Last update: February 1^st, 2020

INTRODUCTION

The protection of your privacy and personal information is important toReflector Entertainment Ltd(collectively with its subsidiaries and affiliates, “Reflector”, and also referred to as “we”, “our” or “us”). In this Privacy Policy (the “Privacy Policy”, as it may be amended, restated, supplemented or modified by Reflector from time to time), you will find information regarding how we collect, use and otherwise process your personal information.

This Privacy Policy applies to Reflector’s website unknown9.com as well as all related Reflector websites, mobile applications and services that link to this Privacy Policy (collectively, the “Website”) unless we have posted a specific privacy policy to a particular website or service. In that case, that specific privacy policy will apply.

Moreover, when you use the Website, you also have responsibilities which are outlined in the Terms and Conditions section of the Website. We recommend that you consult these Terms and Conditions prior to using the Website in order to inform yourself of your obligations.

This Privacy Policy covers all personal information that we collect, use and otherwise process when you interact with the Website or with us. All personal information will be processed in accordance with this Privacy Policy and with applicable laws, which can vary depending on your country of residence. If you do not agree with any provisions or changes to this Privacy Policy, please do not use the Website.

Personal information is collected, held and more generally processed by Reflector.

For legal residents of the European Union, note that the processing of your personal information is founded on at least one of the following legal bases:

You have consented to the processing activity;
The processing activity is necessary for compliance 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 one or more of the following legitimate interests pursued by us and/or a third party:
- To better understand our customers’ interests and preferences by analyzing, profiling and monitoring their behaviour on the Website in order to globally improve the Website, as well as our products and services;
- To offer you an optimal customer experience, namely by tailoring the Website, and our products and services (including advertisements and e-mails) to your interests and preferences;
- To ensure the proper functionality and security of the Website.

These processing activities benefit both us and you without undermining or overriding any of your rights, interests or fundamental liberties.

Note that when the processing of your personal information is based on consent, you can withdraw such consent at any time by contacting us (privacy@reflectorentertainment.com).

We reserve the right to modify this Privacy Policy to adapt it to any technological or legal change, to adjust it to reflect changes made to the Website or for any other purposes. All updates to our Privacy Policy will be posted on this page or otherwise mentioned to you if required by applicable laws.

HOW WE COLLECT INFORMATION

We collect personal information under the circumstances listed below. In certain circumstances or for certain purposes, providing your personal information is voluntary. However, in other circumstances, providing your personal information is mandatory and we may not be able to provide you with the services or products requested if you choose not to provide such information.

We collect your personal information in the following circumstances:

When you create an account on the Website;
When you buy products and services from Reflector;
When you interact with the digital content on the Website;
When you participate in a contest and/or a survey;
When you send us an inquiry, request or otherwise communicate with us;
When you provide us with your personal information while onsite at an event or at our premises, such as when you log in to the Wi-Fi network;
When you choose to give us permission to access your information from third party websites (for example, by linking to social media networks like Facebook).

Some of your personal information may be automatically collected from the devices used to connect to the Website, and some may be provided by our affiliates and/or commercial partners, and/or promotional partners, including companies that sell our products worldwide.

WHAT INFORMATION IS COLLECTED

Under the circumstances listed in the “How We Collect Information” section of this Privacy Policy, the following information may be collected:

Personal Information

To facilitate reading, the expression “personal information” is used throughout this Privacy Policy. For interpretation purposes, this expression shall have the meaning set forth in the legislation that is applicable to you. For instance, for legal residents of the European Union, “personal information” shall be read throughout this Privacy Policy as “personal data” as defined under the General Data Protection Regulation. In any case, we treat any information that makes it possible to identify you as an individual as personal information. For example, we consider your given name, surname, date of birth, postal address, telephone number, e-mail address, mobile number, as well as any information that is considered personal information under applicable laws to be personal information.

