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PRIVACY POLICY

PRIVACY POLICY

This website is owned and operated by Spafax Canada.

At Spafax Canada Inc. (“Spafax”), we respect your privacy. In the course of our business, Spafax conducts contests and promotions for our third party clients (“Client”). This privacy policy (“Privacy Policy”) summarizes the manner in which we collect, and how we use and disclose, personal information when you enter a contest. This Privacy Policy also describes other important topics relating to your privacy when you provide us with information in the context of a contest.

By entering a Spafax contest that links to this Privacy Policy, (“Contest”), or by choosing to submit personal information to such a Contest or the website on which it appears, you signify your consent to all of the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not enter or submit any personal information to a Contest.

Spafax reserves the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on this site and will indicate at the top of this page the date this Privacy Policy was last amended. Your entry into or provision of personal information to a Contest that links to this Privacy Policy after any such changes constitutes your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.

What Personal Information Spafax Collects for Contests

Personal information is information about an identifiable individual, such as your name, address, telephone number or email address (“Personal Information”). When we administer a Contest, we may collect the Personal Information necessary to operate the contest as described in the Contest rules. For example, we may collect Personal Information when you:

  • Enter a Contest in accordance with its rules, or
  • Contact us in relation to a Contest through e-mail, telephone, mail; or other correspondence.

The Personal Information we may collect may include:

  • Your first and last name;
  • Contact information, such as your address, telephone number, or e-mail address;
  • Any other Personal Information that is requested in the context of a specific Contest, for example, some Contests may ask you to submit content you have created, such as a photo, video, or audio recording, and such content may include or be associated with your Personal Information; or
  • Any other Personal Information that you voluntarily choose to submit to us.
Cookies and How Spafax Collects Information Through Technological Means for Contests

When you visit a Contest that is administered on a website, we may collect information that is automatically sent to us by your web browser or your internet service provider. This information may include your domain name, and your numerical IP address. We may also collect other general and analytical information (such as the type of browser you use, your operating system, the time of your visit, which pages you view, the files you request, and other information regarding the functionality of your device). We use this information to better understand how visitors interact with our Contest websites, to analyze usage and traffic patterns, and to improve our website and those of our Clients. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.

To enhance your experience on our Contest websites, we may use a feature on your Internet browser called a "cookie" and/or other similar devices. Cookies are small files that your web browser places on your computer's hard drive. They are used for a variety of reasons, such as remembering user preferences, tracking click streams, and for load balancing. For example, cookies may be used to facilitate voting and entry limits for particular contests or to recognize registered entrants and their language settings. Information tracked through these mechanisms may include, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; and (iii) the pages of a Contest website a user visits. By using cookies, we can deliver faster more consistent service, and a better experience. Your browser may give you the option to reject cookies. However, setting your browser to reject cookies generally hinders the browser's performance and will adversely affect your experience while using our Contest websites.

How Spafax Uses and Discloses Personal Information for Contests

The Personal Information we collect may be used by Spafax for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. For example, we may use your Personal Information to:

  • Administer a Contest which you have chosen to enter, including without limitation, to verify entries and to select and contact potential winners;
  • For example, and without limitation, some of our Contests may offer you the opportunity to vote as a means to participate in the Contest. When you enter such a Contest we may send you email to remind you to vote;
  • Respond to your questions or inquiries;
  • To improve our Contests, services and websites;
  • To send or allow our Clients to send you informational or promotional communications that you have agreed to receive;
  • To carry out other purposes that are disclosed to you and to which you consent;
  • To carry out any other purpose permitted or required by law.

In certain cases when you enter a Contest, the Personal Information you provide may be disclosed to the Client for whom we run the Contest. For example, if you opt-in to receive promotional emails or other messages from one of our Clients, we will provide that Client with your email address or applicable contact information. In such cases, the Client’s privacy policy, and not this Privacy Policy, will apply to the Client’s use of your Personal Information.

We may transfer your Personal Information to third party service providers that assist us with carrying out these purposes. For example, we may use a contractor to operate our computer systems or websites on our behalf. When Personal Information is transferred to a such a third party service provider, we require that party to use such Personal Information only to carry out the services we have requested, and to provide protection for the Personal Information.

We reserve the right to transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed. We may also use, or disclose your Personal Information to third parties, if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter or (iv) to protect our rights, safety or property. Lastly, we may disclose your Personal Information for any other purpose to which you Consent.

Third Party Services

Our Contests may include functionality that allows certain kinds of interactions between the Contest and a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, you may have an option to use your Facebook, Google or other account provided by a third-party site or application to interact with or enter our Contests. If we offer and you choose to use this functionality to interact with or enter our Contests, the third-party site or application may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your interaction with or entering on our Contest.

In addition, we may provide third-party sites’ interfaces or links on a Contest webpage to facilitate your sending a communication from and/or regarding the Contest. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Spafax does not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Contest websites.

How we Protect Personal Information

The security of your Personal Information is important to us. We protect your Personal Information by maintaining physical, organizational and technological safeguards intended to help protect against unauthorized use, disclosure or access. Personal Information may only be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or other purposes permitted or required by the applicable law. Personal Information we collect is maintained in Montréal, QC.

We retain Personal Information that we collect only as long as reasonably necessary to fulfill the purposes for which it was collected or to meet any legal requirements.

Although we have taken measures to help protect our any Personal Information that we have collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the Personal Information.

Access and Rectification

You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to Spafax and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below. We will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.

Children and Parents

Spafax does not knowingly collect Personal Information from children. If a child has provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.

Third Party Websites

A Contest website may contain links to other third party websites. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from a Contest website to other websites, or references to products, services or publications other than those of Spafax, do not imply the endorsement or approval of such websites, products, services or publications by Spafax.

How to Contact Us

If you have any questions regarding this Privacy Policy, any Personal Information you have submitted to us, or if you would like to:

  • access Personal Information that you have already provided to us so that you can correct or update it, or request that it be deleted;
  • request the deletion of Personal Information regarding your minor child; or
  • report any violation of this Privacy Policy;

Please advise us by contacting our Privacy Officer by writing to 1510—500, rue Saint-Jacques, Montréal, QC, H2Y 1S1.