Privacy Policy
Skyline Clean Energy Asset Management Inc., Skyline’s Clean Energy Fund, Skyline Clean Energy GP Inc., and each of their respective subsidiaries (“we”, “us”) are committed to safeguarding the Personal Information you entrust to us. This privacy policy will inform you about the Personal Information we process and how we process it.
We process your Personal Information in accordance with applicable privacy legislation, which includes the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and provincial legislation deemed substantially similar to PIPEDA (privacy legislation applicable to the private sector in British Columbia, Alberta, and Quebec).
1. Scope
This privacy policy applies to the Personal Information of the landlords we work with and their tenants (where applicable), as well as employee information we gather for the purpose of assessing a business transaction and reaching an agreement, any partners we work with that provide us personal information, and our investors and potential investors. Further, it applies to Personal Information shared by our service providers and processed by us. “Processing” Personal Information means collecting, using, and/or disclosing it.
- If you are an investor, please note that, in addition to this privacy policy, Skyline Wealth Management’s privacy policy will be applicable to you as we employ their services to Process investor data, see https://www.skylinewealthmanagement.ca/privacy-policy/
- If you are a job applicant, see https://www.skylinegroupofcompanies.ca/privacy-policy/
- For Skyline Living’s privacy policy, see https://www.skylineliving.ca/en/privacy-policy/
- For SkyDev’s privacy policy, see https://www.skydev.ca/privacy-policy/
- For Skyline Commercial Management Inc., Skyline Retail Asset Management Inc., Skyline Commercial Asset Management Inc., Skyline Industrial REIT and Skyline Retail REIT’s privacy policy, see https://www.skylineretailreit.ca/privacy-policy/
- For Skyline Clean Energy Asset Management Inc.'s privacy policy, see https://www.skylineenergy.ca/privacy-policy/
- For Skyline Mortgage Financing’s privacy policy, see https://www.skylinemortgage.ca/privacy-policy/
- If you are a Skyline employee, please refer to the internal privacy policy.
Personal Information encompasses information about identifiable individuals. Beyond standard elements considered Personal Information (like your name, email, address, phone number, etc.), what makes you identifiable is sharing different pieces of data that, alone or in conjunction with other data, allow us to unequivocally identify you. By way of illustration, your name without further data elements like an address or postal code is unlikely to be categorized as Personal Information because other people may have the same name, as such we may not be able to identify you with certainty.
2. Processing of Personal Information
2.1 Legal Bases
We process your Personal Information based on:
- Your provision of consent (where applicable),
- Your contract with us,
- exceptions to the consent requirement as outlined in the law; or
- in line with legal or regulatory requirements or guidance.
2.2. Collection of Personal Information
We collect Personal Information necessary to provide information, products, or services of your choice. With limited exceptions, we collect your Personal Information directly from you through our website, emails, phone, fax, physical forms, internal systems, marketing campaigns or lists, etcetera. From time to time, we utilize publicly accessible information where necessary to verify information provided by you.
When you disclose to us the Personal Information of another person for use in connection with our products or services, for example, a beneficiary or a family contact, you must be authorized to entrust that Personal Information to us.
2.3. Processing Purposes
We process your Personal Information for the following purposes and, where applicable, for secondary purposes that are compatible (meaning reasonable, necessary, and proportionate) with the ones listed below:
- Assessing and closing commercial transactions, such as the acquisition and disposition of assets.
- Initiating, establishing, and managing a business relationship and the termination of the relationship.
- Managing our portfolio, which includes solar assets, leases, and biogas facilities.
- Managing service providers, partners, and relevant agreements.
- Managing payments.
- Overseeing our debt collection processes.
- Conducting marketing activities.
- Overseeing compliance with legal and regulatory obligations on an ongoing basis.
- Assisting Skyline entities with their sustainability initiatives, for example, by installing and monitoring solar panels and EV chargers.
- Additionally, we process your Personal Information for business purposes like record-keeping, crisis management, data governance, analyses of our products and services, risk analysis, and for conducting data analytics in general, as well as in connection to the oversight and management of the security and resilience of our networks, systems, and physical premises.
2.4. Processing Activities, Profiling and Tracking
In line with the Processing of your Personal Information for the purposes listed above, we conduct different sets of tasks (“Processing Activities”) that are required to provide you information, products, and services. Those Processing Activities dictate the Personal Information we collect, use, and disclose.
The following table highlights some of our Processing Activities and the categories of Personal Information we process or may process (depending on the context) pursuant to each Activity.
Note that Processing Activities and Personal Information collected, used, and disclosed may change occasionally.
TRANSACTION MANAGEMENT
Personal Information is disclosed for the assessment of the relevant asset, facility or entity. This may include Personal Information of employees, such as their employment agreements, employee history and payment records, government-issued IDs of company executives, and Personal Information contained in rent rolls, if any. Furthermore, we process Personal Information required to conduct additional due diligence processes such as credit checks or reviews of insurance, credit information and/or credit information of guarantors.
