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Privacy Policy

Effective Date: May 25, 2018

At L-SPARK Inc. (“L-SPARK”), we are committed to protecting your privacy, and maintain a general policy of openness about how we collect, use and disclose your personal information.

The purpose of this Privacy Policy is to inform you about L-SPARK’s practices relating to the collection, use, disclosure and protection of personal information that may be provided through access to or use of our services and our website or that may otherwise be collected by us.

BY USING OUR SERVICES OR OUR WEBSITE (the “Site”), YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW) IN ACCORDANCE WITH THE FOLLOWING TERMS AND CONDITIONS.

This Privacy Policy also explains how you can contact us if you have a question about, want to make a change to or want to delete any personal information that L-SPARK may be maintaining about you. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.

INFORMATION WE COLLECT & HOW WE USE IT

For the purpose of this Privacy Policy, and in accordance with Canadian privacy legislation, “personal information” is generally defined as information about an identifiable individual, or information that allows an individual to be identified.

The personal information collected by L-SPARK upon using our services or our Site may include at least some of the following:

  • Contact information, including name, company, address, ZIP/postal code, phone number, and email address;
  • Billing information and credit card number;
  • Your service usage;
  • When you provide us with your personal information, we will inform you as to why we are collecting it.

From time to time, we may ask you to provide us with more detailed information regarding your interests in order to serve you better and understand what features and services may be of interest to you. It will be entirely up to you as to whether you choose to share this information with us.

Also, if you send us an e-mail message, we may retain that message and your e-mail address, as well as any response we send you.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

  • Provide you with the L-SPARK services;
  • Research, develop, manage, protect and improve those services;
  • Advise you about any updates or changes to the services that may be of interest to you; and
  • Develop and maintain our relationship with you and communicate with you.

In addition, from time to time, we may use your personal information for the following purposes:

  • to detect and protect L-SPARK and third parties against error, fraud, theft and other illegal activity, and to audit compliance with L-SPARK’s policies and contractual obligations;
  • to understand your needs and preferences, including to contact and communicate with you and to conduct surveys, research and evaluations;
  • to analyze, aggregate and prepare reports and recommendations based on data you provide to us through your use of the service or our Site;
  • for any other purpose we may indicate to you from time to time.

WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

Except with your consent, we will not sell, license, trade or rent your personal information to or with others.

L-SPARK may share personal information with third parties engaged to assist us in providing services (including but not limited to reviewing applications, website development and hosting, data processing, credit card processing, document management and office administration to you or to carry out one or more of the purposes described above. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by L-SPARK and to comply with the general privacy principles described in this Privacy Policy.

L-SPARK reserves the right to disclose personal information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so.

L-SPARK also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of L-SPARK or of any of the business or assets or shares of L-SPARK or a division thereof in order for you to continue to receive the same services from the third party.

KNOWLEDGE AND CONSENT

LSPARK COLLECTS PERSONAL INFORMATION ABOUT YOU ONLY WHEN YOU VOLUNTARILY PROVIDE IT.  Typically, we will seek consent for the use or disclosure of your personal information at the time of collection.  In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.  If you wish to withdraw your consent at any time, please contact our Privacy Officer at 613-271-6305 (ext. 1064) or privacy@l-spark.com. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information that may be of value to you.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.

USE OR DISCLOSURE FOR MARKETING, ADVERTISING AND SPONSORSHIP PURPOSES

We may also use (but will not disclose) your personal information to promote and market additional goods, services and special offers from us, our affiliates and sponsors, including by means of direct marketing.  To ensure advertisers understand who our subscribers are and what they are interested in, we will compile your information and create general profiles of our subscribers’ demographic information and interests. However, we will never share any PERSONALLY IDENTIFIABLE information with our advertisers.

COOKIES

When you visit our Site, we place a text file called a “cookie” in the browser directory of your computer’s hard drive.  A cookie is a small piece of information that a website can store on your web browser and later retrieve. The cookie cannot be read by any website other than the one that set up the cookies.  Aggregate, but not individual, cookie and tracking information may be shared with third parties.

Some third-party services that we use to operate L-SPARK, such as Google Analytics, may place their own cookies in your browser. This Privacy Policy covers use of cookies by L-SPARK only and not the use of cookies by third parties.

HOW WE PROTECT YOUR PERSONAL INFORMATION

L-SPARK makes all commercially reasonable efforts to ensure that personal information collected from you is protected against loss and unauthorized access.  This protection applies in relation to information stored in both electronic and hard-copy form. Access to your personal information is restricted to selected employees or representatives.  In addition, L-SPARK employs robust information security techniques to protect personal information against loss and unauthorized access.

