Beyond Bars: Revelation Pathways to Skilled Trades and Green Futures

Lead Applicant: Beyond Bars (Non-Profit, https://beyondbars.ca/)

Co-Applicants:

Zeus Demolition (Employer), Believe to Achieve (BTA, Non-Profit), Greenwin Corp. (Employer),

Ontario Association of Demolition Contractors (OADC)

Funding Request: $500,000 In-Kind Contributions: $50,000 (tools, PPE, site access, mentorship) Duration: 18 months (November 2025 – April 2027)

1. Executive Summary

Beyond Bars proposes the Revelation Pathways to Skilled Trades and Green Futures program to train 50+ at-risk youth, migrants, and equity-seeking groups in demolition, green retrofits, and property management. Using the Revelation Education App, Zeus Demolition training sites, and Spider Jones’ podcast (BTA, Order of Ontario), we deliver earn-as-you-learn training, functional English, financial literacy, and energy audit skills. Guided by our taglines—“Using technology is helping people get beyond the bars of where they are at and reach out to get connected” and “To get productive and contributing to their community to build a life as a contributing Canadian. Be part of the greatest country in the world”—the program is hosted on https://beyondbars.ca/ (engagement, podcast, job fairs) and https://communitycontractors.ca/ (labor marketplace). Trainees provide discounted labor ($15-20/hour) on Zeus projects, addressing Ontario’s 9,000 demolition/retrofit shortage and 52,000 green retrofit jobs by 2030. https://energysavingsaudit.ca/en/ supports energy audits, led by our energy director’s net savings expertise. With $500,000 SDF funding and $50,000 in-kind, we target 80% completion, 70% employment (25% green roles), and 20% recidivism reduction, yielding $3-5 ROI per $1 invested. 2. Statement of Need Ontario’s construction sector faces a 9,000-worker demolition/retrofit shortage and 23,200 construction gaps by 2027, driven by 18% retirements and aging infrastructure (40% of buildings >50 years old). The green economy requires 52,000 retrofit jobs by 2030. At-risk youth and migrants (395,000 newcomers in 2025) face 2-3x higher unemployment and 23% recidivism. Condo corps and builders demand energy audits for 10-20% savings. Our program, via beyondbars.ca, communitycontractors.ca, and energysavingsaudit.ca/en, addresses these needs, fostering “contributing Canadians.” 3. Project Objectives Train 50+ participants in demolition/property management (Revelation Demo) and green retrofits/energy audits (Revelation Reno). Achieve 80% completion, 70% employment (25% green roles), 20% recidivism reduction. Equip 80% with functional English (IELTS 5.0 equivalent) and 100% with financial literacy. Train 20 for NRCan Energy Advisor certification. Host 4 job fairs (800+ attendees) via beyondbars.ca, shifting trades perceptions. Ensure 90% app adoption, saving 20% on admin costs. 4. Methodology Phase 1 (Months 1-2): Recruit 50+ via BTA, OINP, app assessments, ESL pre-tests, and financial literacy onboarding. Promote via Spider Jones’ podcast on beyondbars.ca. Phase 2 (Months 2-4): App delivers WHMIS, hazardous materials, ESL (4 hours/week), and financial literacy (budgeting). Phase 3 (Months 4-8): Hands-on training at Zeus sites for Revelation Demo (demolition) and Revelation Reno (retrofits, audits). App tracks compliance. Phase 4 (Months 9-12): Place trainees in labor roles ($15-20/hour) via communitycontractors.ca. Phase 5 (Months 12-18): Track KPIs via app; conduct 10 pilot audits via energysavingsaudit.ca/en. Job Fairs: 4 events (200+ attendees each), promoted on beyondbars.ca (15,000+ X impressions). Delivery: Hybrid (Zeus sites, app-based modules). Taglines: Technology “gets beyond the bars”; training builds “contributing Canadians.” 5. Innovation Revelation Education App: Streamlines training, compliance, and audits, saving 20% on costs. Revelation Demo: Paid demolition training channels 70% to apprenticeships. Revelation Reno: Trains for retrofits/audits, delivering 10-20% savings. Spider Jones’ Podcast: Biweekly on beyondbars.ca, drives 85% satisfaction. Supports: ESL, financial literacy, mental health check-ins reduce dropouts by 15%. 6. Partnerships BTA: Spider Jones (Order of Ontario) provides mentorship, podcast ($10,000 in-kind). Zeus Demolition: Training sites, tools, PPE ($30,000 in-kind). Greenwin Corp.: Property management curriculum, 15,000+ units ($10,000 in-kind). OADC: Placement network for 70% employment. IHSA: Safety training (WHMIS, Working at Heights). Great Life Investment Fund (MIC): Future audit sponsor (2026, per assumed Jupiter Her deck). 