PRIVACY POLICY
This Privacy Policy governs use of Personal Information by Imagination Room Company Ltd. (“IR”, “we”, “us”, “our”), whether such information is collected via our website (“Website”) or through offering one of our apps, such as Pool, Car Hop, Jump Shots, Find Me, Breathe Easy or Matched (“App”)
The terms “you”, “User”, and “your” refer to a visitor of our Website or a user of an App.
By submitting Personal Information to us or by otherwise using our Website or an App, you acknowledge and agree that your Personal Information may be used and disclosed by us in accordance with this Privacy Policy.
In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as your name, address or contact information (including home telephone number and personal e-mail address). Please note that not all information that you share with us is considered Personal Information: for example, business contact information is not considered Personal Information.
By submitting Personal Information to us through an App or our Website, you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
If you do not agree with some or all of this Privacy Policy, please do not use the Apps or our Website.
Further, if you are not of the age of majority in your place of residence, please do not use the Apps or our Website.
We recommend that you take the time to read this Privacy Policy so that you understand how we handle Personal Information. We may update or modify this Privacy Policy at any time by posting the revised Privacy Policy to our Website or making the revised Privacy Policy available through the Apps. We will include a “last revised” date on the Privacy Policy as displayed on our Website. We strongly encourage you to refer back to the Privacy Policy periodically.
1. How we Collect and use Personal Information
We may collect Personal Information from you for specific and limited purposes, including to provide the App to you, where you consent to the collection, in order to meet our contractual commitments to you and to comply with our legal obligations.
When collecting Personal Information from you, we will identify the purpose for collecting your Personal Information at the time we request it and will not use or disclose your Personal Information other than for the purpose for which it was collected, without your prior consent or as otherwise permitted by applicable data protection and privacy laws. We endeavor to collect the minimum amount of Personal Information required to fulfil the purpose for which it was collected.
When you download and register to use the App, you may provide us with the following Personal Information: name, email, address, and user name. You may provide other Personal Information if you request our help. If you choose to withhold any Personal Information requested by us or withdraw your consent, you may not be able to use the App and it may not be possible for us to respond to your query.
We may collect and use your Personal Information (or other information) in a variety of ways, including for the following purposes:
Information that you Provide: Your Personal Information may be collected and used by IR to provide the App or services via our Website, or otherwise. Specifically, we may use your Personal Information as follows:
to share information about IR, our Website, the App, and other products and service with you;
to communicate with you regarding inquiries for information or customer service requests or employment opportunities; or
to detect, prevent or investigate security breaches or fraud, to protect our business and to maintain appropriate records for internal administrative purposes, including analyzing and monitoring usage of the App and our Website.
Automated Collection: The App may also collect certain information automatically, including but not limited to:
the type of mobile device you use, your mobile device’s ID, the IP address of your mobile device, your mobile operating system and information on how you use the App, including the location of your mobile device; and
we may use permanent cookies or server-side artifacts to help us track use of our services by Users. Similarly, we may also collect information regarding the type of device, your operating system, the browser you use, your internet service provider, your domain name, your internet protocol (IP) address, the date and time that you accessed our Website, the website that referred you to our Website, the web pages you requested and the subject of the ads you click or scroll over, and use such information to evaluate Website performance and service quality. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies, which may affect functioning of the Website.
Note that much of this information is not considered Personal Information, under applicable laws. Accordingly, we will comply with our legal obligations regarding such information.
Wherever you have given us your consent to use your Personal Information, you may withdraw your consent at any time by contacting us at: legal@imaginationroom.com. You will no longer be able to access the App if you withdraw your consent.
2. Our Disclosure of Personal Information
IR may disclose your Personal Information with your express consent, for loss or fraud prevention purposes or for IR’s other legitimate interests. IR may further disclose Personal Information if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. We will use reasonable efforts to ensure that any third party to whom Personal Information is disclosed provides a comparable level of protection for your Personal Information, as provided in this Privacy Policy.