ASSET & FACILITY MANAGEMENT
- Personal Information provided by vendors acting as sole proprietors.
- Personal Information of landlords, partners, shareholders, and related parties, in connection with the administration of the relevant contract and any service requests including, for example, tax filing information and ethnicity information.
Other Information of Relevance
- The Processing Activities identified above require communication and sharing of Personal Information within the Skyline Group of Companies. For example, the financial component of your business relationship with us requires sharing Personal Information with Skyline Group of Companies’ finance department.
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PROFILING: Profiling means the collection and use of Personal Information to assess specific characteristics of an individual, in particular to analyze that person’s work performance, economic situation, health, personal preferences, interests, or behavior.
If you are an investor or potential investor, we use your Personal Information through Skyline Wealth to understand your marketing preferences and document your investor profile. Compliance with some legal or regulatory requirements may result in you being profiled; that is the case when complying with Anti-Money Laundering and Know Your Client requirements, where we build your profile with information obtained from trusted sources to establish whether a business relationship or specific transaction should proceed. Note that we do not automate the profiling of individuals; there is significant human oversight of this process.
For clarity, your profile is created with information you share regarding your risk appetite and additional investment details. This is required for us to understand your needs and ensure that the product or service we offer aligns with your risk preferences.
- TRACKING:
We track the lifecycle of our relationship with you in our database. We also track your user activity to enable our systems to recognize your browser or device and to provide, market, and improve our offerings. To this end, we and our service providers use cookies and similar technologies (pixels and beacons). To learn about cookies, visit https://allaboutcookies.org/.
2.5. Sharing Personal Information
Service Providers: We use service providers for different purposes. We require them to abide by applicable legislation and implement security controls to safeguard your Personal Information. Some of the categories of service providers and partners with whom we may share your Personal Information include the IESO, government institutions, financial institutions, debt collection agencies, marketing management, advertising partners, as well as technology vendors, analytics providers, credit bureaus, consultants, auditors, and record-keeping providers.
In addition to service providers, you have relationships with third parties with whom we need to exchange your Personal Information for processing transactions. Moreover, where you express interest, we will connect you to our partners for the provision of additional products or services, in which case disclosure of Personal Information will be required.
- Other Companies within the Group: If we determine that Processing of Personal Information by another entity within the Skyline Group of Companies would allow us to provide the service or product in a way that guarantees a better user experience for you, or where the expertise required to deliver you products or services lies with another entity within Skyline Group of Companies, we will grant them limited access, on a need-to-know basis, to the Personal Information they require to do so.
- Government Bodies or Authorities, Courts, Police, and Compliance with Legal or Regulatory Obligations: Where required to disclose information per legal or regulatory requirements; asked to comply with an order or similar request, or to collaborate on matters subject to investigation, we will disclose your Personal Information to the extent permitted by law or, where available, in line with applicable case law (like court, tribunal, board, or commission decisions) when no law regulates the order or request. In addition, we will disclose your Personal Information when necessary to comply with legal or regulatory obligations.
- Access Requests by Third Parties: In some cases, third parties submit requests for access to Personal Information which are processed in accordance with parameters provided by the law.
3. Storage of Data, International Transfers and Transfers Outside of Quebec
Your Personal Information may be processed outside of Canada. If you are a Quebec resident, please be advised that your Personal Information is processed outside of Quebec.
Personal Information may be accessed, transferred, or transit through other countries due to the nature of the Internet and based on the hosting location of some of our service providers. Access from other countries may also be required for maintenance, security, or support management.
4. Retention of Personal Information
We will keep your Personal Information for the period required to provide you with products or services and for a more extended period where required or authorized by law, regulation, or guidance.
5. Security
We understand that the security of your Personal Information is essential; because of that, we employ a range of prevention and detection tools and methods to safeguard against the loss, unauthorized access, and unauthorized disclosure of the Personal Information we hold. Additionally, we implement administrative measures, such as contractual provisions, to ensure that the parties we share your Personal Information with are subject to legal and technical requirements to protect it.
6. Your Rights
You are entitled to access and rectify the Personal Information we hold about you. If you are a Quebec resident, you may be entitled to additional rights. To exercise these rights, please use one of the following mechanisms:
- Email: privacy@skylinegrp.ca
- Mail: Please direct your communication to
Martin Castellan
Co-founder, Chief Administrative Officer & Privacy Officer
Attention: Legal - Privacy & Data Security
301 – 5 Douglas Street,
Guelph, ON
N1H 2S8
In connection to the exercise of your rights, we reserve the right to communicate with you to verify your identity and relationship with us, respond to questions you may have during the process, follow up with you and clarify the boundaries of the request where necessary, and to let you know about the progress of your request.
7. Changes to this Privacy Policy
This Privacy Policy is subject to changes as deemed necessary by us.