7. Outcomes / KPIs 50+ graduates with dual certifications. 80% completion; 70% employed (25% green roles); 20% recidivism drop. 80% ESL proficiency; 100% financial literacy. 20 Energy Advisor certifications; 10 pilot audits. 800+ job fair attendees; 90% positive feedback via beyondbars.ca. 90% app adoption; $500K placement revenue. 8. Budget Category Amount Notes Salaries & Benefits $130,000 Trainers, coordinator, admin Curriculum & Licensing $140,000 App, ESL, financial literacy, audit modules Equipment & Supplies $150,000 Tools, PPE, materials Wraparound Supports $40,000 Transport, childcare, counseling Wage Subsidies/Stipends $25,000 Placements Admin & Overhead $15,000 ≤10% of total Marketing & Outreach $25,000 Job fairs, podcast, X campaigns Evaluation & Reporting $15,000 KPIs, HEQCO assessment Total $500,000 Plus $50,000 in-kind 9. Labour Market Evidence 9,000 demolition/retrofit shortages; 23,200 construction gaps by 2027. 52,000 green retrofit jobs by 2030. 2-3x unemployment for migrants/youth; 23% recidivism. 5.3% property management vacancies. 10-20% energy savings demand. 10. Risk Management Risk Likelihood Impact Mitigation Recruitment Shortfall Medium High Podcast, job fairs, OINP Placement Shortage Low High OADC/LiUNA MOUs, marketplace Dropout Medium Medium ESL, literacy, counseling Budget Overrun Low High 5% reserve, monthly reviews Tech Disruptions Low Medium Offline backups, 24/7 support 11. Sustainability Embed in Zeus pipeline; license app to OADC for 200+ trainees by Year 2 via communitycontractors.ca. Secure Greenwin, LiUNA placements. Generate $500K-$1M from placements/audits; scale with MIC sponsorship. 12. Political & Community Impact Aligns with Ontario’s green economy and equity goals, supporting 100,000 new trades workers. Taglines drive media appeal via beyondbars.ca (15,000+ X impressions). 13. Index of Sources Ontario Construction Secretariat (2025). Natural Resources Canada (2025). Public Safety Canada (2025). Job Bank Canada (2025). NYSERDA (2025). Fieldwire (2025)

Proposal: Zeus Demolition - Fast-Track Demo Pathways Zeus Fast-Track Demo Pathways SDF Training Stream – Round 6 Proposal Funding Request: $500,000 In-Kind Contributions: $50,000 (tools, PPE, site access) Duration: 18 months (November 2025 – April 2027) Lead Applicant: Zeus Demolition (Employer, Private Sector) Co-Applicants: Believe To Achieve (BTA, Non-Profit), Greenwin Corp. (Employer), LiUNA Local 183 (Union), Ontario Association of Demolition Contractors (OADC) 1. Executive Summary Zeus Demolition, a Bowmanville-based leader in safe, sustainable demolition since 2021, proposes the “Zeus Fast-Track Demo Pathways” program to train 50+ at-risk youth, migrants, and equity-seeking groups in demolition, green retrofits, and property management. Hosted on https://communitycontractors.ca/ and https://beyondbars.ca/, our program leverages the Revelation Education App to deliver earn-as-you-learn training, functional English, and financial literacy, guided by our taglines: “Using technology is helping people get beyond the bars of where they are at and reach out to get connected” and “To get productive and contributing to their community to build a life as a contributing Canadian. Be part of the greatest country in the world.” Trainees provide discounted, precision-focused labor on Zeus projects, addressing Ontario’s 9,000-worker demolition/retrofit shortage by 2027 and 23,200 construction gaps. With $500,000 SDF funding and $50,000 in-kind, we target 80% completion, 70% employment (25% in green roles), and 20% recidivism reduction. ROI: $3-5 per $1 invested via labor savings and productivity, aligning with SDF’s workforce resilience, equity, and green economy goals. 2. Statement of Need Ontario’s construction sector faces a 23,200-worker shortage by 2027, including 9,000 in demolition/retrofits, driven by an 18% retirement rate and aging infrastructure (40% of buildings >50 years old). Migrants (395,000 newcomers in 2025) and at-risk youth face 2-3x higher unemployment and 23% recidivism without targeted supports. Our app-driven program, accessible via communitycontractors.ca and beyondbars.ca, breaks barriers (language, financial, social) and fosters community contributions, enabling participants to “build a life as contributing Canadians” in the skilled trades. 