Last Update: November 2020

Highground Ontario Inc. dba EVNTL and its divisions, affiliates and subsidiaries (hereinafter “Company”) respects the privacy and the integrity of any information that you provide in the use of our Site and Services. This Privacy Policy explains our policy regarding the collection, use and disclosure of your personal information.

This Privacy Policy will be continuously assessed against new technologies, business practices and our users’ needs. As we update, expand and diversify our products and services, this Privacy Policy may evolve. Please check this Privacy Policy from time to time for updates by checking the date of the “Last Update” at the top of this document. If we make any material changes to this Privacy Policy, we will notify you here. A link to our Privacy Policy will be provided at the bottom of each web page on our Site. You acknowledge and agree that your access of our Site and your use of our Services following any posted changes to the Privacy Policy indicate your acceptance of such changes.

Application of this policy

The Company is committed to protecting the privacy of our users, It is our policy to comply with applicable privacy laws and to use your personal information with your consent for reasonable purposes related to the Services, to provide you with the Services, to enhance your experience with all of our products and services, and to improve our offerings. We do not sell, rent or lease our customer lists to third parties. It is our policy to only disclose your personal information as required or authorized by law.

We hope this Privacy Policy will answer your questions regarding how we treat personal information gathered from visitors to our Site and users of our Services. This Policy applies to our collection, use and disclosure of your personal information in connection with your use of the Application, the Content, the Services and the Site as defined in our TERMS OF SERVICE Agreement with you. In addition, our services use Google Maps API(s) and Twitter, and as such you are subject to Google’s Privacy Policies found at https://policies.google.com/terms and https://twitter.com/tos, and incorporated herein by reference. If you do not agree to any of these Terms of Service or the Google or Twitter Privacy Policy please do not use Services.

What is personal information?

For the purposes of this Privacy Policy, personal information means information that can be used to identify and contact you, specifically your name, mailing address, e-mail address, country of residence, as well as other information when such information is combined with your personal information. Personal information does not include “aggregate” or “anonymized” information, which is data we collect about the use of our site and our services. Our privacy policy does not restrict or limit our collection and use of aggregate or anonymized information.

Consent and Collection, Use and Disclosure of Personal Information

We may collect your personal information or data from third parties if you give permission to those third parties to share your information with us or if they interact in some way with the Service. Any third parties’ use of your personal information or data is governed by their own privacy policy (which should be accessible from their website or application). If you do not want third parties to be able to access or use your personal information or data, you should not register for, click on or use the applicable third party application or product. In the event that we do not directly collect personal information or data from you we may refer you to such third party application or product to address any concerns you might have about your personal information or data.

We may collect personally identifiable information (“PII”) from, which may include your name, date of birth, sex, email address, locations, address, phone number, marital status, children and ages, household income, credit card information, unique device identifiers and preferences, among other things, in order to provide the Services to you. We may use analytics and consumer behaviour data to make the Services more convenient or more efficient, or to monitor use of the Services in order to improve the Services.

When you provide your personal information to us, you provide us with your consent to use and, to the extent reasonably required, to disclose your personal information as described in this Policy or as described in any applicable consent you may provide.

We may collect, use and disclose your personal information for the following purposes:

  • To provide the Services to you;
  • To make enhancements to the Services to provide a better experience for you;
  • To create, manage and control your account information;
  • To communicate with you for the purpose of informing you of changes or additions to the Services, or of the availability of any products or services we provide;
  • To provide you with targeted ads, offers, coupons and other products and services based on your preferences and channels of interest;
  • To process payments for any offers, coupons and other products and services purchased via the Application;
  • To assess service levels, monitor traffic patterns and measure usage of different service options;
  • To verify access rights to the Services, or other products, services or software;
  • To conduct market research from time to time;
  • To enforce the provisions of our legal relationship with you;
  • To respond to your requests for the Services, including but not limited to customer service or information;
  • To respond to claims of any violation of our rights or those of any third parties;
  • To respond to your requests for the Services, including but not limited to customer service or information;
  • To protect the rights, property or personal safety of you, us, our users and the public;

As required or authorized by law, your consent may be withdrawn at any time. Should your consent be withdrawn, we will advise you of any consequences, which may include our being unable to provide all or part of the Services to you. The law allows us to retain personal information following withdrawal of consent for reasonable business or legal purposes, following which personal information is securely destroyed or rendered anonymous.

You may have the option of registering with us to create an account so that we may better serve your needs and enhance your experience with our applications and services. Installing and/or using the Applications and Services may not require that you provide any personal information to us. However, the operation of the Application and Services may result in your receiving offers, coupons or other information that we feel may be of interest to you, based on any stated preferences you may provide to us or on your location. To cease receiving such information, you may uninstall the relevant Application or stop using the Application or Services at any time.

In some cases, our industry partners may have agreed to pre-load the Application on their mobile devices. If your mobile device has the Application pre-loaded, the Application cannot be uninstalled. However, you will not receive the above information as long as you do not utilize the Application.

Information, including personal information, is currently stored on our secure servers located worldwide. We may provide some of your personal information to our service providers to process payments for any offers, coupons or transactions you purchase through the Application.

