Privacy Policy

General.  Personal Data that we may collect through your use of the Services includes, without limitation:

1. information that you provide to us when you use the Services (e.g., name, address and email);

2. information about how you use the Services (e.g., your length of visits to our website, and the time and frequency of your visits to our website); and

3. information about your computer or mobile device, such as your Internet protocol (IP) address, device ID, browser and operating system type, resolution of your screen, language settings in your browser, referring URLs, and other technical information.

Collection through Services.  We may collect Personal Data from you and any devices that you use when you:

1. use our Services (e.g., through our use of cookies on our website, by you entering a form on our website, or by you otherwise contacting us);

2. communicate with us; or

3. subscribe to any mailing lists.

Cookies.  We may use cookies and similar technologies to track and analyze user activity in order to improve our Services and improve your experience. A cookie is a tiny element of data sent to your browser from a website. The cookie is stored on your hard drive so that your computer or other device may be recognized while you interact with the website.

Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. Your computer also provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Services if you block or disable our cookies. For more information about cookies, please see: https://www.allaboutcookies.org.

Web Analytics.  We may use web analytics services (e.g., Google Analytics) in order to better understand the user experience on our website, including without limitation:

1. how you reached our website;

2. the website you came from;

3. how long you stayed on our website;

4. what pages you looked at;

5. how many pages you looked at;

6. what buttons you clicked;

7. what browser you are using; and

8. what device you are using.

Any use of analytics services by us will result in analytics providers collecting your Personal Data when you access and use our website. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your device identifier, site usage information, and related information about you.

If you do not wish to participate in web analytics, you may be able to download an opt-out browser add-on. Your web browser may also allow you to set a "Do Not Track" signal when you use online services. To learn more about "Do Not Track" signals, visit http://www.allaboutdnt.com. You may also contact us at the "Contact Us" section below regarding any questions about web analytics services that we may use.

Third Party Data.  We may also obtain Personal Data from third parties. We protect such personal Data according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data and applicable laws.

General.  We will process your Personal Data in accordance with the Personal Information Protection Act (British Columbia), and/or any other applicable laws with respect to protecting personal information, including without limitation, the Personal Information Protection and Electronic Documents Act (Canada). We will not process your Personal Data without your consent, unless we are permitted or required to do so by applicable law. Your consent may be express or implied. The type of consent we may rely on in processing your Personal Data will vary based on your reasonable expectations, the sensitivity of your Personal Data, and the circumstances surrounding the collection of your Personal Data. Express consent is when you willingly agree (e.g., orally, in writing, or electronic agreement) to the processing of your Personal Data for particular purposes. Implied consent is when: (i) you do not expressly give consent, but you rather volunteer Personal Data for obvious purposes that a reasonable person would consider appropriate in the circumstances; or (ii) you are given notice and a reasonable opportunity to opt-out of your Personal Data being processed for specified purposes, and you do not opt-out.

European Union.  For individuals to whom the General Data Protection Regulation ("GDPR") applies, we may process your Personal Data on the following grounds, in addition to any other grounds that may be available pursuant to applicable law:

1. Consent.  Where you have given us consent through a statement or clear affirmative action agreeing to the processing of your Personal Data. For instance, by submitting your Personal Data on a form on our website for a specified purpose.

2. Contract.  Where processing of Personal Data is necessary to perform a contract to which you are a party with us, or which you have agreed to enter with us.

3. Legal Obligation.  To comply with a legal obligation to which we are subject.

4. Legitimate Interests.  Where the processing of Personal Data is based on our legitimate interests, provided that these do not override your own interests and fundamental rights. We have legitimate interests in the following:

   1. to properly operate and deliver our Services to you;

   2. to understand how users engage with our Services;

   3. to improve our Services;

   4. to market our Services; and

   5. to provide customer service, including but not limited to, responding to inquiries and feedback.

General.  When we disclose your Personal Data to third parties, we take reasonable measures to ensure that these third parties implement appropriate technical and organizational measures in accordance with applicable privacy and data protection laws. We minimize the amount of Personal Data we disclose to what is directly relevant and necessary to accomplish the specified purpose.

Provision of Services.  We may disclose Personal Data as is necessary to provide our Services (including any features thereof) to you, including without limitation, by disclosing Personal Data to third party service providers in order to help us achieve the Purposes. For example, we may use third party service providers to help us: (i) analyze usage of our Services; (ii) track the effectiveness of our marketing strategies and communications; (iii) assist with the prevention, detection and investigation of potentially illegal acts and security breaches; and (iv) collect and process error and crash reports and store data. These third parties are authorized to use your Personal Data only as necessary to provide these services to us.

