of 18, and you believe he or she has shared information with us, please contact us at privacy@beaconholdings.com so that we can remove such information from our systems.
SECURITY OF YOUR INFORMATION
We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your Personal Data. We restrict access to Personal Data to employees and authorised service providers who need it to perform their duties. We also take certain measures to enhance the security of our Sites. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
RETENTION OF PERSONAL DATA
We retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, as described in this Policy, and to operate our business, or until you withdraw your consent, unless a longer retention period is required to comply with our legal obligations. Where Personal Data is no longer required or you have withdrawn your consent, we will delete, anonymise, or aggregate the Personal Data.
THIRD PARTY WEBSITES AND SERVICES
Our Sites may contain links to other websites and services operated by third parties. These third-party websites and services may collect information about you if you click on a link or visit those websites or services and may automatically record information about your browsing behaviour. Your interactions with these features and third parties are governed by the privacy policy of the third party, not by this Policy.
CHANGES TO THIS POLICY
We may make changes to this Policy from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our Sites so that you will be aware of any changes. Changes to this Policy take effect from the date of publication, unless stated otherwise.
CONTACT US
For the purposes of this Policy, the Data Controller is Beacon Acquisition Corp. If you have any comments, questions, concerns, or suggestions about Policy, or about our privacy practices in general, please contact our Privacy Officer via email at privacy@beaconholdings.com.