We collect and process the following categories of personal information:

Identification information, such as your given name, surname, date of birth, country, e-mail address, gender, chosen username and profile image;
Login information, such as the e-mail address you use to connect to your account on our Website, or other information that you choose to link to your account on the Website. Should you have difficulty logging in, you may contact Reflector at the following email address: supportU9@reflectorentertainment.com. Some information will be required to be disclosed (e.g. email address) to ascertain your identity and provide you with a new password;
Interests and preferences information, including but not limited to preferred medias, favorite genres and other general entertainment interests, wishlist of Reflector products and favorite Reflector products, consumed and/or owned Reflector products;
Information about your interactions with the digital content of the Website, including but not limited to your progression in the interactive experience entitled “Chapters”;
Any other information that you provide directly and voluntarily, including any message you send to us by e-mail and/or by contacting our customer and/or legal service.

Cookies

We, as well as third-party service providers and content providers, may use a variety of cookies and similar tracking technologies (the “Cookies”) that : i) if so allowed by you, remember your login information; and ii) automatically collect certain Website usage information whenever you visit or interact with us (the “usage information”). Usage information may include, without limitation, , the content that you browse, the last position on the Website or while browsing the media content, among other information.

Some usage information may be considered as personal information under certain laws, such as the IP address under the laws applicable in the European Union. To the extent that we combine usage information with your personal information, we will treat the combined information as personal information under this Privacy Policy.

Information about Someone Else

If you submit information on behalf of another individual (for example a friend, a family member, a member of a tour group you are organizing), you must ensure that you have his/her consent to share his/her personal information with us, and you confirm that you have this consent.

Children’s Information

We take children’s privacy seriously. We do not knowingly collect personal information from children through the Website. If you are a minor under the laws of your country, please do not submit any personal information through the Website without the express consent and participation of a parent or guardian. If you learn that any minor under 16 years has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.

As far as is permitted by applicable legislation, Reflector declines any responsibility regarding any activities which may be conducted by children on the Website.

HOW WE USE INFORMATION

We collect and process personal information to:

Manage the account creation process on the Website and, more generally, manage your personal account;
Provide you a personalized experience of the Website and of its the digital content;
Deliver the services you have requested and/or the products you have purchased through the Website;
Monitor, analyze, protect, test, improve and update our services and products, improve the Website performance, respond to your requests regarding the Website, remember your Website preferences/settings;
Design, maintain, analyze, manage, improve, market, promote and provide products and services via the Website;
Help us perform transactions and verify your identity with the transaction you have requested;
Respond to your inquiries;
Communicate with you about changes to our policies;
Perform quality assurance, sales, marketing and other business analysis;
Organize contests and other promotional activities;
Understand your needs and interests and provide you with optimal services and personalized advertisements, services and products by performing profiling, where permitted under applicable laws or with your consent (if required);
Send you specific information, promotional and marketing communications about Reflector products and services (for example, offers, discounts, newsletters and birthday communications), where permitted under applicable laws or with your consent (if required). Such communications will be sent in accordance with applicable laws. Such person may withdraw his/her consent at any time as set forth below; and
Protect our own rights, property, and operations (like enforcing our contracts and terms - including the Terms and Conditions - and pursuing available remedies or limiting the damages we may sustain).
Detect or prevent fraud, security or technical issues or to comply with any applicable law, regulation, legal process or governmental requests.

Note that Reflector does not intent to sell or share personal information to third parties for third party marketing purposes. In all cases, such personal information is only collected and used for the purposes detailed in this Privacy Policy, and for no other purposes.

DIRECT MARKETING AND PROFILING

When we send or display personalised communications or content, we may use some techniques that qualify as “profiling” (i.e. any form of automated processing of personal information consisting of using the aforesaid information to evaluate certain personal aspects relating to a natural person, for example to analyse or predict aspects concerning that person’s personal preferences, economic situation, interests, behaviour, location or movements).

More particularly, we may collect personal information about you in the different scenarios mentioned above, centralize this information and analyse it to evaluate and predict your personal preferences and/or interests. Based on our analysis, we then send or display communications and/or content tailored to your specific interests/needs.

You may have the right to object at any time to the use of your personal information for “profiling”. Please see “Your rights regarding your personal information” section below.

