Last updated/reviewed: October 21, 2020
To provide the Services, we collect two types of information about our users: personal information (information that can personally identify you such as your name, address, email address, birth date, location, gender, etc.) and non-personal information (information of an anonymous nature that cannot be used to identify or re-identify individuals). We limit our collection to what is needed for the purposes in this policy, or as otherwise stated or implied at the time of collection.
The information we collect falls into three categories: (1) information we collect from you; (2) information we collect when you use our Services; and (3) information we collect from other sources.
When you access our Services as a visitor, registered user or subscriber, we collect and use the personal information, non-personal information and other content, communications and other information you provide when using the Services. Your information is collected when you:
We collect information from you such as:
We may also collect information about the Services you use and how you use them. We do this to ensure that we are offering you the best services in a secure environment, and as part of our efforts to constantly improve your experience. In this process, we may collect and use your personal information relating to your use of GENERATE Services, technical details about your browser and mobile device use and location (e.g., whether you are using a tablet or smartphone to visit our websites),your IP address, the metadata on content you provide, which can indicate things like the date a file was created, and your viewing and usage trends in order to analyze and offer you customized advertising, products and services.
Some of the personal information we may collect, such as payment information, we consider to be sensitive information.
We also collect information that is publicly available, to the extent permitted by applicable law. For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Instagram, Twitter or Google+.
We use your personal and non-personal information so that we can:
You are under no obligation to provide personal information, but your refusal to do so may prevent you from using certain portions or features of our Services.
Access to personal information within GENERATE will be restricted to those individuals who need the information in order to carry out their job duties. Those individuals are trained and instructed to maintain the information in the strictest of confidence and will not provide access to the information to anyone who is not authorized.
All individuals we hire to conduct business on our behalf will be required to respect the provisions of this policy and our procedures. Violations of any part of the contractual agreement may result in termination of the contract.
We work with business partners to provide the Services. For example, we have partners that:
Our partners receive your data if you use their services through our Services, and it becomes subject to their privacy policies.
When you interact with them through our Services, our partners may provide information to us such as:
We require our partners to have the right to collect, use and share your data before providing any data to us.
We don’t sell your personal data to advertisers, and we don’t share information that directly identifies you (such as your name, email address or other contact information) with advertisers unless you give us specific permission. Instead, advertisers can tell us things like the kind of audience they want to see their ads, and we show those ads to people who may be interested. We may provide advertisers with reports about the performance of their ads that help them understand how people are interacting with their content.
Other users provide information when they use our websites. This can sometimes include information about you, such as when others share or comment on a photo of you, send a message to you, or upload, sync or import your contact information.
Wherever possible, we seek a person’s consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied and can be provided directly by the individual or by an authorized representative. Implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to sign up for our newsletter, or a name and telephone number to receive a response to a question implies that we have your consent. When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of the person. When using personal information for a new purpose, we will do our best to document that new purpose and ask for consent again.
Our Privacy Officer will act as the main point of contact for individuals seeking information or who have concerns about our handling of their personal information. If you wish to withdraw your consent for the collection, use or disclosure of your personal information by GENERATE, please contact us any time at firstname.lastname@example.org. Your withdrawal of consent can’t be retroactive, since we may already have used your information for the purposes described here, but it will be applied on a go-forward basis.
Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the electronic message you received or by emailing us at email@example.com.
Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you regarding the products or services we provide to you, or if you contact us with an inquiry.
We make reasonable efforts to ensure that any personal information you provide is maintained in a secure environment. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information, GENERATE cannot warrant the security of any personal information you transmit to us or from our on-line services and cannot be responsible for the theft, destruction or inadvertent disclosure of your personal information. You do so at your own risk. Consequently, GENERATE and any directors, officers, employees, agents, contractors, subcontractors or agents thereof do not represent, warrant or guarantee that your personal information will be protected against misuse, loss or modification, nor do such parties accept liability for the security of a user’s personal information submitted on or in connection with our websites.
