1. Your Privacy

This privacy policy (this “Privacy Policy”), as amended from time to time, applies to all of the products and ser­vices created and offered by 542 Entertainment Inc. or its subsidiaries and affiliates (collectively, “Corporation”).

Corporation respects the privacy rights of its customers and visitors (the “Users”) and is committed to protecting the information collected through its services and websites (collectively, “Services”). Corporation has adopted this Privacy Policy to explain how Corporation collects, stores, and uses the information collected in connection with the Services.

The English version of the Privacy Policy is the governing version. Any translation of the Privacy Policy is just a reference for your convenience and should not be relied on in legal proceedings.


  1. Information We Collect & How We Use It

Corporation may collect and use both personal and non-personal data from Users using the Services. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used.

2.1.      Personal Data

2.1.1.   Definition

For the purposes of this Privacy Policy, “personal data” means personally identifiable information that specifical­ly identifies Users as individuals and includes those items listed below.

2.1.2.   Registering for Services

Users may make personal data such as their name, email address, username and password available to Corporation when they register for Services, enter contests and special events, subscribe to newsletters, request technical sup­port or otherwise communicate with Corporation, and when using Corporation’s Services where personal data is required for use and/or participation.

2.1.3.   Information about Users Received from an SNS

When Users access the Services through a social networking site (“SNS”) such as Facebook or Google +, Users allow Corporation to access certain information from their profile for that site. The information Users allow Corporation to access varies by application and SNS, and it is affected by the privacy settings Users and their friends establish at the SNS. Users can control and find out more about these settings at the SNS sites that they use. For example, Corporation may access and store some or all of the following information, as allowed by Users, the SNS and their pref­erences:

  • first and last name;
  • profile picture or its URL;
  • user ID number, which is linked to publicly available information such as name and profile photo;
  • the user ID numbers and other public data for Users’ friends;
  • the login e-mail provided to that SNS when Users register;
  • Users’ physical location and that of Users’ access devices;
  • gender; and

By using the Services through an SNS, Users are authorizing Corporation to collect, store, and use, in accordance with this Privacy Policy, any and all information that Users agreed the SNS could provide to Corporation.

2.1.4.   Optimize User Experience

Corporation may collect, store and use personal data to provide Users with an optimized user experience. For example, the information collected may be used to create Users’ accounts, provide enhanced interaction with Corporation’s websites, manage any in-application features, provide technical sup­port and respond to Users’ inquiries.

2.1.5.   Mobile Devices

If Users access Corporation’s Services on mobile and tablet devices, Corporation may collect device identifiers, including MAC Address and IP Address, and Corporation may assign to devices an identifier that is similar to an account num­ber. Corporation may collect the name Users have associated with their device, device type, telephone number, country, and any other information Users choose to provide, such as user name, character name, geo-location or e-mail address. We may also access Users’ contacts to enable Users to invite friends to join them in the Services.

2.1.6.   Other Purposes

Additionally, Corporation may collect, store, and use personal data to solicit Users’ feedback to help improve the Ser­vices and other Corporation products, inform Users about new products or promotional material offered by Corporation or its trusted third party business partners and affiliates, notify Users about changes to Corporation’s Services or other products, provide Users with advertising and marketing material from Corporation and its trusted business partners and communicate with Users for other commonly accepted purposes such as notifying them that they are a po­tential winner of a contest.

Finally, Corporation may collect and use personal data as required or permitted by applicable law.

2.1.7.   Data Storage

Corporation may store and/or transfer personal data outside of Canada in accordance with applicable legisla­tion and this Privacy Policy.

2.1.8.   Third Party Privacy Policies

While accessing or using the Services, Users may interact with third parties, such as mobile software platforms and social networking services. Users recognize and agree that Corporation is not liable for their use of Users’ personal data and Users should review the privacy policies of these third parties.

Corporation may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, Users are using products or services that are not affiliated with or controlled by Corporation. Corporation is not responsible for those people or companies, the content of their prod­ucts or services, the use of information Users provide to them, or any products or services they may offer. Pro­viding links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies.

2.1.9.   User Generated Content

Users should be aware of the open nature of certain social networking and other open features of the Services Corporation may make available to Users. Users may choose to disclose data about themselves in the course of con­tributing user generated content to the Services including, but not limited to account personas, pictures, forum posts, chat posts, tweets, Facebook postings, profiles and any other text, widgets, messages, links, emails, video, sound, graphics, code and all other audio visual or other material appearing on or emanating to and/or from the Services and any content contributed by the User to the Services (“User Content”). Any User Content that is dis­closed during use of the Services is public information, and there is no expectation of privacy or confidentiality. Corporation is not responsible for any personal data Users choose to make public in any of these forums.

2.1.10.             Minors

Corporation does not knowingly collect any personal data from children below the age of 13 without receiving the con­sent of a legal guardian. If Corporation learns that it has inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, Corporation will take reasonable measures to promptly erase such personal data from their records.

2.2.      Non Personal Data

2.2.1.   Definition

For the purpose of this Privacy Policy, “non-personal data” means: (1) information that does not directly identify Users; and (2) “aggregate” and “de-personalized” information, which is data Corporation collects about the use of Corporation Services, from which any personally identifiable data has been removed.

