Shaftesbury Inc., together with our affiliates and subsidiaries, including Shaftesbury Tech Inc.(collectively, “Shaftesbury”, “we”, “us” and “our”) is committed to protecting your Personal Information (as defined below) by ensuring that your Personal Information is treated with care and is not used or disclosed in ways to which you have not consented.
This privacy policy (“Privacy Policy”) explains the ways in which we collect, use and disclose your Personal Information. It applies to any Personal Information that is collected by us, whether it is collected over the telephone, in writing, or electronically – including via the Shaftesbury website at shaftesbury.ca (the “Website”), the Shaftesbury WebStore at store.shaftesbury.ca (the “WebStore”), when you enter a Shaftesbury contest, or when you download, install, access or use a Shaftesbury mobile app (each, the “App”) and any other digital platform on which this Privacy Policy appears. Each of the Website, the WebStore, the App or other digital platform on which this Privacy Policy appears may be referred to as a “Platform” or collectively, the “Platforms” in this Privacy Policy. Unless otherwise indicated, all aspects of this Privacy Policy applies to each of our Platforms.
We will only use your Personal Information in accordance with this Privacy Policy, unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive and used for limited purposes as described in this Privacy Policy or at the time of collection.
Please read this Privacy Policy carefully to understand our policies and practices for collecting, using, disclosing, processing, storing and deleting your information. By providing us with your Personal Information and using our Platform, you accept this Privacy Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Platform or otherwise provide your Personal Information to us.
We may update our Privacy Policy from time to time and will post any changes we make on this page. If we make material changes to how we treat Personal Information, we will post a notice on the homepage of the Platform and email notice of the change to registered users of our Platforms. We include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this page to check for any changes. By continuing to use the Platform or provide your Personal Information to us after we make changes to our Privacy Policy, you indicate that you accept and consent to such changes.
What is Personal Information?
Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual. This includes information that we can reasonably use on its own, or with other information we have, to directly or indirectly identify an individual. Personal Information generally does not include business contact information, including your name, title, or business contact information.
Information that no longer allows a person to be directly identified is referred to as “De-identified Information”. When you use our Platforms, we may collect De-identified Information such as demographic information, statistical or aggregated information, or anonymized app or game use information. We may also derive De-identified Information from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific App feature. Any De-identified Information within Shaftesbury’s control will not be used by us, either alone or with other information, to directly or indirectly identify a specific individual to whom the information belongs.
What Information Do We Collect?
A) Personal Information You Voluntarily Provide to Us
We collect Personal Information when you directly provide it to us, such as when you meet with us in person, enter a contest, or when you phone us with an inquiry. If there is sign-up for marketing communications, we may ask for your contact information such as your name and email address. We may also collect Personal Information if you choose to disclose it in your email correspondence with us.
In addition, we collect information you choose to provide to us via our Platforms as described below.
Website
We do not generally collect Personal Information of individuals using the Website. We do collect the business contact information (i.e., name, position name or title, company, work address, work email address and work telephone number) (collectively or individually, the “Business Contact Information”) of those individuals seeking Media Access to the Website, as described in the Terms of Use for the Website.https://shaftesbury.ca/terms-of-use/Business Contact Information is not typically considered Personal Information under privacy law.
Personal Information is collected by us via the Website only when you directly provide it to us, such as when you provide us with your contact information, send us a question or comment, enter a contest we are running, or sign up to one of our mailing lists.
WebStore
When you make a purchase or attempt to make a purchase through the WebStore, we collect certain Personal Information from you, including your name, billing address, shipping address, payment information (including credit card numbers, PayPal or Google Pay information), email address and phone number (collectively or individually, “Order Information”).
AppsPlease note that we do not currently collect any Personal Information about you when you download or use our Apps, however should this change in the future, you will have the choice of opting in to provide this information. In the future, with your consent, we may collect certain Personal Information in connection with your use of the App when you provide it to us during your direct interactions with us, for example, by:
filling in forms when subscribing to our service, posting material, and/or requesting further services;
entering a contest or promotion sponsored by us;
responding to a survey we might ask you to complete for research or other purposes;
reporting a problem with the App;
corresponding with us through emails, texts, and other electronic communications sent through or in connection with the App; or
carrying out transactions using the App and their order fulfillment.
The types of Personal Information that we may collect include: your name, mailing address, email address, telephone number, user name or other similar identifier, your financial information, billing and account information for in-App purchases as well of the details of those transactions, and any other identifier we may use to contact you (collectively or individually, “App Personal Information”).
