Last updated: November 4, 2021
DATA PROTECTION POLICY
Your privacy and the protection of your personal information are very important to Reflector Entertainment Ltd. (the terms “we”, “us” and “our” refer collectively to “Reflector” together with its subsidiaries and affiliates). In this Data Protection Policy (“Data Protection Policy”, as amended, supplemented, updated or otherwise modified by Reflector from time to time), you will find information about how Reflector collects and uses your personal information and otherwise processes it.
This Data Protection Policy covers all personal information that we collect, use and otherwise process when you interact with the Site or with us. By using the Reflector Site, you acknowledge that such personal information will be handled in accordance with this Data Protection Policy and applicable laws, which may vary depending on your country of residence. If you do not agree with any provision of this Data Protection Policy or any change to it, please do not use the Site.
For residents of the European Union, please note that the processing of your personal information is based on at least one of the following legal bases:
- You have consented to the processing activity;
- The processing activity is necessary to comply with one or more legal obligations;
- The processing activity is necessary for the performance of a service you have requested;
- The processing activity is necessary for the pursuit of one or more of the following legitimate interests, whether they are ours or those of a third party:
- to better understand our customers’ interests and preferences by analyzing, profiling and tracking their behaviour on the Site in order to improve the Site and our products and services in general;
- to provide you with a better customer experience, including by customizing the Site and our products and services (including advertisements and e-mails) to your interests and preferences;
- to ensure the proper functioning and security of the Site.
These processing activities are for the benefit of Reflector and you without compromising or overriding your rights, interests or fundamental freedoms.
Please note that where the processing of your personal information is based on consent, you may withdraw your consent at any time by contacting us (firstname.lastname@example.org).
We reserve the right to modify this Data Protection Policy to adapt it to any legal or technological changes, to adjust it to reflect changes to the Site, or for any other purpose. Any updates to the Data Protection Policy will be posted on this page or otherwise communicated to you if required by applicable law.
HOW DO WE COLLECT INFORMATION?
We collect personal information in the circumstances listed below. In some cases or for some purposes, the provision of your personal information is voluntary. However, in other cases, the provision of your personal information is mandatory and we may not be able to provide you with the requested services or products if you choose not to provide this information.
We collect your personal information in the following circumstances:
- when you create an account on the Site
- when you purchase products or services from Reflector
- when you interact with the digital content of the Site
- when you participate in a contest and/or survey
- when you send us a request or otherwise communicate with us
- when you provide personal information while at an event or at our locations, such as when you connect to the Wi-Fi network
- when you choose to give us permission to access your information from third-party websites (for example, by logging into social media platforms such as Facebook)
Your personal information may also be provided to us by our affiliates and/or business and/or promotional partners, including companies that sell our products worldwide.
WHAT INFORMATION DO WE COLLECT?
In the circumstances listed in the “How do we collect information?” section of this Data Protection Policy, the following information may be collected:
For ease of reference, the term “personal information” is used throughout this Data Protection Policy. For purposes of interpretation, the meaning of “personal information” shall be as provided by the local laws applicable to you. For example, for residents of the European Union, the term “personal information” should be read and understood in this policy as referring to “personal data” as that term is defined in the General Data Protection Regulation. In all cases, we treat as personal information any information that identifies you as an individual. For example, we consider your first name, last name, date of birth, postal address, telephone number, email address, cell phone number, as well as any information that is considered personal information under applicable law, to be personal information.
We collect and process the following categories of personal information:
- identifying information, such as your first name, last name, date of birth, country, email address, gender, username and profile picture, or any other information that may allow us to identify you personally, or to contact you online or by other means;
- login and connection information, such as the email and password you use to log in to your account on the Site, or any other information you choose to link to your account on the Site, including any login information linked to a login partner you choose to use to connect to the Site (e.g. Google ID, Facebook, Twitter, Twitch). If you are having trouble logging into your account, you can contact us at the following e-mail address: supportU9@reflectorentertainment.com. We will need some information (e.g. e-mail address) to verify your identity and provide you with a new password;
- information about your interests and preferences, including, without limitation, preferred media, preferred genres and other generally entertainment-related interests, Reflector product wish lists, and preferred, used and/or owned Reflector products;
- information about your interactions with the digital content of the Site (including, without limitation, your navigational data within the “Chapters” experience, among others);
- any other information you directly and voluntarily provide, including messages you send to us by e-mail or by contacting our customer service and/or legal departments.