L-SPARK educates all its employees on the importance of privacy.  It is L-SPARK’s policy to give access to personal information only to those employees who require it to carry out the responsibilities of their jobs or to other such third parties with similar designated responsibilities and who are subject to contractual confidentiality restrictions with L-SPARK.

DATA STORAGE

L-SPARK uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run L-SPARK. We maintain two types of logs: server logs and event logs. By engaging with L-SPARK, you authorize L-SPARK to transfer, store, and use your information in Canada and any other country where we operate.

LINKS TO THIRD-PARTY SITES

Our Site may offer links to other third-party websites for your convenience.  You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites.  L-SPARK is not responsible for how such third parties collect, use or disclose your personal information so it is important to familiarize yourself with their privacy policies, which may differ from ours, before providing them with your personal information.  L-SPARK cannot be held liable for your use of such third-party websites.

RETENTION OF YOUR PERSONAL INFORMATION

L-SPARK retains your personal information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws.  When that need has ended, your personal information will be removed from our system and destroyed in a manner that ensures your security.

CONTROL OF YOUR PERSONAL INFORMATION

At L-SPARK, we want you to be able to maintain control over how we use your personal information.  You will always have the option to instruct us not to use your name, e-mail, postal code, etc. beyond providing you with the service or information you requested.  Additionally, e-mail communications will always include an identification of the sender and an “Unsubscribe” option for non-essential email communication. Should you wish to unsubscribe at any time, you may instruct us to immediately do so by clicking on the link.

DATA SECURITY

L-SPARK uses encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the website at your own risk, and you’re responsible for taking reasonable measures to secure your browsing experience.

CHANGES TO OUR PRIVACY POLICY

L-SPARK reserves the right to modify this Privacy Policy at anytime without notice. The Privacy Policy posted at any time or from time to time via this Site shall be deemed to be the Privacy Policy then in effect.

ACCESS TO, CORRECTING OR UPDATING YOUR INFORMATION

If you request access to your personal information, subject to certain exceptions, L-SPARK will inform you of the existence, use and disclosure of your personal information and will provide you with a summary of that information.   If L-SPARK determines not to provide you access to your personal information, we will provide an explanation.

You can help us maintain the accuracy of your personal information by notifying us of any changes to this information.  You may contact L-SPARK in any one of the following ways to request access to or correction or update of your personal information:

E-mail: privacy@l-spark.com

Send Mail: 340 Leggett Drive, Suite 110, Ottawa, Ontario K2K 1Y6

Telephone: 613-271-6305 ext. 1064

CONTACTING US

If you have any questions or requests about L-SPARK’s Privacy Policy or if you have reason to believe that L-SPARK may have failed to adhere to this Privacy Policy, you may contact us at privacy@l-spark.com or call us at 613-271-6305 ext. 1064.

This Privacy Policy is intended to comply with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).

Data Protection Statement for European Union Users

DESCRIPTION OF PROCESSING ACTIVITY

L-SPARK collects and stores personal information about its users only when a user voluntarily provides it through an email opt-in or embedded form. It shares minimal data with its service providers.

Purposes of Processing

  • Gather usage statistics of services
  • Publish and distribute content
  • Collect applications for our accelerator program
  • Fight spam, fraud, and other abuse of services

Categories of Personal Data Collected

  • Email subscribers to:
    • Voice of the North newsletter
    • Talent opportunities newsletter
    • Community events newsletter
  • Dealflow and pipeline data collected in HubSpot

Categories of Recipients

L-SPARK shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

  • Hosting, Storage, & Other Infrastructure
  • Security
  • Analytics
  • Communication & Support

Embedded Content

L-SPARK pages may contain third-party embeds, typically from HubSpot, which may in some cases collect and store personal data. The use of personal data by embedded content providers is not covered by this statement, but by the privacy policies of those sites or services.

Cross-border Transfers

L-SPARK is hosted in Canada. By using L-SPARK’s website, you authorize L-SPARK to transfer, store, and use your information in Canada and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

Retention

L-SPARK retains personal data until a user unsubscribes from our mailing list on HubSpot. If you would like to delete your personal information, you can unsubscribe at any time.

Rights of Data Subjects

If you opt-in to L-SPARK’s mailing list, you may at any time request an export of your personal information by emailing us at privacy@l-spark.com. You may withdraw consent by unsubscribing at anytime. You may object at any time to the use of your personal data by contacting privacy@l-spark.com.

CONTACT INFORMATION

L-SPARK
340 Leggett Drive, Suite 110
Ottawa, Ontario K2K 1Y6
613-271-6305 ext. 1064

Last Updated: May 25, 2018