B) Technical Information that is Automatically Collected
When you visit any of our Platforms, we automatically collect the following information, which we refer to as “Technical Information”. Technical Information is generally De-identified Information, but if we can or do use your Technical Information to identify you, including by sending you targeted advertising (as described below), we treat such Technical Information as Personal Information.
Usage details. We may automatically collect certain details of your access to and use of a Platform, including traffic data, location data, logs and other communication data and resources that you interact with on or through the Platform, such as individual pages or products that you view and what websites or search terms referred you to the Platform. With respect to our game Apps, we may collect usage data on total sessions, unique app launches, main menu impressions, launches and completions of each game level, and app exits.
Device information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, MAC address, operating system, browser type, mobile network information, and the device’s telephone number (where applicable). With respect to our game Apps, we may collect data on average sessions per active device and app units by device and by source.
Stored information and files. The Platform also may, with your authorization, access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location information. If you permit us to identify your location when using the Platform, we will have access to your location and time zone. None of our Platforms collects real-time information about the location of your device. Any location information collected will be anonymized.
The technologies we use for this automatic data collection may include:
Cookies (or mobile cookies). Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies on your browser, visit http://www.allaboutcookies.org. When using an App, it may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you disable browser cookies or refuse to accept mobile cookies, you may be unable to use certain features or access certain parts of the Platform.
Log files. Log files track actions occurring on the Platform, and collect data including your IP address, MAC address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
Web beacons. Small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) permit us, for example, to count users who have visited certain pages and other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Marketing & Advertising Software Development Kits (SDKs): With respect to marketing and advertising on our Apps, we may use integrated SDKs from Facebook and Kochava to track download conversions for advertising campaigns, which will be used by our media agency to optimize our marketing campaigns.
The Technical Information we collect automatically is statistical data and does not include Personal Information. We may maintain it or associate it with Personal Information we collect in other ways (that you provide to us or we receive from third parties in accordance with applicable law). If we use such information to identify you, we will treat it as Personal Information.
If you do not want us to collect this information do not use the Platform or download our App, or delete the App from your device.
C) Google Analytics
Shaftesbury uses Google Analytics to provide statistics about the visitors to our Platforms. Google Analytics uses cookies and other identifiers to collect certain information such as your IP address, your device or browser type, and your activity on our Platforms such as click rates and bounce rates to measure and report statistics about user interactions on our Platforms. Google Analytics collects and analyzes non-personally identifiable information in order to create reports and identify platform trends, without identifying individual visitors. We do not share any Personal Information with Google Analytics. We use the reports provided by Google Analytics to help us improve our Platforms, track the usage of our Platforms and improve our search engine optimization. You can find more information about Google Analytics at the following Google page: https://policies.google.com/technologies/partner-sites. You can opt out of Google Analytics without affecting how you visit our Platforms. For more information on opting-out of Google Analytics across all websites you use, visit this Google page: https://support.google.com/analytics/answer/181881?hl=en&ref_topic=2919631
For What Purposes Do We Collect Information?
Generally, we collect and use Personal Information in order to:
fulfill the purposes for which you provided it or that were described when it was collected, or any other purpose for which you consented;
provide you with information, products, or services that you request from us;
respond to your communications and inquiries;
provide you with marketing material (if we have your consent in accordance with applicable law);
provide you with targeted advertisements or other behavioral marketing (as described below);
meet legal, regulatory and security requirements under applicable laws; and
investigate any violations of, and enforce compliance with, our Terms of Use.
We will notify the individual from whom the Personal Information is collected of the purposes for which we are collecting the information. This notice will be provided at or before the time that we collect the Personal Information. Depending on the way in which Personal Information is collected, this may be done orally or in writing. We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.
We may use both manual and automated systems, such as machine learning and artificial intelligence, to: analyze your Personal Information and Technical Information to improve our Platform; personalize your experience; automate certain aspects of the Platform; aggregate, de-identify or anonymize your information; provide you certain features; and protect the safety and security of our Platform.
In addition to the above, the specific uses of Personal Information collected by our various Platforms are described below.
Website
Business Contact Information collected via the Website will be used or disclosed solely for the purpose of communicating or facilitating communication with the individual in relation to their employment, business or profession. We collect and use Business Contact Information in order to:
verify the professional credentials of those seeking Media Access to the Website and provide such individuals with the Media Password (as described in the Terms of Use for the Website); and
send to media personnel copies of press releases, marketing materials or information about scheduled events, in accordance with applicable law.