3. Project Objectives Train 50+ participants in dual skills (demolition/retrofits, property management). Achieve 80% program completion and 70% employment within 6 months (25% in green roles, 52,000 jobs by 2030). Reduce recidivism by 20% over 12 months via surveys. Equip 80% with functional English (IELTS 5.0 equivalent) and 100% with financial literacy via app. Host 4 mass public hiring events (500+ attendees total) to enhance public perceptions of trades. Ensure 90% app adoption for training and admin efficiency, accessible via beyondbars.ca. 4. Methodology / Program Phases Phase 1 (Months 1-2, Recruitment & Supports): App-driven assessments, ESL pre-tests, and financial literacy onboarding via BTA, OINP, and community networks. Host job fairs promoted on communitycontractors.ca to connect 200+ attendees to trades as “contributing Canadians.” Phase 2 (Months 2-4, Safety Training): App delivers WHMIS, hazardous materials, and ESL modules (4 hours/week, e.g., “demolition safety” vocabulary). Financial literacy begins (budgeting paycheques). Phase 3 (Months 4-8, Skills Training): Hands-on “Revelation-Demo” on Zeus sites, tracked via app for waste diversion and retrofits. Bi-weekly financial literacy (2 hours). Phase 4 (Months 9-12, Paid Placements): Discounted labor ($15-20/hour vs. $25-35 market) with app-generated compliance reports. Phase 5 (Months 12-18, Retention & Evaluation): App tracks KPIs (employment, recidivism, satisfaction) via beyondbars.ca. Delivery: Hybrid (in-person sites, app-based virtual modules). Taglines drive engagement: Technology “gets beyond the bars”; training builds “contributing Canadians.” 5. Innovation Revelation Education App: Hosted on beyondbars.ca, streamlines training, testing, and administration, saving 20% on costs (per Fieldwire benchmarks). Multilingual ESL and analytics ensure inclusivity. Revelation-Demo: Paid demolition exposes trainees to trades, channeling 70% to union apprenticeships. Holistic Approach: ESL, financial literacy, and mass hiring align with OECD’s skills-first model, fostering community integration. 6. Partnerships BTA: Recruitment, mentorship (Spider Jones, Order of Ontario), wraparound supports. Greenwin Corp.: Property management curriculum, site access for 15,000+ units. LiUNA Local 183: Apprenticeship pipelines, in-kind mentorship ($10,000 value). OADC: Contractor network for placements, ensuring 70% employment. IHSA: Safety training for OHSA compliance. 7. Outcomes / KPIs 50+ graduates with dual certifications. 80% completion; 70% employed (25% green roles); 20% recidivism drop. 75% ESL proficiency; 80% financial literacy certification. 200+ job fair attendees/event; 90% positive public feedback on trades via communitycontractors.ca surveys. 90% app usage; 20% admin cost savings; $500K revenue potential from placements. 8. Budget Summary Category Amount Notes Salaries & Benefits $130,000 Trainers, coordinator, admin Curriculum & Licensing $140,000 App, ESL, financial literacy modules Training Equipment & Supplies $150,000 Tools, PPE, materials Wraparound Supports $40,000 Transport, childcare, counseling Wage Subsidies/Stipends $25,000 Placements Admin & Overhead $15,000 ≤10% of total Marketing & Outreach $25,000 Job fairs, X campaigns, website promo Evaluation & Reporting $15,000 KPIs, HEQCO assessment Total $500,000 Plus $50,000 in-kind 9. Labour Market Evidence 9,000 demolition/retrofit shortages; 23,200 construction gaps by 2027 (Ontario Construction Secretariat, 2025). 52,000 green retrofit jobs by 2030 (Natural Resources Canada, 2025). 2-3x higher unemployment for migrants/youth; 23% recidivism (Public Safety Canada, 2025). 5.3% property management vacancies (Job Bank Canada, 2025). 10. Risk Management Risk Likelihood Impact Mitigation Recruitment Shortfall Medium High App-driven job fairs, OINP outreach Placement Shortage Low High OADC/LiUNA MOUs, diverse sectors Participant Dropout Medium Medium ESL, financial literacy, counseling Budget Overrun Low High 5% reserve, monthly reviews Tech/App Disruptions Low Medium Offline backups, 24/7 tech support 11. Sustainability Embed in Zeus’s pipeline; license app/curriculum via communitycontractors.ca to OADC for 200+ trainees by Year 2. Secure hiring commitments from Greenwin, LiUNA. Revenue: $500K-$1M from placements ($15-20/hour labor). 12. Political & Community Impact Aligns with Ontario’s green economy, housing, and equity goals. Taglines drive media appeal: “Using technology to get beyond the bars, connecting communities to build contributing Canadians in the greatest country in the world.” Supports 100,000 new trades workers goal. 13. Index of Sources Ontario Construction Secretariat (2025). 2. Natural Resources Canada (2025). 3. Public Safety Canada (2025). 4. Job Bank Canada (2025). 5. Fieldwire (2025).

