PRIVACY POLICY
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Last Updated: : April 24, 2018
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This Privacy Policy has been prepared by Crucial Interactive (“we”, “us” or “our”) and sets out the manner in which we collect, use, disclose and otherwise manage personal information. This Privacy Policy outlines out privacy practices in connection with (i) premium content advertising that we may make available on our own behalf or on behalf of our clients through our proprietary Contobox™ technology (“Ad” or “Ads”), and (ii) our website located at crucialinteractive.com and contobox.com (the “Website”) (collectively, our “Services”).
COLLECTION AND USE OF PERSONAL INFORMATION
The term “personal information” means information about an identifiable individual. We may collect personal information when you:
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Request that one of our clients contacts you by providing your contact information through one of our Ads;
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Visit our Website;
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Visit a website that displays one of our Ads;
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Sign-up to receive promotional email or other communications from Crucial Interactive;
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Contact us with a comment, question or complaint.
Requesting to be contacted through one of our Ads: We may collect the personal information you provide, such as your name and email address, for the purpose of fulfilling your request to be contacted on behalf of one of our advertisers.
Visiting our Website: In general, you can visit our Website without telling us who you are or submitting any personal information. We collect the Internet Protocol (“IP”) addresses of visitors to our Website and other information about your visit, such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity, and to monitor and improve our Website.
Viewing or interacting with one of our Ads: Our Ads are displayed through third party websites and apps. When you view or interact with one of our Ads, we collect your IP address, the domain name and URL where our Ad appeared, and certain analytic information about your interaction and engagement with the Ad such as the time we served the Ad to your browser, the length of time and type of interaction(s) you have with one of our Ads (e.g. a mouse click, mouse scroll etc.), how long you viewed a video, and, if you interact with the Ad, your browser type and version. We use this information to optimize the design and delivery of our Ads, and we may also use it for the purposes of delivering tailored Ads to you that may be of interest (also known as “Online Behavioural Advertising” or “OBA”). Crucial Interactive adheres to the Digital Advertising Alliance of Canada’s (“DAAC”) Canadian Self-Regulatory Principles for Online Behavioural Advertising.
Opt-out of OBA from Crucial Interactive: To opt-out of Ads being served by Crucial Interactive to your browser using OBA, visit http://www.contobox.com/optout.php.
Note: Opt-outs are implemented using an opt-out cookie, and the opt-out is consequently browser-specific. If you subsequently clear your cookies, the opt-out cookie will also be cleared (though you are welcome to opt-out again at any time).
Opt-out of OBA from DAAC Members: To opt-out of OBA being served by members of the DAAC in connection with your browser, visit http://youradchoices.ca/choices.
Email and Other Communications: From time to time, we may obtain your consent to send you email and other communications about products, services, promotions or events that may be of interest to you. You can opt-out of receiving our promotional messages by doing one of the following:
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If you have received an email, you can follow the opt-out or "unsubscribe" instructions provided in your email.
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You can always request to be unsubscribed by contacting us through the “Contact” page on our Website or using the contact information set out below.
Contact Us: When you contact us with a comment, question or complaint, you may be asked to provide personal information (such as your name, email address or a phone number) along with any additional information we need to help us promptly answer your question or respond to your comment or complaint. We may also retain this information to assist you in the future and to improve our customer service.
DISCLOSURE OF PERSONAL INFORMATION
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Our policy is that we do not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out herein. We may maintain or process your personal information in the US or other jurisdictions.
If you complete a form contained in one of Ads for the purposes of requesting that one of our client brands contacts you, we will disclose the contact information you provide to our client brand for the purposes of fulfilling your request.
ADDITIONAL INFORMATION ABOUT OUR SERVICES
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Service Provider Arrangements: We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. For example, we may use service providers to host and display our Ads, operate certain of its features, and send email or other communications. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.
Sale of Business: We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Crucial Interactive or as part of a corporate reorganization or stock sale or other change in corporate control.
Legal: Crucial Interactive and our Canadian, US and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable Canadian, US or other law. We may also disclose personal information where necessary for the establishment, exercise or defense of legal claims, or as otherwise permitted by law.