WebStore
We use the Order Information that we collect to fulfill any orders placed through the WebStore (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
communicate with you;
screen our orders for potential risk or fraud; and
provide you with information or advertising relating to our products or services (if consistent with the preferences you have shared with us).
Apps
We use Personal Information that we collect about you or that you provide to us via our App, including any Personal Information to:
provide notices about your account/subscription, including expiration and renewal notices;
carry out our obligations and enforce our rights in any contracts with you, including for billing and collection or to comply with legal requirements;
notify you when App updates are available, and of changes to any products or services we offer or provide though it;
improve our App, products or services, or customer relationships and experiences; and
allow you to participate in interactive features, social media, or other features on our App.
Technical Information
Technical Information, such as usage details, helps us to improve our Platform and to deliver a more personalized service, including by helping us to:
estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Platform according to your individual interests;
speed up your searches;
recognize you when you use the Platform;
measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
We also use the Technical Information that we collect to help us screen for potential risk and fraud (in particular, your IP address). We also use Technical Information to improve and optimize our Platform (for example, by generating analytics about how our customers browse and interact with the Platform) and to assess the success of our marketing and advertising campaigns. We use location information we collect to help improve and tailor our App for specific geographic user groups.
Targeted Advertising
We may use the technologies described above under the heading “Technical Information that is Automatically Collected” to collect information about your activities over time and across third-party websites, apps or other online services (i.e., behavioral tracking), so that we can tailor our advertising to you that suits your interests, preferences and usage patterns.
We may use the information we have collected from you to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Third-Party Information Collection:When you download or use the Platform or its content, certain third parties collect information about you or your device. These third parties may include:
Advertisers, ad networks, and ad servers
Analytics companies (see Google Analytics description below)
Your mobile device manufacturer
Your mobile service provider
The third party App provider/vendor.
These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps and other online services. They may use this information to provide you with behavioral advertising or other targeted content. We do not control these third parties’ tracking technologies or how they use them. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
In addition to helping advertisers reach the right people for their products and services, behavioral advertising helps support the Platform so that you can enjoy free content. To learn more about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can also opt-out of targeted advertising by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/?c=3&lang=en (Canadian users) or http://optout.aboutads.info/ (U.S. users). Opting out does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns. Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.
Disclosure of Personal Information
We do not sell our customer lists or other Personal Information. We may disclose Personal Information that we collect as described in this Privacy Policy with your consent for any other purpose we disclose when you provide the information. When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law.
We may disclose De-identified Information, which no longer allows an individual to be directly identified, for study or research purposes or for the production of statistics.
We may disclose your Personal Information in the following circumstances:
Subsidiaries and Affiliates:To our subsidiaries and affiliates for the purposes that you consented to.
Service Providers:To contractors, service providers, technology providers and other third parties we use to support our business, such as analytics and search engine providers that help us optimize and improve our services. We contractually require these third parties to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process Personal Information following the same standards set out in this Privacy Policy.
Email a Friend Feature:If you give us an email address to use the “email a friend” feature, we will transmit the contents of that email and disclose your name and email address to the recipients.
Shopify to Power our WebStore: We use Shopify to power our WebStore — you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
Sale or Business Transaction:According to applicable law, to a buyer or other successor in the event of a proposed and completed merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer or business transaction of some or all of Shaftesbury ’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties, in which Personal Information held by Shaftesbury about our customers and users is among the assets transferred.
Law Enforcement: To comply with any court order, law, or legal process, including to respond to any government or regulatory request (for example, in response to a court order, subpoena, search warrant or other lawful request for information we receive), according to applicable law.
Enforce our Rights: To enforce our rights arising from any contracts between you and us, and, if applicable, for billing and collection.
Protect our Rights: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shaftesbury, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.
Personal Information of Minors
We do not knowingly track, collect, use or disclose the Personal Information of minors (i.e., anyone under the age of 18), without the consent of a parent or legal guardian. However, we cannot always determine the age of persons who access and use our Platform.
If you are under 13, unless you have the consent of your parent or guardian, do not use or provide any information on the Platform or on or through any of its features/register on the Apps, make any purchases through the WebStore or Apps, use any of the interactive or public comment features of the App, or provide any information about yourself to us, including your name, address, telephone number, email address, or any user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental/guardian consent, we will delete that information.