GENERATE has implemented and maintains reasonable and appropriate security measures, procedures and practices to protect against the loss and unauthorized access, use, modification, destruction or disclosure of your personal information while it is in our custody or under our control.
We also limit access to your personal information to those employees, contractors and agents who have a business need to know.
You can help protect the security of your personal information as well. For instance, never give out your password, since this is what is used to access your account or registration information. Also remember to log out of your account and close your browser window when you finish using our websites or surfing the internet, so that other people using the same computer won't have access to your information.
GENERATE retains personal information for as long as is necessary for the purpose for which it was collected. When we no longer are required to retain the personal information, we will destroy, erase, or de-identify it. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold. If you want to cancel or delete your account, you may do so in writing at the email or postal address provided in the "Contact Us" section below. We will make every effort to promptly respond to your request. We will retain your information for as long as your account is active or as needed to provide you Services, such as product returns or warranties. If you ask us to delete your account, we generally retain and use your account information only as long as necessary to fulfill a business or law enforcement need.
GENERATE provides you with the means to access, update, edit or delete any account or registration information you may have provided to us at any time on your own by going to the appropriate page in the account or registration section of the relevant Service, and changing or deleting such information as desired.
If you are unsure whether we have a record containing any of your Personal Information and would like to confirm whether or not we do, please send an email to GENERATE indicating all email addresses and social accounts that you may have given us.
Any such access request may be subject to a small statutory fee to meet our costs in providing you with details of the information we hold about you, where permitted by applicable law.
ou also have the right to formally request access or corrections to your personal information under the Personal Information Protection of Electronic Documents Act (“PIPEDA”). GENERATE is required to direct individuals who request formal access or corrections to their personal information to our Privacy Officer. Once we receive a formal request under PIPEDA, our Privacy Officer will respond according to PIPEDA.
If you decide at any time that you do not want to receive any email materials to which you have subscribed, you may choose to unsubscribe to these emails by following the instructions at the end of the message.DISCLOSURE We will only disclose or transfer your personal information to third parties:
Note that we may also use non-personal information to inform our sponsors and advertisers as to the performance of a particular sponsorship (such as a contest) or advertisement. In such case we may disclose to those third-party sponsors and advertisers the overall aggregate demographics available regarding, for example who participated in a contest or who saw and “clicked” on an advertisement. No personal information will be disclosed to these sponsors and advertisers as part of this process, only information in an anonymous, aggregate form will be disclosed in this manner.
We do not intend for our websites or online services to be used by anyone under the age of thirteen (13). If you are under the age of thirteen (13), please do not use our Services, and if you are over the age of thirteen (13) but under the age of majority in the province in which you reside, you should use our Services with the involvement and permission of a parent or legal guardian. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in the "Contact Us" section below.
A “Cookie” is a small text file containing a unique identification number that is transferred (through your browser) from a web site to the hard drive of your computer. The Cookie identifies your browser and will not let a web site know any personal information about you, such as your name and address. Since Cookies are only text files, they cannot run on your computer, search your computer for other information, or transmit any information to anyone.
Certain Services may contain electronic images known as “Web Beacons”, sometimes called single-pixel gifs, that allow GENERATE to count users who have visited those pages and to deliver co-branded services. Web Beacons are not used to access your Personal Information; they are a technique used to compile aggregated statistics about Service usage. Web Beacons collect only a limited set of information including a Cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. Certain Service web pages may also contain Web Beacons placed there by our advertising partners or web analytics service providers to help GENERATE determine the effectiveness of our Internet advertising campaigns.
If you have any comments, questions or complaints about this policy or about how we manage personal information, you may contact our Privacy Officer at : firstname.lastname@example.org
Where an individual is not satisfied with the actions we may have taken to rectify a matter, or with the explanations given, they should be aware of their right to file a complaint under PIPEDA.