Please note that information collected from other websites or from other media is not covered by this Data Protection Policy and that Reflector is not responsible for the content or possible collection of information from websites linked to the Site.
Information collected automatically (“usage data”)
In addition to intentionally collecting information, we may use various technologies, including cookies, to passively or automatically collect information.
In addition, certain usage data may be considered personal information under certain laws, such as IP addresses under applicable laws in the European Union. In cases where we combine your usage data with your personal information, we treat the combined information as personal information under this Data Protection Policy.
Information about another person
If you are providing information on behalf of someone else (for example, a friend or family member), you must ensure that you have their consent to share their personal information with us. By providing this information, you are confirming that you have obtained this consent.
Information about children
We take protection of the privacy and personal data of children very seriously. We do not knowingly collect personal information from children through our Site. If you are a minor under the laws of your country, please do not provide any personal information through the Site without the express consent and involvement of a parent or legal guardian. If you become aware that a minor under the age of 16 has provided us with personal information without the permission of a parent or legal guardian, please contact us and we will take steps to delete it as soon as possible.
To the extent permitted by law, Reflector disclaims any responsibility for any activity that may be carried out by minors on the Site.
HOW DO WE USE YOUR INFORMATION?
We collect and process personal information for the following purposes:
- to manage the process of creating an account on the Site and, more generally, to manage your personal account;
- to provide a personalized experience of the Site and its digital content;
- to provide the services you have requested and/or other products you have purchased through the Site;
- to monitor, analyze, protect, test, improve and update our products and services, improve the performance of the Site, respond to requests regarding the Site, and retain your preferences/parameters on the Site;
- to design, maintain, monitor, analyze, manage, improve, market, promote and provide products and services on our Site;
- to help us conduct transactions and verify your identity in connection with your transactions, if necessary;
- to respond to your inquiries;
- to communicate with you regarding changes to our policies;
- to perform quality assurance, sales, marketing and other business analyses;
- to organize contests or other promotional activities;
- to understand your needs and interests and to provide you with optimal services and personalized advertisements, services and products by profiling, where permitted by applicable law or where you have consented (if your consent is required);
- to send specific information, marketing or promotional communications about Reflector (e.g. offers, discounts, newsletters), where permitted by applicable law or where you have consented (if your consent is required); such communications will be communicated in accordance with applicable law. You may withdraw your consent at any time as described below;
- to detect or prevent fraud, security or technical breaches or comply with applicable laws, regulations, legal processes and other governmental requests.
By registering for the “newsletter”, you expressly consent to the processing of your personal data for the purpose of sending electronic messages. You can withdraw your consent at any time to no longer benefit from this service.
Reflector does not intend to sell or share personal information to third parties for their own commercial purposes. In all cases, personal information is collected and used only for the purposes described in this Data Protection Policy and for no other purpose.
COMMERCIAL PROSPECTING AND PROFILING
When we send or post personalized communications or content, we may use certain techniques that are considered “profiling” (i.e., any form of automated processing of personal information that involves using that information to evaluate certain personal aspects about an individual, including analyzing or predicting an individual’s personal preferences, economic situation, interests, behaviour, location or movements).
Specifically, we may collect personal information about you in the different scenarios mentioned above, centralize this information and analyze it to assess and predict your personal preferences or interests. Based on our analysis, we will send or display communications or content tailored to your specific interests and needs.
Please note that these operations do not have any significant legal effect.
PERSONAL INFORMATION COLLECTED BY THIRD PARTIES
Our Site includes hyperlinks to third-party websites, including for the purpose of processing any requests to purchase Reflector products.
