1. WHAT PERSONAL INFORMATION DO WE COLLECT?
Depending on your use of the Services, we may collect your Personal Information, including but not limited to your name, contact information, e-mail address, location, postal address, social media accounts, survey feedback, demographic information, and information about your mobile and/or computer devices.
2. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Directly from you
Generally, we will obtain the Personal Information that we need directly from you, for example when you use our Services or when you communicate with us.
We may also gather information that is generated by your mobile and/or computer devices (e.g., mobile advertising identifiers, location information and IP address). See Section “How do we provide online advertising?” for more information on this topic.
With a legal basis such as a contractual basis or your consent
The legal basis for collecting and using your Personal Information is typically a contractual basis (i.e., to provide you with the Services) or because you have consented to it. However, we may also rely on other legal grounds, for example, where the processing is necessary for our legitimate interests or for compliance with legal obligations to which we are subject.
Refusal of collection and withdrawal of your consent
You have the right, if you so choose, to refuse the collection, use and disclosure of your Personal Information. You may also, at any time, and subject to reasonable notice and applicable legal or contractual restrictions, withdraw your consent (if any) to the use of your Personal Information in our possession by contacting us. You should be aware, however, that if you choose not to provide us with your Personal Information, this may prevent you, for example, from using the Services, as this information is essential to the provision of the requested services.You may contact us as set forth in the Section “How to contact us?” to address any issue thereof.
3. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
For specific and limited Purposes
We generally collect and uses your Personal Information to:
- Process payment for the Services that you purchase from us, when applicable;
- Communicate with you concerning your account and provide timely customer service when needed;
- Track your location for the purpose of identifying the Services that are currently available to you;
- Provide you with the Services, respond to and perform your requests for the Services, including delivering the Services you have purchased;
- Offer you product upgrades, and other Services;
- Authenticate the users of the Services;
- Provide you with advertising while using the Services or third-party services including social media;
- Recommend your content based on your use of the Services; and
- Administer the surveys that you have agreed to complete
(collectively, the “Purposes”).
To send you the Messages
If you have consented to receive such information, we may send newsletters, electronic messages, news, updates, contests, special offers and/or other written communications (the “Messages”) to you about the Services, and/or about products and/or services of our partners and licensors. Separate Services and lines of business may send separate Messages. You may opt-out of receiving the Messages as set forth in the Section “How to contact us?”, or through the Preference Center accessible via the Messages footer. However, we may continue to send you Messages to inform you about available upgrades or critical technical service issues relating to a Service that you requested or purchased, or to provide you with important information on your account.
For secondary purposes
We may also aggregate and anonymize Personal Information that you have provided to create aggregate statistical data which we may use to improve the Services, train machine learning algorithms, or share with our third-party partners including advertising partners. Such statistical data does not include any Personal Information.
4. DO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?
We do not rent nor sell any of your Personal Information to third parties and will not share it with third parties without your consent, unless it is necessary to do so by law or for the Purposes as set forth below.
With our employees
In the course of their work, our employees may need to access your Personal Information, for example, when you contact us or request support. Their access is limited to what is necessary to perform their duties.
With strategic partners
We may share your Personal Information with our partners and licensors to the extent that such disclosure is required for the Purposes. We may use third parties to facilitate our business, such as payment processors, hosting services providers, contractors for sending out e-mail updates about us and the Services or for providing customer support services. In connection with these business operations, our service providers may have access to your Personal Information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing of any Personal Information, we implement reasonable contractual and technical protections in order for such third parties to keep all Personal Information they process strictly confidential. Please note that these third parties may be located in other countries than your location in which case appropriate measures are taken by us as set forth below in the Section “Where is your Personal Information stored and transferred?”.
When required by applicable laws
We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform with the law; (b) comply with the order of a competent judicial authority in any jurisdiction; (c) comply with legal process served on us; (d) protect and defend our rights or property; (e) enforce or verify your compliance with any part of the agreements that you have entered into with us, if any; (f) prevent fraud or other illegal activity perpetrated through the Services; or (g) act in urgent circumstances to protect the personal safety of users of the Services or the public at large.
During business transfers
We may share your Personal Information without your permission when our operations require it (in the event of a merger, acquisition, bankruptcy or sale of assets, for example). As part of this kind of event, we may also share some or all of your Personal Information to the relevant third-party (or its advisors) as part of a due diligence process.
For other purposes with your consent
Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific instances where additional terms apply and, through these, we make clear that specific third parties process your Personal Information.
5. THIRD-PARTY SERVICES AND PLATFORMS
Links to third-party platforms
Use of reCAPTCHA
6. HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?
We will retain your Personal Information only for as long as necessary to fulfill the Purposes for which it was collected, or as required for our legitimate interests, or to comply with applicable legal, tax or regulatory requirements. After such time, any Personal Information held by us will be destroyed, deleted, or made anonymous. If you would like more information on this subject, we invite you to contact us as set forth in the Section “How to contact us?”.
7. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
With necessary and appropriate security measures
We strive to apply appropriate precautions to protect your Personal Information. We use physical, electronic, and procedural safeguards that comply with applicable regulations to protect your Personal Information.
Increase your level of privacy
Our software may include the opportunity to disable certain software features to increase your level of privacy. However, certain technical information (e.g., zip code) may be automatically transmitted between networked servers to authenticate access to the Services, enable their delivery, or optimize your media delivery experience.
Except as otherwise provided for a specific Service, the Services are only available for individuals aged 13 years or older. We do not knowingly collect, hold, use or divulge any Personal Information from children under the age of 13, unless a parent or legal guardian has consented to it. If you believe that Personal Information has been collected from children under the age of 13 without your prior consent, you may contact us as set forth in the Section “How to contact us?”.
Strictly necessary Cookies
These Cookies are necessary for the Services to function and cannot be switched off in our systems. Strictly necessary cookies must be present for the Services to provide basic functions and could include signing in, adding items to a cart, or e-billing. They allow for a user to navigate back and forth between pages without losing their previous actions from the same session.
If you have consented to their use, we and/or our third-party partners may also use non-essential Cookies in connection with the Services and the Messages, including the following:
- Functional Cookies. These Cookies enable the Services to provide enhanced functionality and personalisation. If you have consented to their use, functional Cookies allow the Services to remember the preferences and choices that you make including your username, region, and language.
- Advertising Cookies. If you have consented to their use, we use advertising Cookies to gather information from you on your devices to display advertisements to you based on relevant topics that may be of interest to you. Also, our partners may use these Cookies to determine whether our advertisements were displayed to you and whether you interacted with them. In such cases, our partners share data with us, including statistics about the performance of our ads. If you want more information about how to manage and/or disable Advertising Cookies, visit http://www.youronlinechoices.com/ and http://www.youronlinechoices.com/. You can also refuse the use of such Cookies by following the instructions listed below.
- Analytic Cookies. We use analytic Cookies to understand traffic patterns on the Services, to help measure and improve the effectiveness of the Messages and to determine whether such messages have been opened and links clicked on. These Cookies are used for statistical purposes only. All information these Cookies collect is aggregated and anonymous. To opt out of being tracked by Google Analytics, visit http://tools.google.com/dlpage/gaoptout. You can also refuse the use of analytic Cookies by following the instructions listed below.
How to manage Cookies
Except for strictly necessary Cookies, we will only place Cookies on your devices if you consent to it, and such Cookies will be kept for a maximum period of thirteen (13) months from when they are placed on your devices. At the end of this period, your consent will be required again.
Cookies can be managed and/or disabled through your browser’s Cookie settings, mobile device’s advertising settings and, in the case of the Messages, through the Preference Center. Social media Cookies (“plugins”) can also be managed by consulting the following networks’ policies:
- Facebook: https://www.facebook.com/policies/cookies/
- LinkedIn: https://fr.linkedin.com/legal/cookie-policy
- Twitter: https://support.twitter.com/articles/20171379
- Instagram: https://www.facebook.com/policies/cookies/
If you want more information about how to manage and/or disable non-essential Cookies, please visit http://www.allaboutcookies.org/manage-cookies/, and http://optout.aboutads.info/?c=2&lang=EN.
9. HOW DO WE PROVIDE ONLINE ADVERTISING?
Depending on the preferences that you have expressed in your mobile devices, we may, together with our advertising partners, also use your mobile advertising identifier to target and measure the effectiveness of their advertising campaigns. In iOS, this identifier is called “IDFA” (ID for Advertising); in Android (Google Play), this identifier is called “AAID” (Android Advertising ID). You can access and reset your mobile advertising identifier or limit its use through the settings on your mobile devices’ operating system.
In no event will we permit advertising directed at children where it has actual knowledge that the user is under the age of 13. To learn more about our advertising practices, please contact us as set forth in the Section “How to contact us?”.
Do Not Track
Web browsers can transmit Do Not Track (“DNT”) signals that indicate that a user does not wish to have his/her activity tracked over time and across websites. Currently, no universally accepted standard exists for how to interpret such signals, although work to create consensus is ongoing. Accordingly, and because we do not track its users over time and across third-party websites, we do not respond to such DNT signals.
10. WHERE IS YOUR PERSONAL INFORMATION STORED AND TRANSFERRED?
Your Personal Information may be held by us in locations other than your province, territory, state, or country of residence, including in Canada (including in the provinces of Quebec and Ontario), the United States and/or the United Kingdom. We may also subcontract processing to or share your Personal Information with third parties located elsewhere, including locations other than your province, territory, state, or country of residence. In such case, we will ensure that your Personal Information is transferred to countries that have received an adequacy decision from the competent authority, or that your Personal Information is adequately protected by appropriate technical, organizational, contractual, or other lawful means. If you would like to obtain more information on these security measures, please contact us as set forth in the Section “How to contact us?”.
11. WHAT ARE YOUR RIGHTS?
Depending on applicable laws, you might have the right to have your Personal Information deleted, the right to obtain access to, or rectification of your Personal Information, the right to withdraw your consent (if any), the right not to be discriminated against, the right to object to the use of your Personal Information by us, or the right to receive a copy of all Personal Information that hawse have about you in a structured, commonly used and machine-readable format. To exercise any of these rights (to the extent available), please contact us as set forth in the Section “How to contact us?”.
12. HOW TO CONTACT US?
If you have questions about the privacy aspects of the Services or the Messages, would like to know more about our legitimate interests, make a complaint or exercise any of the rights made available to you according to applicable laws, please do so through the “Contact Us” section or link on the Services, when such link is available, or please contact our Data Protection Officer as follows:
Last update: July 23, 2021.