PERSONAL INFORMATION COLLECTED BY THIRD PARTIES

Our Website includes hyperlinks to third parties’ websites, including for the purposes of processing any requested purchase of Reflector’s products. These third parties have privacy policies that may be different from this Privacy Policy. The information collected and stored by third parties, whether through our Website or a third party’s website, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. We are not responsible for the manner in which your information may be collected, used, disclosed and otherwise processed by said third parties, and encourage you to familiarize yourself with and consult their privacy policies and terms of use. To the extent we combine information we receive from third parties with personal information we collect directly from you on the Website, we will treat the combined information as personal information under this privacy policy.

SHARING OF YOUR PERSONAL INFORMATION

For the purposes outlined in the Privacy Policy, we may share your information with Reflector’s affiliates as well as with the different third parties listed hereafter, which may be located all around the world:

Service providers: Your personal information may be shared with third parties acting on our behalf or for us, such as data processors, hosting service providers, e-commerce websites, technical systems consultants and marketing agencies;
Commercial partners : Your personal information may be shared with third parties assisting Reflector in the development or operation of the Website, such as, but not limited to: (i) Facebook, Google and other third-party social media networks that you choose to link to your account on the Website, (ii) Alice & Smith, providing digital interactive content on the Website (ii) Google Analytics, providing advertising services allowing the collection of data by using advertising cookies and anonymous IDs (you may withdraw your consent by deactivating such functions in Google®’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs. More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy), (iii) Salesforce and Microsoft Azure, providing servers location, cloud computing and live game platforms for the storage of various information (including Personal Information).
Promotional partners: We may share your personal information with third parties who may associate themselves with us for the promotion of our products, the presentation of our events or for any other activity, such as contests, games, sweepstakes or other promotions. We gather advertising and analytics info from third parties to help support our marketing initiatives, improve Reflector’s services and products, and better manage our ad campaigns (like by displaying more personalized ads and measuring how effective they are);
Business transaction: We reserve the right to transfer your personal information without seeking your express permission in the event of a business transaction 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 a manner that is consistent with this Privacy Policy;
Legal or administrative bodies: We may share your personal information with third parties (including legal or administrative bodies, governmental authorities, jurisdictions) if we believe that disclosure is reasonably necessary to enforce this Privacy Policy, to detect or prevent fraud, security or technical issues or to comply with any applicable law, regulation, legal process or governmental request.

Please note that once we share your personal information with a third party, it may become subject to a third party’s privacy practices unless it is specifically provided for that the present Privacy Policy applies. Please note that we make commercially reasonable efforts to have your personal information used by such individual members and third parties in a manner that is consistent with this Privacy Policy.

STORAGE OF YOUR PERSONAL INFORMATION AND INTERNATIONAL DATA TRANSFERS

While your personal information will be collected and stored on servers in Canada, it may be shared with, stored and/or otherwise processed by Reflector’s affiliates and/or by third parties who are located in other countries. For example, some of the service providers that process or handle personal information on our behalf may be located outside of Canada. Regardless of where the processing of your personal information takes place, we will take steps to protect your personal information in accordance with this Privacy Policy, the data protection laws and, where required by applicable laws, recognised data transfer mechanisms (such as EU-US Privacy Shield Certification of third party service providers that we use or standard data protection clauses recognized by the European Commission). While we use reasonable means to safeguard your personal information, it is subject to the legal requirements and governmental authorities of the foreign jurisdictions in which it is located. For example, we may be legally required to disclose personal information to a governmental authority of a foreign jurisdiction in which your personal information is located.

PERSONAL INFORMATION SECURITY

We have adopted reasonable security procedures to help protect against loss or theft, unauthorized access, disclosure, copying, use or modification to the personal information you provide to us. While we strive to protect your personal information, we cannot guarantee or warrant the security of any personal information you disclose or transmit on the Website and cannot be responsible for the loss, theft, unauthorized access, disclosure, copying, use or modification of your personal information, unless such acts are the result of our gross negligence or wilful misconduct, unless otherwise provided by law.

