Last updated: November 6th, 2023
Your privacy and the protection of your personal information are very important to Reflector Entertainment Ltd., company whose head office is located at 2200 Stanely Street, Montreal, Quebec, H3A 1R6, Canada, which acts as data controller of the personal information covered by this Policy (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. Reflector has designated a person in charge of the protection of the personal information, which can be reached at the following e-mail address : [email protected], or by mail at Reflector Entertainment Ltd., to the attention of the data protection officer, at 2200 Stanley Street, 2nd floor, Montreal, Quebec, H3A 1R6, Canada.
This Data Protection Policy applies to the Reflector reflectorentertainment.com website and all Reflector websites, mobile applications and related services that hyperlink to the Data Protection Policy (collectively the “Site”), unless we have published a specific data protection policy relating to a particular website or service. In such case, the specific data protection policy applies to that website or service.
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:
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 ([email protected]).
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.
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:
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.
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, e‑mail 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:
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.
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.
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.
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.
We collect and process personal information for the following purposes:
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.
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:
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):
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.
Please note that once your personal information is shared with a third party, the processing of that personal information may become subject to that third party's data protection practices, unless expressly provided otherwise in this Data Protection Policy. 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 which is not designated by the European Commission as providing a sufficient level of protection for personal data, the transfers will take place under a agreement that covers obligations imposed by the EU for the transfer of personal data outside the EU, including standard contractual clauses (SCCs) approved by the European Commission, or under other appropriate safeguards.
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.
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:
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:
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.
To stop receiving promotional e-mails from us, follow the link at the bottom of the promotional e-mail or contact us ([email protected]).
To the extent permitted by applicable law, you may exercise the following rights with respect to the personal information we hold about you:
You may contact us ([email protected]) 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 http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
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 ([email protected]).
This policy comes into force on the date it is posted online. The same applies for amendments.
Any inquiries related to this Data Protection Policy may be sent to [email protected] or by mail to the following address to the attention of the data protection officer at :
Reflector Entertainment Ltd.
2200 Stanley Street
H3A 1R6 CANADA
+1 438 792 5100.