Recommended Demolition Trades Offices and Associations in Ontario Ontario Association of Demolition Contractors (OADC) Why Associate?: OADC is the primary voice for demolition contractors in Ontario since 1976, representing ~80 member companies engaged in demolition and abatement, all signatories to the Demolition Collective Agreement with LiUNA. It advocates for clear legislation, provides professional representation, and supports members with safety, WSIB, and labor relations. OADC’s focus on high industry standards aligns with your quality-over-speed model. Value Proposition: Partnering with OADC gives access to their network of 51+ contractors (e.g., Sittler Demolition, GFL Infrastructure), who need skilled workers to address the 9,000-worker demolition/retrofit shortage by 2027. OADC can provide job sites for your trainees’ paid placements, enhancing your 70% employment KPI. Action: Contact OADC (This email address is being protected from spambots. You need JavaScript enabled to view it., 289-485-1017, 70 Leek Crescent, Richmond Hill) to propose co-applying for SDF grants. Offer your program as a recruitment pipeline, with OADC contributing in-kind (e.g., site access valued at $10,000). Highlight ROI: 20-30% labor cost savings. Key Contact: Margaret Taylor, Executive Director (17 years in demolition/abatement), or Anthony Shorkey, CEO. Provincial Building and Construction Trades Council of Ontario (PBCTCO) Why Associate?: PBCTCO represents 150,000 workers across 15 construction craft unions, including LiUNA, which is central to demolition. It focuses on workforce development, apprenticeships, and green initiatives, aligning with your program’s goals of reducing recidivism (20%) and integrating migrants. Value Proposition: PBCTCO can connect you to LiUNA locals (e.g., 183, 506) for apprenticeship pipelines, ensuring your 50+ trainees transition to unionized roles. Their advocacy for equity-seeking groups (via programs like Ontario Building and Construction Tradeswomen) supports your inclusion focus. Action: Pitch PBCTCO (This email address is being protected from spambots. You need JavaScript enabled to view it.) as a co-applicant for SDF, emphasizing your “Revelation-Demo” as a feeder for their 7% GDP-contributing sector. Offer media hook: “Union-powered second chances in green trades.” Key Contact: Executive Director or Workforce Development Officer (via website contact form). Laborers’ International Union of North America (LiUNA) Why Associate?: LiUNA is the largest union for demolition workers, with locals like 183 (Toronto) and 837 (Hamilton-Niagara) representing 4,000+ members. They provide training (e.g., at Cobourg facility) and have collective agreements with OADC members, directly relevant to your Zeus Demolition partnership. Value Proposition: Your program delivers pre-certified candidates (e.g., WHMIS-trained), reducing LiUNA’s onboarding costs by 20-30% amid a 23,200-worker construction shortage. LiUNA’s apprenticeship programs can absorb your 70% employment target, especially for green retrofits (52,000 jobs by 2030). Action: Contact LiUNA Local 183 (This email address is being protected from spambots. You need JavaScript enabled to view it.) and propose a memorandum of understanding (MOU) for SDF co-application. Offer discounted labor ($15-20/hour vs. $25-35 market rate) during placements. Key Contact: Local 183 Business Manager or Training Centre Coordinator. Council of Ontario Construction Associations (COCA) Why Associate?: COCA represents 30+ construction associations, including OADC, advocating for policies that enhance industry growth and sustainability. Their influence on WSIB reforms and construction legislation (e.g., Construction Act) makes them a powerful ally for navigating regulatory challenges. Value Proposition: COCA can endorse your program to its members (e.g., Toronto Construction Association), providing access to 1,800+ firms needing skilled labor. This supports your 80% completion and 70% placement KPIs by connecting trainees to diverse employers. Action: Reach out to COCA (This email address is being protected from spambots. You need JavaScript enabled to view it.) to join as an affiliate or co-applicant, highlighting alignment with their 50-year advocacy for workforce solutions. Key Contact: Ian Cunningham, President, or Advocacy Director. Environmental Abatement Council of Canada (EACC) Why Associate?: EACC focuses on environmental abatement, a key aspect of demolition (e.g., asbestos removal), and provides input to the Ontario Ministry of Labour. Their expertise aligns with your program’s hazardous material training. Value Proposition: EACC can guide compliance with Ontario’s asbestos regulations, ensuring