You agree that Company may disclose your personal information in the circumstances set out below:

Company may disclose your personal information with your prior consent;

  1. Company may be required by law to disclose personal information without your consent in the event of emergency situations or when required by government or other legal authority;
  2. Company may also disclose personal information to third parties in connection with a corporate re-organization, merger or amalgamation, or the sale of all or substantially all of our assets, provided that, where appropriate, any party to whom the information is disclosed is bound by agreements or obligations, and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise; or
  3. Company may share your personal information with service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, collect debts, to provide data storage, to host websites, to fulfill orders, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service. Each company is bound by agreement or obligations with Company to implement and maintain reasonable security procedures and practices in order to use and disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
  4. We share the information we collect with third-party business partners who commit to comply with applicable laws concerning their usage of the information. Our third-party business partners may share the information with their own third party business partners and use the information either for themselves or on behalf of their own business partners to:
    • Operate and improve their services;
    • Provide you with advertisements and information for products and services or send you other notifications based on variables such as your location, and assess your level of engagement with them; and
    • Carry out other purposes that are disclosed to you and to which you consent.

Security

Company stores and process your personal information on our computers in Canada and the U.S. Company employs reasonable managerial and technical measures to ensure that your personal information is secure. In addition, our dedicated team of information technology professionals works to maintain data accuracy and prevent unauthorized access to sensitive information.  Unfortunately, no security system can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the security of your personal information and cannot assume liability for improper access to it. The Internet is not a secure medium and you acknowledge and agree that the privacy of your e-mail communication and personal information can never be guaranteed as any e-mail communication may be lost, intercepted or altered. By using our Site, or providing personal information to us through any means, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Site and our Services.

In the unfortunate event that we suffer a loss of personal information, or unauthorized access to or disclosure of personal information, we will notify any affected individuals as required by law.

Anonymized and Aggregated Data

“Anonymized Data” means records which have been stripped of personally identifying information, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information are not available in Anonymized Data. We may combine or aggregate Anonymized Data with other anonymized data or with other information to generate “Aggregated Data”.  Anonymized Data and Aggregated Data may be used by us for any purpose including but not limited to internal and commercial use and for sharing with affiliates, subsidiaries and business partners and for planning and marketing purposes.

External Links

Our Sites are connected by “hyperlinks” to other websites. You acknowledge and agree that Company makes no representation, warranty, covenant, or claim regarding, and Company expressly disclaims and denies any responsibility or liability for, directly or indirectly, the privacy practices on any third-party website or resource accessible by hyperlink from our Site. You agree that the inclusion of any such hyperlink does not suggest, represent, warrant, covenant or imply that Company monitors, endorses or exerts any control over such website or linked resource whatsoever.  You agree that Company provides these hyperlinks to you only as a convenience, and the inclusion of any hyperlink does not suggest, represent, warrant, covenant or imply affiliation, endorsement or adoption by Company of any such website or linked resource whatsoever.

When you leave our Site, you acknowledge and agree that our terms and policies do not govern your access to, and use of, other websites. You acknowledge our recommendation to review the applicable privacy and data gathering practices, of any website or linked resource to which you navigate from our Site.

Contact Us

If you have any questions or suggestions regarding this Policy or our practices regarding personal information, if you wish further information, if you wish access to your personal information, or if you wish to modify or correct your personal information, please email our privacy officer at info@evntl.com. You may also write to us at: 100 Commerce Valley Drive East Suite 200 Thornhill, ON Canada L3T 7R1.

Children

This Site and Service is not intended for use by children, especially those under age 13. No one under age 13 is allowed to register for the Service or provide any personally identifiable information or use our social, community and public discussion areas, photo and video galleries, bulletin boards, forums, chats, blogs, personal/job search and other classified ads, and elsewhere. You affirm that you are 13 years of age or older, or an emancipated minor, or, if between the ages of 13 and 17, possess legal parental or guardian consent, including permission of parent(s) or legal guardian(s) before making purchases, including subscriptions, on this Service.  In addition, you affirm that you are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in these Terms of Service, and to abide by and comply with these Terms of Service.

Access to your personal information

You are responsible for updating and maintaining the truth and accuracy of the personal information you provide to us relating to your Account. If you want to update the personal information, you have provided to us, you should do so by visiting the “Account” section of the Web site. You must be signed in to access your Account.

There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you.  In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.  If we do not provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Collection of non-personal information

You acknowledge and agree that from time to time Company, its service providers and business partners  may collect non-personal information from your use of our Site  and Services such as server log files, environmental variables (such as MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version) and from scanning navigational data to collect non-personal information about our users in order to help us deliver better service and user experience. Such non-personal information could include the IP addresses or areas of site being clicked on most frequently. Company and our service providers (including ad servers, outbound email vendors, affiliate vendors and search engine advertising agencies, and providers of web analytics tools) and business partners may also use “cookies” as well as so-called “pixel tags,” “web beacons,” “clear GIFs” and other similar technologies to help us deliver better service and user experience and to facilitate your ongoing access to and use of our services. Cookies are files saved to your computers through your Web browser to enable websites or service providers systems to recognize your browser and capture and remember certain information. Company, like many other Web services, uses cookies to understand and save your preferences for future visits and to compile aggregate data about site traffic and site interaction, so that we can offer better site experiences and tools in the future. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. If you choose to reject all cookies, you may not be able to access the services. To learn more about cookies, please visit http://www.allaboutcookies.org. You may find more information about opting out of most third-party service cookies at www.networkadvertising.org or other related sites.

Interpretation of this Privacy Policy

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Company any obligations, in addition to any rights or obligations imposed by Canada’s applicable federal and provincial privacy laws.  Should there be any inconsistency between this Privacy Policy and Canada’s applicable federal and provincial privacy laws, this Privacy Policy will be interpreted to comply with the applicable privacy laws.

Any services provided by Company is controlled and operated by us from Canada, and we do not intend that our services subject us to the laws or jurisdiction of any state, country or territory other than that of Canada. We do not represent or warrant that the services, or any part of the services, are appropriate or available for use in any particular jurisdiction. Those who choose to access the services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the services’ availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

© Highground Ontario Inc. November 2020