We also share some of your Personal Information with third parties in order to offer the App to you, including:
we may disclose your Personal Information to third party service providers for fraud prevention or for law enforcement purposes; and
we may send information to third party service providers that help us to operate the App or our Website, including website hosting, data analysis, event logging, information technology, customer service, user analytics and email delivery and messaging.
Additionally, IR reserves the right to disclose and to transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, merger, amalgamation, or any other type of acquisition, disposition, or financing of all or any portion of IR or any of the assets or shares of IR, provided that the third party represents that it will continue to use the information for the purposes set out in this Privacy Policy and in accordance with applicable privacy laws. IR also reserves the right to aggregate and anonymize Personal Information (or other information) stored on its system and use such aggregated and anonymized Personal Information (or other information) as it sees fit.
3. Retention of Personal Information
We routinely destroy Personal Information that is no longer required for the purposes for which it was collected, in accordance with applicable laws. We will delete your Personal Information when it is no longer required to retain the Personal Information as set out in this Policy or when you request us to do in accordance with this Policy.
4. Accuracy of Personal Information
IR takes reasonable steps to ensure that any Personal Information in our custody is accurate and up-to-date for the purposes for which the Personal Information is to be used by IR. In most instances, we rely on Users of our Website and the App to notify us of any changes to their Personal Information provided by them.
5. How we Protect your Personal Information
IR uses reasonable and appropriate physical, administrative and technical measures, including encryption methods, designed to help you secure your Personal Information against accidental or unlawful loss, access or disclosure. Only staff and service providers who have a legitimate business purpose for accessing the Personal Information collected by us are authorized to do so. Unauthorized use of Personal Information by anyone affiliated with IR is prohibited and constitutes grounds for disciplinary action. Even though we take steps to protect your Personal Information, security breaches cannot be eliminated and we cannot guarantee that your Personal Information will not be disclosed or used contrary to this Policy.
You and you alone are responsible for ensuring that sufficient security software is installed and running on your smartphone or tablet and that your network firewall is of sufficient quality and that your wireless connection is encrypted to a degree that will prevent third party access. IR is not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks. IR also is not responsible for any failure by you to eliminate malware. These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.
6. Location of Personal Information
Personal information we collect is stored and processed by us and our third party service providers primarily in Canada regardless of where you are located.
For Users located in the European Economic Area, we take steps to ensure that adequate protections and appropriate safeguards are in place for your Personal Information. This may include reliance on the adequacy status of the country’s data protection laws (in the case of Personal Information processed in Canada), the incorporation of standard data protection clauses in our agreements with third parties or reliance on an EU-US Privacy Shield registration.
7. Personal Information and Children
We do not knowingly offer Services to anyone under the age of majority in their place of residence. If you are under the age of majority, you may only use the App and our Website with the permission and involvement of a parent or legal guardian.
8. Links to Third Party Sites
Our Website may lead you to third party websites, including websites advertising other products or services. Those organizations are separate and distinct from IR and have their own separate privacy policies. We are not responsible in any way for how any third party collects, uses or discloses your Personal Information, so it is important to familiarize yourself with the privacy policies of these websites before providing your Personal Information to them.
9. Direct Marketing
You may sign up to receive marketing or promotional communications from us. Where you have opted-in, we may use your Personal Information to inform you about us and our products and our services, including promotional offers and events. If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:
using the unsubscribe feature found in our emails and other electronic communications; or
contacting us via email at: legal@imaginationroom.com
10. Your Rights
Upon written request to legal@imaginationroom.com, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to that Personal Information. IR provides an opportunity for individuals to challenge the accuracy and completeness of their Personal Information and have it amended as appropriate. You may also delete the App to stop collection of information.
In addition, you also have the right to:
request a copy of your Personal Information in a structured, machine readable, commonly used format and may request that we transfer this information to another company;
request us to restrict our use or disclosure of your Personal Information;
object to our use or disclosure of your Personal Information; and
request us to delete the Personal Information we hold about you.
11. Contacting us
Accountability with respect to your Personal Information is important to IR. In the event that you have any questions (including how Personal Information is managed by IR), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at legal@imaginationroom.com.
Last Revised: February 3, 2020