Thank you for visiting the Circular Innovation Fund website and taking the time to read and understand our Privacy Policy (hereafter the “Policy”).

By using this site, our systems or our services, you acknowledge that you have read and understand the Policy and agree that we use and process your personal data and information in accordance with the Policy, where applicable.

The Policy comprises the following:

  1. Privacy Policy goals / scope and application
  2. Purposes of data collection
  3. Terms and conditions / guidelines for obtaining consent
  4. Goals of data collection / use of collected information
  5. Purposes of data processing / data retention
  6. Personal information collected / data security
  7. Data processing / disclosures
  8. Terms and conditions regarding the control of personal information / regulatory compliance and enforcement
  9. Reasons to share personal information with third parties / commercial data transfer
  10. Use of cookies and similar technologies / your rights and options
  11. Retention of personal information
  12. Personal information protection officer

1. Privacy Policy goals / scope and application

We firmly believe in the right to privacy; this Policy has been specifically designed to uphold this right in accordance with the applicable laws.

In keeping with this position, Circular Innovation Fund undertakes to collect, process and share personally identifiable information (PII) only when the individual who is the subject of the information has provided their consent to do so, unless otherwise required or permitted by law, in which case consent will not be required.

The aim of the Policy is to inform users of why and how Circular Innovation Fund, or any individual acting on its behalf, collects and uses personal information. It has been drafted in plain language to allow for informed user consent.

For the purposes of this Policy, “personal information” refers to any information pertaining to an identifiable individual or any PII. When possible, we shall use acronyms, pseudonyms or aggregate information to render any such personal information personally unidentifiable.

2. Purposes of data collection

Personal information is collected and used for purposes such as:

  • Enabling you to access our services and make proper use of them.
  • Processing your requests, including inquiries and bookings.
  • Enabling you to apply for a job posting.
  • Enabling you to sign up to our newsletter or an activity.
  • Addressing reported issues, including troubleshooting, support, optimization, website security breach reviews and/or data recovery.
  • Assessing, optimizing and improving website content and features.
  • Contacting you regarding a request or your experience with our services or website.
  • Offering advertising content, including through remarketing, and improving ad and service content to better suit your needs and interests.
  • Tracking your use of website features.

We use your personal information solely for the purposes for which it was collected.

3. Terms and conditions / guidelines for obtaining consent

We shall obtain an individual’s consent before collecting any of their personal information. Consent may be express or implied, and can be provided directly by the individual or by an authorized representative.

We recommend express consent given orally, electronically or in writing. However, implied consent is acceptable should it be reasonably inferred from an individual’s action or inaction. For instance, providing a name and address to receive a publication or providing a name and telephone number to obtain a response to a question may be construed as implied consent for the collection of personal information. The sensitivity of the targeted personal information, the purpose of their collection and reasonable expectations of a person in a similar situation determine the proper type of consent.

When you access this service, your computer and our server automatically exchange data. This exchange of information is necessary if the server is to send you a file that is compatible with the computer equipment you use. The following data is exchanged:

  • ISP
  • Your IP address (unique string of numbers that identifies a specific network device; e.g., 123.45.67.890)
  • Browser (e.g., Chrome, Safari, Firefox, Explorer) and operating system (e.g., Windows, Mac OS)
  • Pages you visit
  • Date and time you accessed the pages
  • Referring URL (if accessed through another site)

Most information exchanged automatically between computers do not allow personal identification. This information is collected solely to meet the technological requirements for Internet browsing and is stored for statistical purposes (number of visits, most visited pages, technology used, referring sites and users’ country of origin).

Use of cookies

Cookies are used to facilitate navigation in the pages of this service. These cookies do not allow us to retrieve personal information. While you can disable cookies at any time in your browser’s settings, this may prevent you from accessing certain features on the site.

If you use a computer in a public location or share your computer with other users, make sure to delete your browsing history at the end of each session.

Use of Google Analytics

This site uses Google Analytics, a web tracking and reporting tool. Using cookies, Google Analytics gathers non-personal aggregate statistics to analyze how visitors use the website.

The information collected relates to your use of this site; it is kept on servers located in the United States and elsewhere. Google may disclose this information to third parties if required by law or if the information is processed by such third parties on behalf of Google.

The information collected by the tool includes pages visited, date, time, length and frequency of visits, links used, operating system and language, the name of your Internet service provider, and your geographical position (region). It also includes your IP address, which is truncated/anonymized to ensure the confidentiality of your personal information. IP address anonymization prevents the identification of an Internet user from their IP address.

Google uses the collected information solely for statistical and reporting purposes regarding the use of this site, allowing Circular Innovation Fund to enhance its electronic service delivery. Under no circumstances will Google associate the information collected through this site with any other retained data.