These third parties may have privacy policies that differ from this Data Protection Policy. Information collected and stored by third parties, whether through our Site or their site, remains subject to the policies and practices of those third parties, including the type of information they share with us, the choices you make on your devices or when using their services, and whether they store the information in the United States or elsewhere. For your information, we provide hyperlinks to the privacy policies of third parties who may collect and process data through our Site:
SHARING YOUR PERSONAL INFORMATION
For the purposes described in this Data Protection Policy, we may share your information with members of the Reflector group of companies, as well as with the various third parties listed below (who may be located in Canada or elsewhere):
- Bandai Namco Group companies – Your personal information may be shared with companies of the Bandai Namco Group, including its subsidiaries, parent company or international entities. This allows us to better understand who our consumers are on a global scale, to improve our products based on global trends, needs and interests, and to market our products with locally relevant materials that reflect the reality of the geographic area.
- Promotional partners – Your personal information may be shared with third parties who partner with us to promote our products, present our events, or for other activities, such as contests, games, sweepstakes or other promotions. We collect advertising and analytical information from third parties to support our business initiatives, to improve our services and products, and to better manage our advertising campaigns (including displaying more personalized ads and evaluating their effectiveness).
- Business operation – We reserve the right to transfer your personal information without your express permission in the event of a business operation, such as a bankruptcy, merger, acquisition, reorganization or sale of assets. In doing so, we will use commercially reasonable efforts to ensure that your personal information continues to be used in accordance with this Data Protection Policy.
- Legal or administrative authorities – We may share your personal information with third parties (including legal or administrative authorities, government agencies and jurisdictions) if we believe that disclosure is reasonably necessary to implement this Data Protection Policy, to detect or prevent fraud, security problems or technical problems, or to comply with any applicable law, regulation, legal process or governmental request.
Please note that once your personal information is shared with a third party, the processing of that personal information may become subject to the data protection practices of that third party, unless this Data Protection Policy is expressly stated to apply. We use commercially reasonable efforts to ensure that your personal information is used by our affiliates and such third parties in a manner consistent with this Data Protection Policy. Where we transfer personal data outside the EU to a country that is not designated by the European Commission as providing an adequate level of protection for personal data, transfers will be made under an agreement that covers the obligations imposed by the EU for the transfer of personal data outside the EU, including the standard contractual clauses approved by the European Commission, or under other appropriate safeguards.
STORAGE OF YOUR PERSONAL INFORMATION
Although your personal information is collected and stored on servers located in Canada and the United States, your personal information may be shared with or stored and/or processed by Reflector affiliates or third parties located in other countries. Notwithstanding the location from which we process your personal information, we take steps to protect your personal information in accordance with the terms of this Data Protection Policy, data protection laws and, where required by applicable laws, recognized data transfer mechanisms (such as standard contractual data protection clauses recognized by the European Commission). While we make reasonable efforts to protect your personal information, this protection is subject to the legal requirements and government authorities of the foreign countries in which the information is stored. For example, we may be legally required to disclose personal information to the government authority of a foreign country in which your personal information is stored.
SECURITY OF PERSONAL INFORMATION
We have adopted reasonable security procedures to help protect the personal information you provide to us from theft, loss, unauthorized access, disclosure, copying, use or modification. While we strive to protect your personal information, we cannot guarantee the security of any personal information you disclose or transmit to our Site, and we cannot be held responsible for the loss, theft, unauthorized access, disclosure, copying, use or modification of your personal information, unless such actions result from our gross negligence or unintentional misconduct, unless otherwise provided by law.
In this regard, we have put in place or are in the process of putting in place the following measures:
- SSL technology: Every time the site is accessed via the Internet, Secure Socket Layer (SSL) technology protects personal information through server authentication and data encryption. No personal information will be disclosed until this technology is enabled, which can be confirmed by: i) the site address bar (URL) which should display, depending on the browser, a padlock to the left of the site address (URL); and ii) the URL or browser address bar where the first few characters of the address on that line should display “https” and not “http”.
- Limiting access: Access to personal information is only granted to Reflector’s employees, agents and, where applicable, subcontractors or relevant business partners on a need-to-know basis.
