PRIVACY POLICY

*References to “we” in this policy statement include suppliers that we utilize in the compilation, storage, and utilization of data.

 TERMS OF USE

We value your privacy and are committed to protecting your personal information. This Privacy Policy outlines what information we collect from visitors who access or use the Website. It also describes how we retain, use, disclose, and protect your personal information. This Privacy Policy applies to information collected from you through our Website as well as other places where, or means by which, we may collect personal information.

Capitalized terms used in this Privacy Policy that are not defined have the meanings assigned to them in our Terms and Conditions.

1.Definition of Personal Information
Personal information is defined as information that can identify an individual and information about an identifiable individual, which means a person can be identified by the information either directly or in combination with other information.

2. Collection of Personal Information
We collect and process your personal information only when we have a lawful basis to do so. Lawful bases include your consent, the fulfilment of our contractual rights or obligations, complying with applicable law, and the legitimate interests of us or third parties (provided that processing your data for a legitimate interest does not outweigh your rights and freedoms).

Examples of a legitimate interest include (i) analyzing user data to maintain and improve the Website for all users; (ii) providing you with access to our Website; (iii) providing you with up-to-date information about new features of our Website; and (iv) engaging third- party providers to deliver certain features of the Website. You may withdraw your consent or object to a legitimate interest at any time by contacting us at the email address provided below.

We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you use our Website, submit, post, or upload User Content, provide us information on a web form, participate in community discussions, chats, or dispute resolution, or when you otherwise correspond with us regarding our Website.

Personal information that we may collect may include:
Identifying information such as your name, addresses, telephone numbers, email addresses, and IP addresses.

Location data and demographic data such as your gender and age.

Any content that you submit, post, or publish.

Other content that you generate, or that is connected to you as a result of responding to submitted, posted, uploaded, or published content.

Any other information you provide us through a web form, through your participation in community discussions, chats, dispute resolution, or when you otherwise correspond with us regarding our Website, and Additional information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or to verify the information we have collected.

Some of the personal information set out above may be collected by third party service providers. By accessing and using our Website, you understand that your personal information will be transferred to such third parties and will be subject to the privacy policy and practices of such third parties.

We may, from time to time, use an outside ad company to display ads. These third-party ad companies may collect certain personal information. Please note that this Privacy Policy covers the collection of personal information by us only and does not cover the collection of personal information by any third-party ad companies. By accessing and using our Website, you understand that your personal information will be transferred to, and will be subject to the privacy policy and practices of, such third- party ad companies.

3. Use of Personal Information
We use the personal information we collect to:

Provide, improve, and personalize our content and services
Communicate with you about our Website
Provide you customer service
Provide you with personalized advertising and marketing communications
Detect, prevent, mitigate, and investigate fraudulent or illegal activities
Enforce our Terms and Conditions and this Privacy Policy

4. Security and Retention of Personal Information
We retain your personal information as long as it is necessary and relevant for our operations. We may retain your personal information to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions and take other actions permitted or required by applicable laws. After it is no longer necessary for us to retain your personal information, as determined by us in our sole discretion in accordance with applicable laws, we dispose of it in a secure manner according to our data retention and deletion policies.

In recognition of our legal obligations to protect your personal information, we have made arrangements to protect against unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information.

5. Location of Servers
We may create, maintain, and archive information on servers that are not located on our immediate premises and are located in Canada or the USA, where the laws may be deemed by other countries to have inadequate data protection. Please be advised that a foreign government may be able to access data relating to your use of the Website, including your personal information, for lawful access purposes. If you are located outside of Canada or the USA and you continue to use the Website, you consent and continue to consent to us creating, maintaining, and archiving information on servers located on a third party’s premises within Canada and in the USA. We have agreements in place with our affiliates and contractors that include standard contractual clauses to protect your rights with respect to your data.

