INTRODUCTION

The protection of your privacy and personal information is important to Reflector 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.

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 the personal information that you provide us.

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:

1. Contact information, such as your given name, surname, and e-mail address.;

2. 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 service.

• Information Collected Automatically (‘usage information’)

We, as well as third-party advertisers, service providers and content providers, may use a variety of cookies and similar tracking technologies (the “Cookies”) that automatically collect certain Website usage information whenever you visit or interact with us (the “usage information”). Usage information may include, without limitation, the information on your browser.

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.

HOW WE USE INFORMATION

We collect and process personal information to send you specific information, promotional and marketing communications about Reflector products and services.

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, technical systems consultants and marketing agencies;

• 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

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.

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 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 (123@gmail.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 the General 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; 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 (123@gmail.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  (123@gmail.com).

CONTACT US

All inquiries about our Privacy Policy may be sent by e-mail at 123@gmail.com or by mail at the following postal address to the attention of the Legal Department: