Last Updated May 25, 2018.
PART A – COLLECTION OF PERSONAL INFORMATION
1. Information You Provide
We collect the personal information that you provide to us, which may include, but is not limited to:
- basic personal information, including your name and contact information;
- information about third parties with whom you are sharing content using our Services;
- information collected in a dispute resolution if applicable; and
- any feedback you provide regarding our products and services.
Collection of this personal information is necessary for us in order to execute upon your preferences.
2. Information We Collect Automatically
PART B – USE OF YOUR INFORMATION
1. What We Do with Your Information
Information you provide to us is stored on our servers in Canada. To accomplish any of the purposes listed below, we may combine personal information, Automatic Information, and non-personal information collected through your use of our Services. This information may be used in a variety of ways including, but not limited to:
to connect you to members of our team;
- to enforce our Terms;
- to prevent, detect and investigate potentially prohibited or illegal activities, fraud and security breaches;
- to collect data on our Services;
- to improve our Services;
- personalize your experience while using our Services; and
- to provide you with any additional information you may request.
Except as set forth above an, your personal information will not be provided to any other users of our Services.
All of our third-party partners (e.g., Stripe, for payment processing) are required to be in compliance with data protection requirements, as applicable in the EU.
With your consent and/or as permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone or text messages. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that our marketing practices are in compliance with applicable laws.
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).
2. Automatic Information
We also reserve the right to use personal information and Automatic Information as set forth in our Terms, if applicable.
3. If Our Business Changes Hands
4. Your Data Related Rights
Under the GDPR, you have certain rights in relation to your data, which include the right to:
Request a copy of the data that we have about you.
- Request that we provide you with an electronic copy of the personal data that you have provided us with (data portability).
- Request that we correct the data that we have about you.
- Request that we restrict our use of your data.
- Request to erase your data.
- Notify us that you object to particular ways in which we are using your personal data.
- File a complaint with the governmental authority in your country which is mandated with regulating data privacy matters.
5. Legal Basis for Our Use of Your Data [NTD: is this similar to Part B (1)]
- The processing of your data is necessary for us to provide you with our Services in accordance with the contractual relationship between you and us;
- The processing of your data is required for us to comply with our legal obligations, including maintaining records which we may legally be required to keep;
- The processing of your data is required in connection with our legitimate interests, or those of a third party recipient of your personal data;
- The processing of your data is done according to an express consent that you gave us.
PART C – DISCLOSURE OF YOUR INFORMATION1. To Help with Business Operations
We may disclose your information to our representatives, affiliates, suppliers or other third parties with which we do business (our “Business Partners”) when it is deemed necessary for our business operations. For example, from time to time, we may engage companies or individuals for certain services on our behalf including, without limitation, conducting audits, performing legal services, processing credit card payments, collecting feedback, and providing customer service. Our Business Partners and any other third-party service providers will only have incidental access to personal information to the extent required to perform their services. They are prohibited from the use of your personal information for any purpose other than assisting with our business operations.
2. Safety and Security
We may disclose your information as necessary to protect the safety or security of users of our Services, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law.
3. Legal Requirement
We may disclose your information, if required, to supervisory authorities, tax authorities, police and other regulatory authorities as required by law or in response to a subpoena, court order, or other legally valid inquiry or order;
- to either prevent/minimize a criminal offence or to protect a person’s rights and personal and or financial health; and
- an intellectual property rights owners or such party’s representative if a room ad may be considered, in good faith by such owner, to violate owner’s rights; provided however the owner will be required to enter into an agreement to limit the use of the personal information provided only for purposes of the possible violation of an intellectual property right.
You may withdraw your consent for the collection, use, storage or disclosure of your personal information at any time by contacting us at the coordinates provided below. Your withdrawal of consent is not retroactive, since we may already have used your information for the purposes described here; it will be applied on a go-forward basis.
PART D – PROTECTING, RETAINING AND STORING YOUR PERSONAL INFORMATION
1. Protection. We have put in place appropriate and industry-accepted technical and security measures in order to prevent your data from being lost or used without proper authorization. That said, we cannot guarantee that information provided to us through our Services will remain private, or that the information you transmit to us over the Internet will not be intercepted.
3. Identification. To help prevent unauthorized access to your personal information you are responsible for keeping the username and password (collectively, “ID”) that you receive upon registration with our Services private and confidential. You are solely responsible for preventing the unauthorized use of your ID.If you suspect that your information has been compromised or that your account has been accessed without your consent, please contact us immediately at [ ].
4. Retention: We may store your personal information for no longer than 3 years from the date of collecting such personal information, or until the agreement which governs your use of the Services is terminated, whichever period may be longer. We will use commercially reasonable efforts to delete your personal information and any other information you may have provided to us in a reasonable time frame.
For security purposes we will continue to store your email address and IP address after the lapse of 3 years. Your email address, as saved on our servers, will be encrypted, and your IP address will be saved in an anonymized form. Marinating your email address and IP address is required, among other things, in order for us to be able to comply with some of the requirements under GDPR, relating to your rights to access, restriction of processing, erasure, correction, objection or portability of your data.
PART E – ELECTRONIC COMMUNICATIONS
Should you submit an inquiry through our Services, or otherwise communicate with us electronically, you consent to us responding to such inquiries electronically. We cannot guarantee that information that we send to or receive from you over the Internet will not be intercepted.
PART F – ACCESSING AND MODIFYING YOUR PERSONAL AND ACCOUNT INFORMATION
We aim to give you effective controls on our use of your data including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
You are under no obligation to provide us with any information. However, we do require certain information in order to be able to provide you with our Services.
Removal of data or withdrawal of consent will limit our ability to provide our Services to you. You request may be subject to a processing fee as allowed under law.
PART H – HOW TO CONTACT US
You can also send a letter to Sprout Studios Inc.,110 James St., Suite 303, St. Catharines, Ontario, Canada, L2R 7E8
In addition, you can contact our EU representative, Robert Nowell at email@example.com
In addition, you can contact our Data Protection Officer, Robert Nowell, at firstname.lastname@example.org
Any questions you can contact email@example.com
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