Corporation may use tools or third party analytical software to automatically collect and use certain non-personal data. You will not be identifiable through the use of these tools or third party analytical software. The types of non-personal data Corporation may collect and use include, but are not limited to:

  1. Device properties, including, but not limited to:

(a) IP address;

(b) Media Access Control (“MAC”) address; and

(c) Unique device identifier or other device identifier (“UDID”);

  1. Device software platform and firmware;
  2. Mobile device carrier;
  3. Geographical data such as zip code, area code and coarse location; and
  4. Other non-personal data that Corporation may require to enhance the Services and other Corporation products.

2.2.2.   Trusted Partners and Contractors

Corporation may use and disclose to its affiliated companies, contractors, participating sports leagues and teams or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of Corporation’s Services, offering products and services to Users and to further develop the Services and other Corporation products.

2.2.3.   Cookies, Beacons and Tracking

Corporation may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. Corporation treats information collected by cookies and similar technologies as non-personal data.

A “cookie” is a small bit of record-keeping information that is sent to the Users’ computer. Corporation’s cookies do not include personal data and may be used to: (1) facilitate Users’ login authentication, (2) help Users navigate around the Corporation website, (3) monitor how many people are using the Services, and (4) store Users preferences and track trends.

Most browsers are initially set up to accept cookies, but Users can disable cookies or set their browser to indicate when a cookie is being sent. However, disabling cookies may affect Users’ ability to use the Services.

Corporation may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember Users’ settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate.

Users may prevent locally shared objects from being placed by disabling locally stored objects in their browser or by visiting www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.

Corporation may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic commu­nications Corporation sends to you may contain pixel tags that enable Corporation to track your usage of the communication, including whether the communication was opened and/or what links were followed.

2.2.4.   Ad Serving Technology

Corporation reserves the right to use and disclose the collected non-personal data for purposes of advertisement by Corporation or Corporation’s trusted partners and contractors. Corporation may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through the Services.

Corporation or third parties operating the ad serving technology may use demographic and location information as well as information logged from Users’ hardware or device to ensure that appropriate advertising is presented within the Service. Corporation or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-app information.

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. Users recognize and agree that the advertising companies who deliver ads for Corporation may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services; if Users do not want to be subject to this technology, do not use or access the Services. Although Corporation may take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, Corporation does not have access to or control of third party technologies.

  1. Who We Disclose Personal Data To

3.1.      Disclosure of Personal Data

In providing the Services, Corporation may disclose the personal data to other companies or individuals in the follow­ing limited circumstances:

  1. In accordance with the purposes outlined in this Privacy Policy;
  2. In cases where Corporation receives Users’ consent;
  3. Corporation has a good faith belief that access, use, preservation or disclosure of such personal data is reason­ably necessary to;

(a) satisfy any applicable law, regulation, legal process or enforceable governmental request;

(b) enforce applicable Terms of Use including investigation of potential violations thereof;

(c) detect, prevent, or otherwise address fraud, security or technical issues; or

(d) protect against imminent harm to our rights and/or property, or

  1. As required or authorized by applicable law.

Corporation may also disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of providing marketing and advertising content to Users. Corporation requires that these parties agree to process such personal data based on Corporation’s instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. Users can unsubscribe from this service at any time.

3.2.      Data Processing

Corporation may also disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. Corporation requires that these parties agree to pro­cess such personal data based on Corporation’s instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures.

3.3.      Sale of Business

As Corporation continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If Corporation becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy.

  1. Choices for Personal Data

If Corporation proposes to use personal data for any purposes other than those described in this Privacy Policy, Corporation will obtain the Users’ prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes.

Users may choose to withdraw their consent to the use, collection or disclosure of personal data outlined in this Policy at any time. If a User withdraws his or her consent, then Corporation may no longer be able to provide the same level of Services.

Users are also given the opportunity to “opt-out” of having their personal data used for purposes such as receiv­ing newsletters or other information from Corporation.

Withdrawals of consent will not have an effect on data that Corporation has provided to third parties in accordance with this Privacy Policy prior to such withdrawals.

  1. Information Security

Corporation takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. Corporation employs physical, electronic and/or procedural safeguards to protect its systems and all personal data under its control against unauthorized access and use. All safety and security mea­sures are appropriate to the sensitivity level of the information collected.

  1. Accuracy and Access/Control over Personal Data

Corporation processes personal data only for the purposes for which it was collected and in accordance with this Policy. Corporation may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but Corporation is not responsible for verifying the correctness of personal data.

Corporation will allow Users to access their personal data in the custody or control of Corporation, and will allow them to:

  1. update or correct such personal data;
  2. change User preferences with respect to communications, push notifications and other information re­ceived from Corporation or third parties; or
  3. delete the personal data of the Users on Corporation’s systems (by submitting a request to Customer Support).

Such updates, corrections and changes will not have an effect on other information that Corporation maintains, or information that Corporation has provided to third parties in accordance with this Privacy Policy prior to such update, correction or change.

  1. Retention of Personal Data

Corporation stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law.

Corporation may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Corporation’s user agreements, and comply with technical and legal requirements and constraints related to the securi­ty, integrity and operation of the Services.

  1. Enforcement

It is Corporation’s policy to contact a complaining user regarding his or her concerns. Corporation will cooperate with the ap­propriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Corporation and an individual.

  1. Changes to this Policy

Corporation reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If Corporation makes material or significant changes to this Privacy Policy, Corporation may post a notice on Corporation’s website along with the updated Privacy Policy. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

  1. Contact Information

Should you have any questions relating to this Privacy Policy, please contact our Privacy Officer at Suite 1240 – 1140 West Pender Street, Vancouver, BC V6E 4G1, at 604-418-8062 or baasen@542entertainment.com.