If you believe that a minor has provided us with his/her data without parental or guardian consent, we encourage the parent or legal guardian to contact us at info@shaftesbury.ca to have this information removed from our records.
Security, Retention & Disposal of Personal Information
Security
The security of your Personal Information is very important to us. We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education.
The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping it confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards, which any user can view.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through the Platform. This risk is inherent in all Internet dealings.
Retention & Disposal
Except as otherwise permitted or required by applicable law, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For purchase orders made through the WebStore, we will maintain your Order Information for our records for a period not to exceed seven years, unless you ask us to delete this information.
Note that we will retain Personal Information to the extent necessary: (a) to send you marketing communications in accordance with your marketing preferences (which you can change at any time as set out below under “Your Privacy Preferences”); and (b) for our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us), to exercise, establish or defend legal claims, and to protect against fraudulent or abusive activity on our Platforms.
When your Personal Information is no longer required, we will make all reasonable efforts to ensure all electronic and hard copies of such information are securely destroyed or anonymized. However, where your information has been provided to third parties for certain purposes, such as payment processing, those third parties, such as payment processors and financial institutions, may retain the information according to their own retention and privacy policies.
Under some circumstances we may anonymize your Personal Information so that at all times it is reasonable to expect in the circumstances that it irreversibly no longer allows you to be identified directly or indirectly. We reserve the right to use such anonymized information for any serious and legitimate purpose without further notice to you or your consent.
Transfer of Personal Information
Your Personal Information may be transferred to, processed and/or stored in a foreign jurisdiction outside of the jurisdiction in which it was originally collected. For example, we may use a third party marketing company for the purpose of issuing promotional material, whose servers are located outside of Canada. As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction. Whenever we engage a non-Canadian service provider, we require that its privacy and security standards comply with this Privacy Policy and applicable Canadian laws. You can obtain more information about our policies and practices with respect to the use of non-Canadian service providers by contacting us as described below under the “Contact Us” heading.
Links to Other Platforms
Our Platform may provide links or references to websites, mobile applications or other platforms operated by third parties. These third party platforms are not governed by this Privacy Policy but by other privacy policies that may differ from ours. This Privacy Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties. In visiting any third party platforms, whether linked to this Platform or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party platform or any content on such platform. We encourage you to review the privacy policies of each platform visited before using them or disclosing any Personal Information to third parties.
Your Privacy Rights
You have certain rights with respect to your Personal Information that we collect and process, as described below. To exercise any of your privacy rights, please contact us as set out below under the “Contact Us” heading.
Accessing & Correcting Your Personal Information
It is important that the Personal Information we hold about you is accurate and current. We will not update your Personal Information unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information. Please keep us informed if your Personal Information changes.
By law, you have the right to request access to and to correct the Personal Information that we hold about you. If you want to review, verify or correct your Personal Information you may contact our Privacy Officer (see “Contact Us”, below) or send us an email at info@shaftesbury.ca. We will respond to requests within 30 days. We may request specific information from you to help us confirm your identity. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices and applicable law. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Withdrawing Your Consent
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at info@shaftesbury.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
Your Privacy Preferences
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following controls over your information:
Cookies: For more information about cookies, and how to disable cookies on your browser, visit http://www.allaboutcookies.org. When using an App, it may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you disable browser cookies or refuse to accept mobile cookies, you may be unable to use certain features or access certain parts of the Platform.
Google Analytics: You can opt out of Google Analytics without affecting how you visit our Platforms. For more information on opting-out of Google Analytics across all websites you use, visit this Google page:
Targeted Advertising: You can opt-out of targeted advertising by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/?c=3&lang=en (Canadian users) or http://optout.aboutads.info/ (U.S. users). Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using the opt-out tool created by the Digital Advertising Alliance. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.Marketing Communications: If you are receiving our marketing communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g. email) you receive or by contacting us as set out below under the “Contact Us” heading. Please note that if you unsubscribe from marketing communications, we may still send you transactional emails or emails about your account and/or purchases (where applicable) or use of our Platform.
Contact Us
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer, who is ultimately accountable for the handling of such Personal Information and for ensuring that the principles described in this Privacy Policy are being complied with. If you would like to exercise your privacy rights or preferences or if you have any questions or complaints about our privacy policies or practices, please contact our Privacy Officer as set out below. Since email communications are not always secure, please do not include sensitive information in your emails to us.
Privacy Officer
18 Logan Avenue, Toronto, Ontario M4M 2M8
Tel: (416) 363-1411
Email: info@Shaftesbury.ca