If you wish, you can prevent the recording by Google of any information regarding your use of this site by installing the Google Analytics Opt-out Browser Add-on on your computer.

Personal and confidential information

Circular Innovation Fund may also gather some of the personal information, including your full name, mailing address, email address and phone number, you voluntarily provide when using the features of our website (e.g., when applying for a job posting, signing up for an activity and/or our newsletter, and booking a visit). These features lead to the exchange of your personal or confidential information between the service and our various partners (hosting service provider, web developer, marketing agency, etc.). Such partners will comply with applicable laws to maintain the confidentiality of this information.

By using this service, you agree to the exchange of the following information between the service and our partners:

  • Answers provided to questions (e.g., first and last name, phone number, email address)
  • Marketing preferences (e.g., if you wish to receive our marketing communications or newsletters)

Should we want to use your personal information for any other purposes, we will provide a description of the intended use and request your consent once again.

It is not always possible, including at the request of the State, to obtain consent from an individual to collect, use or disclose their personal information. We will never share this type of information otherwise than as is provided by this Policy, except where permitted or required by law.

4. Goals of data collection / use of collected information

The collected information is gathered for the purposes and goals set out in this Policy.

The purposes of information collection are as follows:

  • Relationship management
  • Product and service delivery personalization
  • Tracking history and booking activities
  • Fraud prevention and risk management
  • After-sales support/service for our products/services

Marketing

We will send you marketing communications using data you provide when you make a purchase or if you express real interest in making a purchase, and if you do not opt out of our marketing communications, to the extent permitted by applicable law.

You may opt out of our marketing communications at any time by clicking on the unsubscribe link at the bottom of each communication.

If you choose to unsubscribe from our marketing communications, we will continue to use your personal information for other relevant activities, including non-marketing messages such as booking or registration confirmations.

  • Providing our products and services: We will collect and process the data and information needed to fulfil our mandate and meet our contractual obligations.
  • Maintaining and enhancing our products and services: Data collected through your interactions with our services may be used to analyze and enhance the performance of our products and services.
  • AI and developing new products and services: Collected data may be used for research and development purposes to offer new products and services to our users, including through advertising and marketing messages. Furthermore, aggregate data will likely be processed using AI algorithms.
  • Offering personalized products and services: The collection and analysis of data generated through your interactions with our services allow us to develop and create relevant products and services in an effort to best meet your expectations, including to perform adjustments for customers in need.
  • Assessing product and service performance: Data is collected (including through surveys) to obtain information on the strengths and weaknesses of our products and services in an effort to assess them and resolve any issues. This allows us to ensure the quality of our products and services, while supporting risk management.
  • Protecting the privacy of our users: Collected data allows us to verify the identity and protect the privacy of those who contact us by phone, email or otherwise.
  • Meeting legal obligations: Data is collected to meet obligations provided under laws, regulations or international treaties.

5. Purposes of data processing / data retention

Circular Innovation Fund may collect personal information in various forms, but may only do so by lawful means and solely for the necessary purposes disclosed, as outlined in this Policy, or as required or allowed by law. Pursuant to regulatory provisions, personal information will be retained for a period of two (2) years for the following purposes:

● Providing adequate access to the service
● Fully responding to your requests
● Achieving the aims stated
● Offering our products and services
● Fulfilling legal obligations
● Solving disputes
● Applying the terms of an agreement

Following this 2-year period, we will anonymize the information or destroy it to safeguard it against unauthorized access and disclosure.

Collected personal information and its sensitivity may vary according to the context surrounding the interactions between you and Circular Innovation Fund. We must therefore prioritize establishing the type of personal information used.

We protect all the personal information we collect. Among the personal information that may be collected and used, information that requires special attention includes (but is not limited to) the following:

Name and coordinates. First and last name, email address, mailing address, phone number and other similar data for contact purposes.

Credentials. Password, password hints and other similar security information allowing to identity you and access your account.

Demographics. Information about you (e.g., age, gender, country, language preference).

Payment details. Data required to process your payments, including payment instrument number (e.g., credit card number) and corresponding security code.

Subscription data. Information pertaining to event-related and newsletter subscriptions.

Sound and image data. Audiovisual data allowing to ensure the safety of our users, including on the sites of events we organize or host.

Interaction-based data. Data related to your use of the websites, platforms or tools created. You provide this data to use the products. In other cases, such as error reports, we generate the data.

