NewCo Privacy Policy Effective December 10, 2019

1. OVERVIEW Vision 7 Communications Inc. currently operates (a) NewCo festivals and (b) the online site Newco.co, among other sites and services. This Privacy Policy applies to consumers who provide us with information in connection with their participation in NewCo festivals or who sign up to stay informed of NewCo events. The Policy describes our collection and use of your Personal Information (e.g., information that identifies a specific person, such as full name, postal address, telephone number, email address, or credit or debit card number). It also generally describes our practices for handling Other Information (e.g., interests, demographics and site usage) collected from you. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

2. INFORMATION WE COLLECT “Personal Information” is the information that identifies you as an individual, such as name, postal address, telephone number, email address and credit or debit card number. We collect Personal Information when you submit it to us, including but not limited to your registration or subscription to certain products or services, such as registering for any NewCo events we may create in the future. “Other Information” is any information that does not reveal your specific identity, such as browser information, information collected through cookies and other technologies, demographic information, and aggregated information. We may combine Other Information with your Personal Information, and when we do, we treat the combined information as Personal Information. We collect Other Information when you submit it to us. It may include your gender, education, occupation, financial information (such as your income, and other information), interests, photos, connections, and comments. We may also receive Personal Information about you from our partners such as sponsors or businesses which aide us in delivering services to you or from publicly available sources such as Facebook, Twitter, LinkedIn, Instagram. We may receive Other Information about you from third parties, including, for example, demographic data, information about your interests, and information about your activities on other websites.

When you access our site, we automatically collect certain information about those visits. For example, in order to permit your connection to our Online Services, our servers receive and record information about your computer and browser, potentially including your IP address, browser type, and other software or hardware information. If you access our Online Services from a mobile or other device, we may collect a unique device identifier assigned to that device (“UDID”) or other transactional information for that device in order to serve content to it. We also may use cookies and other tracking technologies (including browser cookies, pixels, beacons, and Adobe Flash technology including cookies). We may use these technologies to facilitate our login processes; personalize your experience; display relevant content, products, services and advertising, as described further below; and collect and store information about your usage of our services.

3. HOW WE USE YOUR INFORMATION We will only contact you for marketing purposes with your consent or as permitted by law. We use the Personal Information we collect from and about you for the purposes set forth below. Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information. To improve the quality of our products and services, we may combine the Personal and Other Information we collect with information that you provide to us in connection with your use of our other products, services and websites, or information from third parties. We use the information we collect from and about you to provide our products and services and features to you, including: to process and fulfill your registration, to send you information about your relationship or transactions with us, to measure and improve those services and features, to personalize your experience, to provide you with customer support, and to respond to inquiries. To make your experience more interesting and personalized, we may use any of the Personal and Other Information we collect to assist us in delivering content on our Online Services. We may periodically send promotional materials or notifications related to our products and services to the email address you provided to us at registration or to your account. To help make these promotional materials more relevant to you, we may use and combine any of the Personal and Other Information we collect to assist us in sending you promotional materials. If you want to stop receiving promotional materials from us, you can follow the unsubscribe instructions at the bottom of each email. You always have the right to “opt-out” of receiving our marketing. You can exercise the right at any time through a link at the bottom of each email, or by emailing support@newco.co. We retain your Personal Information until you “opt-out” at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don’t actually send you any more marketing.

4. HOW WE SHARE YOUR INFORMATION We only share your Personal Information with non-affiliated third parties when we believe sharing is permitted by you or authorized by this Privacy Policy. We never share your Personal Information with non-affiliated third parties for marketing purposes unless we have your “opt-in” consent to share your Personal Information with a specific non-affiliated third party for them to send you marketing.  We may share your Personal Information with partners such as sponsors or businesses who act as data processors in aiding us in delivering services to you. Vision 7 Communications Inc. is the data controller of the jointly-used Personal Information. We also share your Personal Information to manage registrations. If your subscription is provided in whole or in part by your employer or other third party, we may notify the provider when you access or use your subscription. We may make your Personal Information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; auditing; processing data or statistics; and serving, customizing or delivering marketing or ads. These outside service providers are required to protect Personal Information entrusted to them and not use it for any other purpose than the specific service they are providing to us. If you register for an event, we may share your contact information with other companies whose products and services may be of interest to you. While many of our subscribers appreciate receiving offerings from these companies, if you prefer that we do not share your information for this purpose, you can opt out on the event registration form or email support@newco.co.  There may be instances when we may disclose your Personal Information, including situations where we have a good faith belief that such disclosure is necessary in order to: (i) protect or defend our legal rights or property, our affiliated companies or their employees, agents and contractors (including enforcement of our agreements); (ii) protect the safety and security of users of the our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence. If we sell all or part of its business or make a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, we may transfer your information to the party or parties involved in the transaction as part of that transaction.

5. WHERE WE STORE YOUR INFORMATION Our headquarters are based in Canada and data is stored in the cloud.

6. DATA SECURITY We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place internal security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your Personal Information to those people who need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. In addition, we have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.

7. HOW LONG WE KEEP YOUR INFORMATION Your Personal Information is kept for 10 years after we receive it.  In some circumstances it may be necessary to keep your Personal Information for longer than that in order to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. In some circumstances we may anonymize your Personal Information so that it can no longer be associated with you.

8. NOTICE This Privacy Policy is the primary means by which we provide you with notice and choice about our collection and use of your Personal Information. If we ask for specific Personal Information that will be used in a manner different from what is described in this Privacy Policy, we will inform you at the time of collection. We may modify this Privacy Policy as necessary. If we make material changes to this Privacy Policy that materially expand our rights to use your Personal Information, we will provide you with notice and choice consistent with applicable law. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our products and services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

9. HOW TO ACCESS, CORRECT, DELETE OR UPDATE YOUR INFORMATION You can access or modify your registration information and modify your preferences by contacting support@newco.co. Certain laws permit our customers to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. To make such a request, please write to us at: Vision 7 Communications Inc., 300 St-Paul Street, suite 300, Quebec City, Quebec, G1K 7R1 and include your name and the address to which you would like us to respond. For any GDPR-related request or question please contact our nominated representative, Mr. Mark Cater at Alphabeta Building, 14-18 Finsbury Square, London 1C2A 1AH, United Kingdom; gdpr@v7international.com.

 

 

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