Corporate Transactions.  We may also disclose or transfer your Personal Data to affiliates or third parties in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, subject in each case to customary confidentiality agreements.

Legal Disclosure.  We may disclose Personal Data if we reasonably believe disclosure is in accordance with or required by any applicable law. This includes the disclosure of Personal Data where necessary for the establishment, exercise, or defense of legal claims, or as otherwise permitted by applicable law. We will have no liability associated with any such disclosures made in good faith.

International Transfer and Storage.  Your Personal Data may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using our Services and otherwise providing us your Personal Data, you consent to the transfer of your Personal Data to countries outside of your country of residence, which may have different data protection rules than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. If applicable, we will comply with the GDPR requirements providing adequate protection for the transfer of Personal Data from the European Economic Area to third country.

General.  You have certain rights relating to your Personal Data, subject to applicable law in each instance:

1. Right to be Informed. To know how your Personal Data is collected, how it is used, and how it is disclosed and stored. This further includes:

   1. Right to Withdraw Consent.  To withdraw your consent to the processing of your Personal Data at any time. Please be advised that withdrawing your consent to the processing of Personal Data may impact the provision of Services. For further information on this, please contact our Privacy Officer as provided in the "Contact Us" section below.

   2. Right to Make a Complaint.  To make a complaint about the processing of your Personal Data.

2. Right to Access.  To receive a copy of your Personal Data.

3. Right to Rectification.  To request correction of your Personal Data.

European Union.  If you are an individual to whom the GDPR applies, then you have the following additional rights relating to your Personal Data, subject to applicable law in each instance:

1. Right to Erasure. To request the deletion of Personal Data when: (A) you believe it is no longer necessary for the purposes collected; (B) you withdraw your consent or object to the processing of your Personal Data; or (C) your Personal Data was unlawfully processed.

2. Right to Restriction of Processing. To restrict the processing of Personal Data if you dispute its accuracy or object to its processing.

3. Right to Portability. To request that your Personal Data be transferred to another organization.

4. Right to Information about Automated Decision Making. To receive information about the basis of any automatic decision making (e.g., algorithms).

5. Right not to be Subject to Automated Decision Making. To not be subject to decisions based solely on automated processing, unless this is necessary pursuant to a contract between us.

6. Right to Object to Processing Activities. To object to the processing of your Personal Data based on our legitimate interests.

If you want to learn more about any rights under the GDPR, you can visit the European Commission's page on Data Protection at https://ec.europa.eu/info/law/law-topic/data-protection_en.

California Residents.  This section applies to our collection and use of "Personal Information", as defined under the California Consumer Privacy Act (2018), as amended (the "CCPA"), if you are a resident of California. As used in the CCPA, "Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

1. Your Rights.  As a resident of California, you have certain rights with respect to your Personal Information, subject to applicable law in each instance:

   1. Right to Know.  To request information on the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business and/or commercial purposes for which such Personal Information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business and/or commercial purposes, as well as the categories of third parties to whom disclosure was made in the twelve (12) months preceding your request for your Personal Information.

   2. Right to Delete.  To request us to delete Personal Information that we collected from you.

   3. Right to Opt-Out.  To opt-out of the "sale" of your Personal Information to third parties. Subject to exceptions set out in the CCPA, a "sale" for the purposes of the CCPA means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating, of Personal Information to a third-party for monetary or other valuable consideration. For the purposes of this Section 9(c), the terms "sell," "selling," "sale," or "sold," have the meaning ascribed in the CCPA.

   4. Right to Non-Discrimination.  To not receive discriminatory treatment when you exercise your California privacy rights (e.g., denial of goods or services, provision of a different level, quality or price for goods or services). However, notwithstanding the foregoing, different service levels and prices may be provided if such difference is reasonably related to the value provided by the Personal Information.

2. Handling of Personal Information.  The following table sets out the categories of Personal Information collected, disclosed and "sold" (as such term is defined above) by the Company during the twelve (12) months preceding the ‘Last Updated' date of this Privacy Policy:

Exercising Your Rights.  If you would like to exercise your any of your Personal Data rights, please refer to our "Contact Us" section below. When doing so, please tell us which right you wish to exercise and provide us with contact information to direct our response. Response procedures may vary depending on the laws applicable to you. Your use of the Services may be affected depending on the nature of the rights you seek to exercise.

Subject to applicable law: (i) we may verify your identity before fulfilling requests to exercise any rights; and (ii) we may request additional information if we cannot initially verify your identity, or if we require such additional information in order to properly assess your request. Any Personal Data you disclose to us for purposes of verifying your identity and/or exercising your rights will solely be used for the purpose of verification and processing of your request.