Last updated: December 6, 2024
This Privacy Policy (the “Policy”) sets out the practices of Reflector Entertainment Ltd. with respect to the collection, use and disclosure of your personal information by technological means with respect to the situations set out in Section 2 hereof. For ease of reference, we refer to ourselves as "Reflector" or simply "we".
For the purposes of this Policy, personal information is any information that allows a natural person to be identified, directly or indirectly.
By accepting our Policy or providing us with personal information after having had an opportunity to review it, you agree that your personal information will be treated in accordance with our Policy.
You can reach our Privacy Officer:
By email:
To the attention of Marc-Antoine Dumais, CFO, in his capacity as Reflector's Privacy Officer: [email protected]
How we will treat your personal information will depend on the nature of your interaction with us. Below is a description of how we process your personal information, with the understanding that we may also process your personal information as provided by applicable privacy laws or otherwise with your consent.
In the course of our activities, we process your personal information by technological means in the manner set out in the following articles:
2.1 - When you communicate with our team via our website or by email;
2.2 - When you send us your application; Possible to apply;
2.3 - When you connect to our wifi network;
2.4 - When our employees use the Robin application to manage our office spaces;
2.5 - When you choose to give us permission to access your information from third-party websites.
When you browse our website, we refer you to the section of our website that deals with our use of cookies. Indeed, the use of cookies may involve the processing of your personal information.
How do we collect your personal information?
We collect your personal information directly from you when you fill out the "Contact Us" form on our website or when you send us an email.
What categories of personal information are collected and for what purposes do we use it?
| Class of Information | Usage |
| Identification information: Last name, first name, email address if you use your personal contact information. | Confirm your identity and allow relevant Reflector personnel to communicate with you. |
| Content of the message (if personal information is provided). | Identify your needs in order to respond to your request. |
Professional Information: We ask that you avoid sharing your personal information with us whenever possible. Please provide us with your email address instead.
Important: We ask that you do not include any personal information that is not necessary for the content of the message.
Who has access to personal information?
Reflector personnel, whose duties require it, will have access, in whole or in part, to your personal information.
We use service providers who provide software and cloud services to collect, store and process your personal information on our behalf.
Your personal information may be shared with Bandai Namco group companies, including its subsidiaries, parent company, or international entities. This allows us to better understand who our global consumers are, to improve our products based on global trends, needs and interests, and to commercially promote our products using locally tailored media that match the reality of the geographic area.
Your personal information may be shared with third parties who partner with us for the promotion of our products, the presentation of our events, or for any other activities, such as contests, games, sweepstakes, or other promotions. We collect advertising and analytics information from third parties to support our marketing initiatives, improve our services and products, and to better manage our advertising campaigns (including by displaying more personalized ads and evaluating their effectiveness).
How do we collect your personal information?
We collect your personal information directly from you when you submit your application to us by filling out the form on our website, emailing us your application, applying through our LinkedIn or through Indeed.
If your application is submitted through a recruitment firm/employment agency, we will collect your personal information from that firm or agency.
We may also collect your personal information when you are referred.
What categories of personal information are collected and for what purposes do we use it?
| Class of Information | Usage |
| Identification information: First name, last name, email, phone number. | To communicate with you, to evaluate your application for employment or to allow us to manage any follow-up in connection with this application. |
| CV and any other relevant document (cover letter, presentation message, etc.). | To communicate with you, to evaluate your application for employment or to allow us to manage any follow-up in connection with this application. |
Who will have access to your personal information?
We restrict access to your personal information to those Reflector employees who require such access as part of the recruitment process (human resources, internal team members related to the position to be filled, technical and administrative support).
We use service providers who provide software and cloud services to collect, store and process your personal information on our behalf.
Your personal information may be shared with Bandai Namco group companies, including its subsidiaries, parent company, or international entities. This allows us to better understand who our global consumers are, to improve our products based on global trends, needs and interests, and to commercially promote our products using locally tailored media that match the reality of the geographic area.
For some positions, we may share your personal information with a criminal record check provider.
How do we collect your personal information?
We collect your personal login information when you connect to and use our WIFI network.
What categories of personal information are collected and for what purposes do we use it?
| Class of Information | Usage |
| Connection information: Connection time, IP address, and connection history. | To allow you to connect to our Internet network. Monitor network activity to prevent attacks. Optimize network performance. Troubleshoot if there is a connection issue. |
Who will have access to your personal information?
We restrict access to your personal information to those Reflector employees who require such access in the course of their duties.
We use service providers who provide software and cloud services to collect, store and process your personal information on our behalf.
How do we collect your personal information?
We collect personal information from our employees directly from them when they use our office space management application.
What categories of personal information are collected and for what purposes do we use it?
| Class of Information | Usage |
| Connection information: IP address, location, mobile phone number. | Establish where employees are working from. |
Who will have access to your personal information?
We restrict access to this personal information to those Reflector employees who require such access in the course of their duties.