- Secure centre: Your personal information is collected and stored on servers located in Ireland in a data centre. You can find more information about the security of Salesforce and Microsoft Azure systems by visiting the Salesforce “Trust” site (https://trust.salesforce.com/en/) and the Microsoft “Privacy Management Center” available at https://www.microsoft.com/en/trust-center, as of the effective date of this Data Protection Policy.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will retain your personal information only for a period of time commensurate with the purposes of use described in this Data Protection Policy or for a longer period if required or permitted by applicable laws and regulations. The amount, nature and sensitivity of your personal data, the purposes for which we have collected your personal data, the service you expect from us as well as applicable legal requirements have been taken into account in determining the appropriate retention period. For example:
- User account data (including any identification, login and connection data, as well as any information about your interests and preferences and your interactions with the content of the Site, related to that account): The data will be kept for 15 days following the deletion of your account;
- Data relating to subscription to the newsletter: The data will be kept for 15 days following the deletion of your account, if applicable, or for 30 days following the request to unsubscribe, when the user does not have an account;
- Data related to the contact form: The data are kept for 3 months from the receipt of the request;
- Application log data: The data are kept for 30 days from the time they were generated.
Please note that we may retain your personal information for additional periods of time in archival databases, in particular for periods corresponding to the applicable statute of limitations, in order to be able to exercise our rights or defend ourselves in the event of legal proceedings.
UNSUBSCRIBING FROM PROMOTIONAL e-mail
To stop receiving promotional e-mails from us, follow the link at the bottom of the promotional e-mail or contact us (email@example.com).
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
To the extent permitted by applicable law, you may exercise the following rights with respect to the personal information we hold about you:
- The right to confirmation of whether or not personal information is being processed – You have the right to receive confirmation as to whether or not personal information about you is being processed.
- The right to access your personal information – You have the right to access and obtain a copy of the personal information we hold about you (subject to certain conditions).
- The right to correct your personal information – You have the right to have your personal information corrected if it is incorrect or outdated, or to have it completed if it is incomplete. To correct your personal information, please contact us (firstname.lastname@example.org).
- The right to erasure of your personal information – In some cases, you have the right to have your personal information erased or deleted. This right is not absolute; we may have legal or legitimate reasons to retain your personal information.
- The right to object to the processing of your personal information – Where the processing of your personal information is based on legitimate interest, you have the right to object to its processing.
- The right to limit the processing of your personal information – The processing of your personal information may be limited, in which case we will store it, but will not be able to use it or process it further. This right applies in the limited circumstances set out in the General Data Protection Regulation.
- The right to portability of your personal information – You have the right to receive a copy of your personal information in a structured, commonly used and machine-readable format or to request its transfer from our database to another service provider. This right is limited to personal information you have provided where the processing is based on a contract or on your consent and the processing is carried out using automated processes.
- The right not to be subjected to automated decision-making, including profiling – You have the right not to be subjected to a decision based solely on automated processes, including profiling, that produces legal effects that significantly affect you. As a responsible company, we do not use automated decision-making for these purposes.
- The right to withdraw consent at any time in relation to the processing of data based on consent – The withdrawal of consent does not affect the lawfulness of the processing based on consent prior to the withdrawal of consent.
- The right to set post-mortem instructions – You have the ability to set instructions regarding the retention, deletion and disclosure of your personal data after your death with a trusted, certified third party who is responsible for carrying out the wishes of the deceased in accordance with the requirements of the applicable legal framework.
You may contact us (email@example.com) at any time to exercise the rights set out above. Before granting your request, we may require you to confirm your identity. Your request may be accepted or rejected depending on applicable law.
If you are dissatisfied with the way we have handled your request or if your request has been rejected, you may contact your local supervisory authority to have it reviewed. Residents of the European Union can contact their supervisory authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION – CALIFORNIA
Under California law, California residents have the right to know how we respond to the “Do Not Track” feature available in their browser settings. Enabling this feature sends a special signal to the website you are visiting that you do not want tracking to occur. Currently, we do not respond to “Do Not Track” signals. If we adopt this practice in the future, we will describe how we do so in an updated version of this Data Protection Policy.
California law also permits customers who are California residents to request certain information about the sharing of their personal information with third parties and, in some cases, with affiliates for the purpose of marketing by such third parties or affiliates. For such requests, please contact us (firstname.lastname@example.org).
Any inquiries related to this Data Protection Policy may be sent to email@example.com or by mail to the following address for the attention of the Legal Department:
Reflector Entertainment Ltd.
2200 Rue Stanley
H3A 1R6 CANADA
+1 438 792 5100