In this regard, we have notably put in place or currently implement the following measures:

SSL technology: Each time the Website is accessed via Internet, Secure Sockets Layer (SSL) technology protects personal information by using server authentication and data encryption. No personal information will be communicated prior to this technology being activated, which can be confirmed by looking (i) at the address bar which will, depending on the browser, have a lock to the left of the Website address (URL), and (ii) at the URL or the address bar of the browser, where the first characters of the address in that line should change from “http” to “https”;

Limited access: Access to any personal information is granted to Reflector’s employees, representatives and as applicable sub-contractors or commercial or promotional partners on a “need-to-know” basis only;

Secured center: Reflector’s platform and servers are located in data centers located in Canada and the United States. Additional information regarding the security of Salesforce’s and Microsoft Azure’s systems can be obtained by reviewing Salesforce “Trust Website” [https://trust.salesforce.com/] and Microsoft “Trust center” available here [https://www.microsoft.com/en-ca/trust-center] , as of the effective date of this Privacy Policy.

RETENTION PERIOD

We will retain your personal information only as long as is necessary for the fulfillment of the purposes outlined in this Privacy Policy or for a longer period if required or permitted under applicable laws.

We may retain your personal information for an additional period in archive databases, including for the duration of applicable statutes of limitation in order to be able to exercise our rights and/or defend ourselves in case of legal claims. Please note that if you merely unsubscribe from marketing communications such as the newsletter, we may nonetheless continue to use your personal information for marketing and business analytics purposes, unless you withdraw your consent to this activity or object to it by contacting us (privacy@reflectorentertainment.com).

UNSUBSCRIBE FROM PROMOTIONAL E-MAILS

To stop receiving promotional e-mails from us, follow the link at the bottom of the promotional e-mail or contact us (privacy@reflectorentertainment.com).

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

As permitted under applicable laws, you may exercise the following rights with regards to the personal information we hold about you:

Right of confirmation of personal information processing:You have the right to obtain the confirmation as to whether or not personal information that concern you are being processed;
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 restrictions);
Right to rectify your personal information: You have the right to have your personal information rectified if it is incorrect or outdated and/or completed if it is incomplete. To correct your personal information, please contact us (privacy@reflectorentertainment.com).
Right to have your personal information deleted: In some cases, you have the right to have your personal information erased or deleted. This is not an absolute right, as we may have legal or legitimate grounds for retaining your personal information;
Right to object to the processing of your personal information:Where the processing of your personal information is based on a legitimate interest, you have the right to object to its processing;
Right to restrict the processing of your personal information:The processing of your personal information can be restricted, in which case we will store it accordingly, but will not use it or process it further. This right applies in the limited circumstances set forth in theGeneral Data Protection Regulation;
Right to the 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 and/or to request its transfer from our database to another service provider. This right is limited to personal information that you have provided, where processing is based on a contract or your consent, and where the processing is carried out by automated means;
Right to not be subject to automated individual decision-making, including profiling: You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces significant legal effects that concern you. Please note that as a responsible company, we do not use such automated decision-making for such purposes; and
Right to withdraw consent at any time for data processing based on consent:The withdrawal of consent shall not affect the lawfulness of processing based on consent prior to its withdrawal.

You may contact us (privacy@reflectorentertainment.com) at any time to exercise the above rights. Before granting your request, we may require that you confirm your identity to us. Your request may be accepted or denied on the basis of any applicable laws.

If you are not satisfied with how we have handled your request, or if your request was refused, you can apply to your local authority to have it examined. For European Union residents, you can communicate with your competent supervisory authority at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

YOUR CALIFORNIA PRIVACY RIGHTS

Legislation in California provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. If activated by you, these settings send a special signal to the websites you encounter indicating that you do not wish to be tracked. We do not respond to Do Not Track signals at this time. If we do so in the future, we will describe how so in an updated version of this Privacy Policy.

Legislation in California also permits customers who are California residents to request certain information about the sharing of their personal information with third parties or, in some cases, affiliates for those third parties’ or affiliates’ own direct marketing purposes. For all such inquiries, please contact us (privacy@reflectorentertainment.com).

CONTACT US

All inquiries about our Privacy Policy may be sent by e-mail at privacy@reflectorentertainment.com or by mail at the following postal address to the attention of the Legal Department:

Reflector Entertainment Ltd.
2200 Stanley Street
Montreal (Quebec)
H3A 1R6 CANADA.