Our office space management app.
We do not knowingly collect personal information from anyone under the age of 18. If you are a minor, you may not provide us with any personal information without the express consent of a parent or the holder of parental authority. For this purpose, if you are under 18 years of age, you represent that you have the permission of a parent or legal guardian to use and browse the Website. Ask them to read this Policy with you. If you are the parent or legal guardian of a user under the age of 18, by allowing your child to use our Website, you are bound by the terms of this Policy and assume responsibility for your child's activity on our Website. If you are a parent or guardian and you are aware that your children have provided us with personal information without your consent, please contact us. If we discover that we have collected personal information from a person under the age of 18 without the consent of the person with parental authority or guardian, we will take steps to delete that information from our systems.
As part of your browsing on our website, we collect cookies. You can enable these technologies by accepting cookies identified as being used for identification, profiling, or location on the cookie banner on our website. For more information, we invite you to consult our cookie policy here.
We also collect your location when you connect to our WIFI or on our VPN. You can activate these technologies by agreeing to connect to WIFI or our VPN.
We will retain your personal information until the purposes for which it was collected have been fulfilled and in accordance with our internal policies and processes to that effect. However, we may retain your personal information for a longer period of time as required to comply with our legal and regulatory obligations regarding information or record retention.
For more information about how long we retain personal information, please contact our Privacy Officer whose contact information can be found in section 1 of this Policy.
Your personal information is held virtually on several servers and platforms, including Reflector's servers, cloud service provider platforms that we use, or the servers of third parties with whom we do business. In connection with the use of these platforms, it is likely that your personal information will be transferred to and hosted outside of Quebec by these providers, particularly in the rest of Canada, the United States and Europe.
When we consider that the disclosure of your personal information outside of Québec is necessary to support our operations, we assess whether your personal information is adequately protected in the event of disclosure. We will only share your personal information if we believe it is adequately protected. Communication will also be governed by an appropriate contractual agreement.
We deploy adequate security measures to protect your personal information. In particular, we have put in place appropriate physical, technical, and administrative safeguards to ensure the protection of personal information.
If you have reason to believe that personal information has been compromised, please contact our Privacy Officer using the contact information provided in Section 1 of this Policy.
The law gives you different rights with respect to your personal information. In particular, you have the following rights:
You can ask us if we hold any personal information about you and, if so, you can request access to that personal information.
You may request that we rectify any incomplete or inaccurate personal information we hold about you.
In some cases, you may withdraw your consent to the disclosure or use of the personal information we hold about you. You understand, however, that if you do so, you may no longer be able to benefit from our products and services. If the withdrawal of your consent inevitably leads to a breach of contract, you understand that contractual consequences may apply.
You may request that we disclose your personal information to you or to another organization in a structured, commonly used technology format.
To exercise any of your rights above, please contact our Privacy Officer at the contact information provided in section 1 of this Policy.
Reflector takes requests, complaints, and comments about how we handle your personal information very seriously. We encourage you to contact our Privacy Officer to submit complaints or comments about our privacy practices.
Your complaint will be reviewed by our Privacy Officer, who will determine whether the handling of your personal information complies with our privacy program, as well as any applicable laws.
You can also file a complaint with the Commission d'accès à l'information du Québec using the form available on the Commission's website. However, we encourage you to contact our Privacy Officer first.
This Policy does not apply to, and we are not responsible for, any third-party websites, pages or applications that may be accessed through our products and services, including, but not limited to, through our websites and financial portal. If you follow such links, these third-party websites or services will likely have their own privacy policies that you should review before submitting your personal information.
We may change our Policy from time to time. Changes will be posted on Reflector's website along with a notice of change. The proposed amendments will come into force on the date specified in the relevant notice of change.
Reflector is committed to protecting your personal information throughout its lifecycle, in accordance with its privacy practices and in accordance with the requirements contained in applicable laws.
To this end, in addition to our Privacy Policy, Reflector has adopted an internal governance policy with respect to personal information, the purpose of which is to set out the principles governing the protection of personal information in the context of its operations.
The objectives of our internal governance policy are:
Since respecting your personal information is everyone's business at Reflector, our Privacy Officer is supported by a team that is aware of the protection of personal information as well as the rights of the individuals concerned.
Each member of our staff has a role to play in ensuring that we can act in accordance with our privacy program. In fact, each member of our staff is called upon to:
Reflector recognizes the importance of the protection, confidentiality and security of the personal information it handles in the course of its activities and the importance of educating its staff and partners on this subject.
Reflector has prepared best practice and prohibited practices guidelines regarding how we may handle your personal information, for example:
Reflector has a process in place to respond to and address privacy incidents.
Under this process, Reflector must take reasonable steps to reduce the risk of serious harm and review its practices to prevent future confidentiality incidents of a similar nature.
Reflector documents all confidentiality incidents in its Confidentiality Incident Log and will adapt its privacy program as necessary, following a confidentiality incident.