6. Children Under 16
The Website is intended for general audiences and is not directed to children under 16. We do not knowingly collect personal information from children under the age of 16. If you are under 16, please do not use the Website or submit any personal information through the Website. If you have reason to believe that a child under the age of 16 has provided their personal information to us, please contact us at the email address provided below, and we will delete that information.

7. Disclosure of Personal Information
We do not disclose your personal information to third parties for their marketing and advertising purposes without your explicit consent. There are, however, certain circumstances in which we may share your personal information with certain third parties without further notice to you. This disclosure may be required for us to provide you access to our Website, to comply with our legal obligations, to enforce our Terms and Conditions, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Website. These circumstances include, but are not limited to:

Law Enforcement. We cooperate with government and law enforcement officials or private parties to enforce and comply with applicable laws. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect our property or rights or the property or rights of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable laws.

Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

8. Consent for Collection, Use, and Disclosure
By accessing and using our Website, we consider you to have given us consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. Once this consent has been given, we will continue to collect, use, and disclose personal information for the set out in this Privacy Policy without obtaining further written or verbal consent to do so. We may also collect, use, or disclose personal information about an individual without that individual’s consent as permitted under applicable laws.

9. Cookies
We use cookies and other technologies to passively collect demographic information, personalize your experience on our Website, and monitor advertisements and other activities. Cookies are small files downloaded to your computer to track movements within websites. Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent. However, some areas of our Website will not function properly if you do so.

We may link cookie information to personal information. We use cookies to monitor website usage. We may also use cookies to deliver content specific to your interest. We may, from time to time, use an outside ad company to display ads. These ads may contain cookies. Our ad companies may collect cookies received with banner ads, and we do not have access to this information. Please note that this Privacy Policy covers the use of cookies by us only and does not cover the use of cookies by any advertisers.

10. Remarketing
In addition to using cookies and related technologies as described above, we may also permit certain third-party companies, to help us tailor advertising that we think may be of interest to users. These third-party companies may place or recognize a unique cookie on your computer and may record information to these cookies based on your activities on our Website and on third party websites. These third-party companies may use information about user behavior in order to provide customized advertisements across various services and products. Use of such third- party companies’ services allows us to tailor our marketing to better suit your needs and only display ads that are relevant to you. Please note that this Privacy Policy covers the use of cookies by us only and does not cover the use of cookies by such third-party companies.

11. Third Party Services
From time to time, our Website may also include links to other websites. Certain products or services available on our Website are provided to you in partnership with third parties and may require you to disclose personal information in order to register for and access such products or services. Such products or services shall identify the third-party partners at the point of registration. If you elect to register for such products or services, your personal information will be transferred to such third parties and will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy practices and policies of such third parties and, therefore, you should review the privacy practices and policies of such third parties prior to providing your personal information in connection with such products or services.

12. Withdraw Consent
You can choose not to provide any personal information to us or to withdraw your consent for the collection, use, or disclosure of your personal information for purposes set out in this Privacy Policy. If you choose to do so, you may not have access to all our Website and we might not be able to provide you all of the services and customer support offered to our visitors and users under this Privacy Policy and our Terms and Conditions.

We only send promotional and marketing communications with your consent. If you no longer wish to receive these or other communications from us, send us an email at the email address provided below. You can stop receiving newsletter email communications from us by clicking on the “unsubscribe link” provided in such communications.

13. Requests to Access, Correction, and Deletion
We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it. You can request to view and change your personal information by contacting us. Upon your request, we will change or remove your personal information from view as soon as reasonably possible, based on your activity and in accordance with applicable laws.

Depending on the law that applies where you live, you may have additional rights, such as the right to request that we send your information to another organization of your choice (where technically feasible).

14. Improper Collection and Misuse of Personal Information
Please report any improper collection or misuse of personal information provided on the Website to us at the email address provided below. Depending on the law where you live, you may also have the right to file a complaint with your local data protection authority.

15. Contact
If you have any questions or concerns about our Privacy Policy, or how we have handled your personal information, please contact us in writing at info@sagesolstice.com.