your trainees meet safety standards for 40% of aging buildings requiring abatement. This boosts grant competitiveness by demonstrating regulatory alignment. Action: Contact EACC (This email address is being protected from spambots. You need JavaScript enabled to view it.) to collaborate on curriculum development and site access for abatement training. Key Contact: Executive Director or Technical Committee Chair. Infrastructure Health and Safety Association (IHSA) Why Associate?: IHSA is Ontario’s trusted health and safety resource, providing training for high-risk activities like demolition. Their programs (e.g., Working at Heights) are essential for your trainees. Value Proposition: IHSA certification enhances your program’s credibility, ensuring 100% compliance with OHSA for your 50+ trainees. This addresses 66% of employers reporting safety-related hiring challenges. Action: Partner with IHSA (1-800-263-5024, This email address is being protected from spambots. You need JavaScript enabled to view it.) to deliver safety modules, potentially as an in-kind contribution ($5,000 value). Key Contact: Training Services Coordinator. Additional Entities to Associate With Beyond demolition-specific groups, these organizations can amplify your program’s reach and impact, especially for green retrofits and equity-focused recruitment: Skilled Trades Ontario (STO) Why?: STO oversees apprenticeship registration and certification, critical for channeling your trainees into formal trades (e.g., construction craft worker). They support Ontario’s goal of 100,000 new trades workers. Value Proposition: STO can streamline your 70% apprenticeship placement KPI by approving your program as a recognized training pathway. Their data shows 23,200 construction vacancies by 2027. Action: Engage STO (This email address is being protected from spambots. You need JavaScript enabled to view it.) to align your curriculum with apprenticeship standards. Ontario Immigrant Nominee Program (OINP) Why?: OINP fast-tracks migrants into skilled trades, addressing your goal of integrating 395,000 newcomers (2025 forecast). This supports your migrant recruitment focus. Value Proposition: Reduces 2-3x higher unemployment rates for migrants, ensuring 25% of your trainees enter green retrofit roles. Action: Collaborate with OINP (This email address is being protected from spambots. You need JavaScript enabled to view it.) to recruit via Skilled Trades Stream. BuildForce Canada Why?: Provides labor market forecasts (e.g., 9,000 demolition/retrofit shortages by 2027) and partners with training programs. Value Proposition: Their data strengthens your SDF proposals, justifying need and ROI (15-20% productivity gains). Action: Use BuildForce reports for grant applications; contact (This email address is being protected from spambots. You need JavaScript enabled to view it.) for partnership discussions. Canadian Green Building Council (CAGBC) Why?: Focuses on net-zero retrofits, aligning with your green economy goals and 52,000 retrofit jobs by 2030. Value Proposition: CAGBC’s LEED training can certify your trainees, enhancing employability in high-demand green roles. Action: Partner for curriculum (This email address is being protected from spambots. You need JavaScript enabled to view it.). Strategy for Association Prioritize OADC and LiUNA: Start with OADC for contractor access and LiUNA for unionized demolition workers. Secure MOUs by September 15, 2025, to meet SDF deadlines. Leverage PBCTCO: Gain endorsement for province-wide union outreach, amplifying your 20+ partnership goal. Integrate Safety/Regulatory Partners: Work with IHSA and EACC to ensure compliance, boosting grant competitiveness. Outreach Plan: Week 1-2 (Aug 24-Sep 7): Email tailored proposals (use prior template) to all listed contacts, emphasizing ROI and shortage data. Week 3-4: Host webinars showcasing “Revelation-Demo” (invite Spider Jones for credibility). Week 5: Secure in-kind commitments (e.g., $10,000 in site access from OADC). By Oct 1: Submit via TPON with partners listed. Media Hooks: “Demolition as a gateway to green trades” or “Unions and second chances: Building Ontario’s future.” Budget: Allocate $2,000 for outreach (e.g., mailings, webinars). Why These Associations? Market Justification: Ontario’s 23,200 construction worker shortage (2027) and 5.3% property management vacancy rate demand innovative pipelines like yours. OADC and LiUNA directly address 9,000 demolition-specific gaps. SDF Alignment: Partnerships with OADC, PBCTCO, and IHSA demonstrate “innovative, partnership-driven” solutions, a key SDF criterion. ROI: Partners save 20-30% on labor/hiring costs; your program delivers $3-5 ROI per $1 invested.

Privacy policy The identity and the contact data of the Supplier of products and/or services and the contact data of the data protection officer Identity and the contact data of the Supplier of products and/or services (also referred to in this Privacy Policy the “Supplier of products and/or services” or the”Controller”) Data protection officer: This email address is being protected from spambots. You need JavaScript enabled to view it. 1.1. Contact data of the data protection officer (“DPO”) may be found on the website greatlifeinvestmentfund.com as long as it was (necessary to be) appointed such a data protection officer. Purposes (and related legal basis) of the processing(s) 2.1. The Controller shall process the personal data you (also referred to in this privacy policy ”you” or the “client” or the “data subject”) provided by the client (eg. 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Right of access by the data subject 8.1. The data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in the Regulation and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. 8.2. Where personal data are transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards relating to the transfer. 8.3. The Controller provides a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information are provided in a commonly used electronic form. 8.4. The right to obtain a copy referred to in paragraph 8.3 doesn’t adversely affect the rights and freedoms of others. Right to rectification The data subject has the right to obtain from the Controller without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. Right to erasure (‘right to be forgotten’) 10.1. The data subject has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay, and the Controller has the obligation to erase personal data without undue delay where one of the following grounds applies: (a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (b) the data subject withdraws consent on which the processing is based, where the processing takes place on the basis of the data subject’s consent given for processing personal data for one or more specific purposes and where there is no other legal ground for the processing; (c) the data subject objects to the processing, on grounds relating to his or her particular situation, in accordance with the Regulation, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing for direct marketing purpose and where there is no other legal ground for the processing; (d) the personal data have been unlawfully processed; (e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject; (f) the personal data have been collected in relation to the offer of information society services to a child, in accordance with the Regulation. 10.2. Where the Controller has made the personal data public and is obliged pursuant to paragraph 10.1 to erase the personal data, the Controller, taking account of available technology and the cost of implementation, takes reasonable measures, including technical measures, to inform controllers and processors which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 10.3. Paragraphs 10.1 and 10.2 do not apply to the extent that processing is necessary: (a) for exercising the right of freedom of expression and information; (b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller; (c) for reasons of public interest in the area of public health in accordance with the Regulation; (d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with the Regulation, in so far as the right referred to in paragraph 10.1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or (e) for the establishment, exercise or defence of legal claims. Right to restriction of processing 11.1. The data subject has the right to obtain from the Controller restriction of processing where one of the following applies: (a) the data subject contests the accuracy of the personal data for a period enabling the Controller to verify the accuracy of the personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; (c) the Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; (d) the data subject has objected to processing on grounds relating to his or her particular situation, in accordance with the Regulation, pending the verification whether the legitimate grounds of the Controller override those of the data subject. 11.2. Where processing has been restricted under paragraph 11.1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. 11.3. A data subject who has obtained restriction of processing pursuant to paragraph 11.1 is informed by the Controller before the restriction of processing is lifted. Notification obligation regarding rectification or erasure of personal data or restriction of processing The Controller communicates any rectification or erasure of personal data or restriction of processing carried out in accordance with paragraph 9, paragraph 10.1. and paragraph 11 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller informs the data subject about those recipients if the data subject requests it. Right to data portability 13.1. The data subject has the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the Controller to which the personal data have been provided, where: (a) the processing is based on consent or on a contract; and (b) the processing is carried out by automated means. 13.2. In exercising his or her right to data portability pursuant to paragraph 13.1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible. 13.3. The exercise of the right referred to in paragraph 13.1 of the present Article is without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller. 13.4. The right referred to in paragraph 13.1 does not adversely affect the rights and freedoms of others. Right to object 14.1. At any time, the data subject has the right to object, on grounds relating to his or her particular situation, to processing, for the purpose of the legitimate interests pursued by the Controller or a third party, personal data concerning him or her, including profiling based on those provisions. The Controller no longer processes the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 14.2. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such purpose, which includes profiling to the extent that it is related to such direct marketing. 14.3. Where the data is subject to processing for direct marketing purposes, the personal data is longer processed for such purposes. In case the data subject chooses the processing of personal data for the purpose of direct marketing, separately and without any connection to another action, including by activating any accept button regarding the processing of personal data for the purpose of direct marketing, the latest personal data provided in any way will be processed for direct marketing purpose. 