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Cookies: Our Website and Ads may use a technology called “cookies”. A cookie is a tiny element of data that our Website can send to your browser, which is stored on your hard drive so we may later be able to recognize your computer or other device while you interact with our Ads or our Website. Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. However, if you decide not to accept cookies from our Website or Ads, you may not be able to take advantage of all of their respective features.
We use Google Analytics to help us gather and analyze information about the areas that you visit on the Website to evaluate and improve the customer experience and the convenience of the Website, and to help us evaluate some of the specific information related to your Website visits. To opt-out of Google Analytics’ tracking of your Website visit across all websites, Google makes a tool available that you can install in your browser.
Tracking Tags & Web Beacons: Our Website may also use technologies such as “tracking pixels” and “web beacons”. These technologies allow us to understand which pages you visit on our Website. These tracking tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.
We may also use third parties to serve our advertisements on other websites. These companies may use tracking tags or web beacons to report certain information (but not your name, address, e-mail address or telephone number) about your visits to our Website and the websites which advertise and feature links to our Website, in order to measure the effectiveness of our advertisements.
Third party links: Our Services may contain links to other sites that Crucial Interactive does not own or operate. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, our policy is that we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.
Children: Our Services are not intended for children under 13 and therefore we do not intend to collect personal information from children under the age of 13. If you are 13 or older, but under the age of majority in the jurisdiction in which you live, you must have your parent or legal guardian’s permission to use our Services.
SECURITY OF PERSONAL INFORMATION
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We have implemented measures designed to help protect personal information in our custody and control. We maintain reasonable administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements.
ACCESS TO YOUR PERSONAL INFORMATION
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You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in personal information we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
CHANGES TO THE PRIVACY POLICY
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This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on this Website. If we make material changes to this Privacy Policy, we will notify you by posting a notice on the front page of this Website. We strongly encourage you to please refer to this Privacy Policy for the latest information about our personal information practices.
EUROPEAN ECONOMIC AREA (EEA) GENERAL DATA PROTECTION REGULATION (GDPR)
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To the extent that Crucial Interactive’s activities involve the collection and use of personal information of EEA residents, we are committed to compliance with the GDPR. If you are a resident of the European Economic Area, you may have the following rights with respect of personal information controlled by Crucial Interactive:
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The right to request access to, or to obtain copies of, personal information Crucial Interactive holds about you, which may be subject to a fee specified by applicable law for processing your request. We will respond to your request within a reasonable period, and where Crucial Interactive is a Data Processor with respect to your data, Crucial Interactive may redirect your request to the Data Controller (our client). We may decline a request for access to personal information in circumstances prescribed by applicable privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable or unlawful to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
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The right to ask us to delete any personal information that we hold about you free of charge, unless we are required or permitted to maintain a copy of this data pursuant to applicable law;
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The right to ask us to update and correct any out-of-date or incorrect or inaccurate personal information that we hold about you free of charge. We will take reasonable steps to correct the data so that it is accurate, complete and up-to-date. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable or unlawful to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
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The right to opt out of any marketing communications that we (or any third-party to whom we have disclosed your personal information with your consent) may send you or to withdraw your prior consent or object to any further processing of your personal information;
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The right to request information about any automated decisions made using your personal information that have legal consequences for you or which significantly affect you; and
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The right to lodge a complaint with your local Data Protection Authority concerning our processing of your personal information.
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If you wish to exercise any of the above rights, please contact us at privacy@contobox.com. Before we process any request, we may ask you for certain personal information to verify your identity, and in situations where we are the Data Processor, we may share your request with the Data Controller of your personal information. Where permitted by applicable law, we may reject requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests.
Please contact us if:
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you have any questions or comments about this Privacy Policy,
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you wish to opt-out of marketing messages, or to access, update, or correct inaccuracies in your personal information, or
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you otherwise have a question or complaint about the manner in which we treat your personal information.
Email: privacy@contobox.com
Mail: Privacy Officer c/o Contobox
21 Camden Street, 5th Floor Toronto, Ontario M5V 1V2