Other examples of interaction data that we collect include:

  • Data on the sites visited and how they are used. For example:
    • Payments and account history. Data on the items you purchase and account activity.
    • Problem-solving and support data. Data you provide when you contact Circular Innovation Fund for assistance, including the products you are using, and other information that helps us solve your problem.
  • Interest and preference-related data. Data on your interests and preferences, what you enjoy, etc. Besides the information you share explicitly, other information we collect allows us to establish or guess your interest and preferences.
  • Data relating to content consumption. Data on the multimedia content (e.g., television, videos, music, audio content, books, apps and games) you access through our products.
  • Search and command data. Search queries and commands you use when you use our website.
  • Text, entry and handwritten input data. Text, entry and handwritten input data, and any other related information.
  • Location data. Specific or non-specific data on the location of your device. For example, it is possible to retrieve location data from a device’s IP address, or account profile data showing your location with less accuracy (city or postal code).
  • Other data. Other data provided when you use our website, including data from Google Analytics.

6. Personal information collected / data security

Provision of our products and services. We use the data to operate our products and services and provide rich and interactive experiences. All personal information and other data are kept on servers in Canada with high security ratings and protection against non-compliant uses and non-authorized access. We endeavour to maintain the required physical, administrative and technical security measures in our offices and data retention centres. Access to personal information is granted solely to individuals (employees or agents) requiring such access to fully perform their duties.

We will use all reasonable means to protect the personal information provided during your use of the website. More specifically, we will employ technical and organizational means to protect personal information against loss, theft or unauthorized access or disclosure, both internally and externally.

However, as there is no such thing as a perfectly secure system, you should be aware that there will always be a certain risk of a security breach. Circular Innovation Fund shall not be liable for any disclosure of your personal information except in the case of negligence on our part.

All data, including personal information, collected through your use of the website is stored on servers in Canada. However, this data may be processed by third-party service providers located outside of Canada, to assist Circular Innovation Fund in fulfilling its mandate, in which case we will take all reasonable measures to ensure such third-party services providers are bound by the appropriate safeguards.

For example,

Our data is collected by two systems, one of which is FileMaker Pro which collects orders made exclusively to shoe stores. Data backup is performed by Carbonite Safe CE 23.3 in Montreal. Our invoice management and order dispatch software is called PG2. PG2 is an external system that does not belong to us. It is based in Quebec City.

Product/service enhancements. We use the data to enhance our products, namely by adding new features or capabilities (error report when purchasing a ticket or viewing a program online, etc.).

Personalization. Some products include personalized features such as recommendations that optimize your experience and maximize your satisfaction. These features use automated processes to adapt your experiences based on the collected data (e.g., inferences made about you and your use of the product, activities, interests and location).

Product/service development. We use the data to develop new products. For example, we use anonymized or pseudonymised personal information to better understand our customers’ needs.

Customer support. We use the data to troubleshoot and solve product/service-related problems, restore access to your personal account, and provide other support and assistance services.

Security and problem-solving. We use the data to heighten security and contribute to product/service-related problem-solving. This includes using data to ensure the security of the services provided to our customers, to detect malware and malicious activities, to resolve performance and compatibility issues to help customers get the most out of their experience, and to inform them of product/service updates. This may include the use of automated systems to detect security concerns.

Safety. We use the data to protect the security of our products and of our customers. Our security features can prevent the proper operation of malware, inform users when malware is detected on their device, or even enable videosurveillance to ensure public safety during events.

Surveys and promotional communications. We use the collected data to provide surveys and promotional communications. You can subscribe by email, complete surveys, and opt in or out of promotional communications from Circular Innovation Fund by email, text message, mail or phone. To learn more about how coordinates, electronic subscriptions and promotional communications are managed, please refer to the section of this Policy on the terms and conditions for accessing and controlling personal information.

Relevant offers. Circular Innovation Fund uses data to provide relevant and important information regarding available products/services. We analyze data from various sources to predict what information will be most interesting and relevant to you, and to communicate it to you in different ways. For instance, we predict your interests in terms of concerts and offer new activities that are likely to please you.

Advertising. Circular Innovation Fund uses the data collected through our interactions with you, some of our products and third-party websites to advertise our products/services, including on third-party websites. We may sometimes use automated processes to render more relevant advertising.

Commercial transactions. We use data to process your transactions with us. For example, we process payment information to provide product subscriptions to customers and we use coordinates to deliver products purchased online.

Reporting and commercial operations. We use data to analyze our operations and improve decision-making. This allows us to make informed decisions and generate performance reports.

Protection of rights and property. We use data to detect and prevent fraud, resolve disputes, implement contracts and protect our property. For example, we use data to confirm the validity of purchased tickets to fight fraud. We may use automated processes to detect and prevent activities in violation of our rights and the rights of third parties.