14.4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 14.1. and 14.2. is explicitly brought to the attention of the data subject and presented clearly and separately from any other information. 14.5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 14.6. Where personal data are processed for scientific or historical research purposes or statistical purposes in accordance with the Regulation, the data subject, on grounds relating to his or her particular situation, has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest. Automated individual decision-making, including profiling 15.1. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. 15.2. Paragraph 15.1. does not apply if the decision: (a) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (b) is authorised by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or (c) is based on the data subject's explicit consent. 15.3. In the cases referred to in points (a) and (c) of paragraph 15.2., the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision. Right to lodge a complaint with a supervisory authority 16.1. Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes the Regulation. 16.2. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 17. Right to an effective judicial remedy against a supervisory authority 17.1. Without prejudice to any other administrative or non-judicial remedy, each natural or legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them. 17.2. Without prejudice to any other administrative or non-judicial remedy, each data subject has the right to exercise an effective judicial remedy where the supervisory authority which is competent pursuant to the Regulation does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged pursuant to Article 16. 17.3. Proceedings against a supervisory authority are brought before the courts of the Member State where the supervisory authority is established. 17.4. Where proceedings are brought against a decision of a supervisory authority which was preceded by an opinion or a decision of the Board in the consistency mechanism, the supervisory authority forwards that opinion or decision to the court. Right to an effective judicial remedy against a controller or processor 18.1. Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to the Regulation, each data subject has the right to an effective judicial remedy where he or she considers that his or her rights under the Regulation have been infringed as a result of the processing of his or her personal data in non-compliance with the Regulation. 18.2. Proceedings against a controller or a processor are brought before the courts of the Member State where the Controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the data subject has his or her habitual residence, unless the Controller or processor is a public authority of a Member State acting in the exercise of its public powers. Representation of data subjects 19.1. The data subject has the right to mandate a not-for-profit body, organisation or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects' rights and freedoms with regard to the protection of their personal data to lodge the complaint on his or her behalf, to exercise the rights referred to in Articles 16, 17 and 18 and to exercise the right to receive compensation referred to in the Regulation on his or her behalf where provided for by Member State law. 19.2. Member States may provide that any body, organisation or association referred to in paragraph 19.1 of this Article, independently of a data subject's mandate, has the right to lodge, in that Member State, a complaint with the supervisory authority which is competent pursuant to Article 16 and to exercise the rights referred to in Articles 17 and 18 if it considers that the rights of a data subject under the Regulation have been infringed as a result of the processing. Right to compensation and liability 20.1. Any person who has suffered material or non-material damage as a result of an infringement of the Regulation has the right to receive compensation from the Controller or processor for the damage suffered. 20.2. Any controller involved in processing is liable for the damage caused by processing which infringes this Regulation. The processor is liable for the damage caused by processing only where it has not complied with obligations of the Regulation specifically directed to processors or where it has acted outside or contrary to lawful instructions of the Controller. 20.3. The controller or processor shall be exempt from liability under paragraph 20.2 if it proves that it is not in any way responsible for the event giving rise to the damage. 20.4. Where more than one controller or processor, or both a controller and a processor, are involved in the same processing and where they are, under paragraphs 20.2. and 20.3, responsible for any damage caused by processing, each controller or processor shall be held liable for the entire damage in order to ensure effective compensation of the data subject. 20.5. Where a controller or processor has, in accordance with paragraph 20.4., paid full compensation for the damage suffered, that controller or processor shall be entitled to claim back from the other controllers or processors involved in the same processing that part of the compensation corresponding to their part of responsibility for the damage, in accordance with the conditions set out in paragraph 18.2. 20.6. Court proceedings for exercising the right to receive compensation are brought before the courts competent under the law of the Member State referred to in 18.2. Withdrawal of the consent Where the processing is based on: i) the consent of the data subject given for processing his/her personal data for one or more specific purposes; or ii) the consent of the data subject given for processing certain special personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition to process special personal data may not be lifted by the data subject, the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on the consent before its withdrawal. For the sake of clarity the withdrawal of the consent shall not affect the processing of the personal data based on other legal basis. 22.Cookie Policy [Controller’s webs application may use “cookies.” Cookies are text files containing small amounts of information which are downloaded to your device when you visit and use the web application. Cookies are then sent back to the originating URL on each subsequent visit, or to another URL that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu . For a video about cookies visit www.google.co.uk/ goodtoknow/data-on-the-web/cookies. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests. You may set and/or adjust your (browser) settings and preferences regarding cookies at any time, and you may disable cookies. Disabling them may prevent you from using certain parts/functionalities of the Controller’s web application. We may collect anonymous information, including for statistical or research purposes. We use the following categories on our web based application: Category 1 — Strictly Necessary Cookies These cookies are essential in order to enable you to move around Controller's web application and use its features, such as accessing secure areas. Without these cookies services like shopping baskets or e-billing cannot be provided. Category 2 — Performance Cookies These cookies collect information about how you use the Controller’s web application — for instance, which pages you go to most, and if they get error messages from web pages and/or the web application. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Controller’s website(s) and/or the application works. As 3rd party cookies in this category we use Google Analytics, a service which transmits website traffic data to Google servers in the United States. The reports provided by Google Analytics help us understand website traffic and webpage usage. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. Google Analytics: For more information about Google Analytics cookies, please see Google's help pages and privacy policy: Google's Privacy Policy Google Analytics Help pages Google has developed the Google Analytics opt-out browser add-on; if you want to opt out of Google Analytics, you can download and install the add-on for your web browser here. Category 3 — Functionality Cookies These cookies allow the Controller’s web application to remember choices you make while browsing and/or using the application (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, language and other parts of web pages that you can customize. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non- Controller’s websites. For reliable review of your order status, on-screen on the application, in real-time, and also for easy reordering, your data may be saved on your device, serving a cookie locally. Category 4 - Targeting cookies or advertising cookies These cookies will usually be third-party cookies, although if a user is visiting the advertising network’s own website it is technically possible these could be first party. They will always be persistent but time-limited cookies. These cookies can be associated with services provided by the third party but this is not always the case. These cookies contain a unique key that is able to distinguish individual users’ browsing habits or that can be translated into a set of browsing habits or preferences using information stored elsewhere. Generally speaking, the privacy statement should indicate if the cookie is being used as part of an advertising network. Cookies may also be used to limit the number times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign. Examples include: Cookies placed by advertising networks to collect browsing habits in order to target relevant adverts to the user. The site the user is visiting need not actually be serving adverts, but often this will also be the case. Cookies placed by advertising networks in conjunction with a service implemented by the website to increase functionality, such as commenting on a blog, adding a site to the user’s social network, providing maps or counters of visitors to a site. By default, the web ordering application and its originating website URL is not serving category 4 cookies. However, it may be possible to order online from other websites that frame-in or facilitate access to the online menu and web application. Therefore, please always check the cookie policy of the visited website from which you initiated an online ordering session in order to find out if any category 4 cookies are served and which is the way to opt-out or opt-in for them, as the legal case may be. Processing of your personal data by the Provider as the processor of the suppliers of products and/or services The Provider may also process your personal data as the processor of the supplier of products and/or services, including without limitation for the following purposes, according to those agreed with the suppliers of products and/or services : i) data storage for the suppliers of products and/or services; ii) sending notifications to you regarding the information about confirmation or reject of the order or about the missed orders and about the delivery of your order; iii) sending to you direct marketing communications; iii) collection of the IP addresses in order to be used in case of any litigation and/or fraud regarding the payments; iv) sending your data to different recipients and in different (third) countries, recipients that are processing the personal data for compatible, related and correlated purposes with the purpose of executing the contract you have with the suppliers of products and/or services, namely: delivery, printing, pos billing, loyalty, online payment processing, etc. Miscellaneous 24.1. You have all the rights mentioned in the present Privacy Policy as well as any other rights mentioned by the mandatory legal regulations in force regarding personal data processing. 24.2. Your rights mentioned in the present Privacy Policy can be exercised according with the Regulation and any other applicable legal regulations in force. 24.3. Any requests and/or demands sent by you towards the Controller for exercising any of your rights may be made in writing, by registered letter that will be sent to the headquarter of the Controller and/or online via the contact for or contact email of the Controller as found on the website greatlifeinvestmentfund.com at the email of the DPO, if such DPO exists, and/or by any other ways of communications mentioned in the legal regulations in force. 24.4. The data subject may request, according to the above mentioned ones, and obtain, free of charge, in particular, access to and rectification or erasure of personal data, restriction of the processing of personal data, data portability, and the exercise of the right to object and also the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her but also in relation with the security breach of the personal data. 24.5. The terms used in the present Privacy Policy will have the meaning defined in the Regulations, unless the context otherwise requires or it is otherwise provided herein. 24.6. Except otherwise required by the mandatory legal regulations in force, the Controller reserves the right to update and change the Privacy Policy from time to time without specific notice.