Legal compliance. We process data to ensure legal compliance. For instance, we use the age of our customers to ensure compliance with youth privacy laws and to make certain each customer meets the age recommendations set for the target audience. We also process coordinates and credentials to help customers exercise their data protection rights.

Searches. We use data to perform searches, including searches for scientific purposes and searches conducted in the public interest, when permitted by law.

7. Data processing / disclosures

Circular Innovation Fund takes the security of your personal information extremely seriously and undertakes to process your information in accordance with industry standards and solely for the purposes for which it was collected, as stated herein or in a specific notice to that effect. However, considering the security limits inherent to web-based transfers, absolute data security is unachievable. The transfer of information by the user is at their own risk.

Service providers

We may turn to outside firms and third parties to administer and deliver services on our behalf (e.g., perform data processing and storage, analyze the quality of customer service, perform tracking tasks, manage bookings, subscriptions and staffing, provide marketing services).

In such cases, we will take all necessary measures to ensure such third parties have access to and process solely the information required to fulfil their mandate and have implemented measures to protect personal information in compliance with applicable laws and the conditions and levels of protection stated herein.

Third-party apps and software

We use apps and software, for instance, to process activity subscriptions, newsletter subscriptions and bookings. The information collected by external developers (if applicable) varies according to the features and functions of the app or software. In some cases, the developer collects no personal information whatsoever. In other cases, the developer collects personal information for the sole purpose of providing their services.

Links and third parties

The website may contain sharing or posting options, or links to third-party websites or platforms. By using or activating such links or features, you thereby leave our website and the terms of use and privacy policy of the third party thus come into effect.

We have no control over such platforms and accept no liability for such platforms despite them being listed on our website.

8. Terms and conditions regarding the control of information / regulatory compliance and enforcement

Circular Innovation Fund ensures that all personal information under its control is as accurate, current and complete as required for the purposes for which it is to be used.

You have the right to request access to your personal information for verification purposes and to request corrections be made should the information be inaccurate. If you think your personal information is inaccurate or if you want to access your personal information, you can submit a request to the coordinates provided at the end of this Policy.

We will do everything we can to provide timely access to your personal information. However, for security purposes, we may need to verify your identity.

Also, there may be circumstances in which we are unable to provide access to your personal information, for instance, when such access may lead to the disclosure of another individual’s personal information and such individual refuses to provide consent for such disclosure, or where legal restrictions apply. In such cases, we will inform you of the reason we are unable to provide access to your personal information.

Should your request concern data appearing on third-party web pages or platforms, please contact the third party directly.

We may disclose your personal information to the government, to law enforcement officials or to private parties in accordance with the law, and disclose and use such information as we deem necessary and appropriate to:

  1. Comply with applicable laws, legitimate demands and legal proceedings, including in response to subpoenas or requests from government authorities.
  2. Apply the general terms and conditions that govern our products/services.
  3. Protect our rights, privacy, safety and property, along with yours and those of others.
  4. Protect against, investigate and discourage unauthorized, fraudulent, harmful, unethical or illegal practices.

9. Reasons to share personal information with third parties / commercial data transfer

We will not share your personal information with companies, organizations or individuals outside Circular Innovation Fund, with the exception of our authorized providers and partners who require access to such information for the purposes outlined herein according to the limits set herein, and in the following cases:

  • With your consent.
  • Storage on cloud-based servers, in which case personal information may transit through third-party jurisdictions. Note: We only use the services of well-know firms with well-established privacy policies.
  • For external processing needs: We provide personal information to other trustworthy companies or individuals who process them on our behalf, following our guidelines, in accordance with this Policy, employing at least an equivalent level of security measures as ours and following any other appropriate security and privacy measures.
  • For legal purposes: We provide personal information outside our company if access to such information is required to comply with existing laws and regulations.

Circular Innovation Fund will not sell or rent your personal information to a third party.

Circular Innovation Fund can sell or transfer the company or its assets, in whole or in part, including your personal information, as part of a commercial transaction (or a potential commercial transaction) such as a merger, consolidation, acquisition, reorganization or bankruptcy asset sale, in which case we will make a reasonable effort to require the receiver to abide by this Privacy Policy

10. Use of cookies and similar technologies / your rights and options

Circular Innovation Fund may use cookies, Internet tags, web beacons, log files or other technologies to collect certain personal information regarding visitors to our websites and individuals who receive our newsletters, invitations and other communications. Cookies are pieces of information that pass from the server to the browser when users visit a website to uniquely identify the connection. They include information such as your IP address, the type of browser, the browser version, the pages that you visited, the date and time of your visit, the duration of your visit and any other statistical data.

Cookies are used, for example, to retrieve the session’s search history and cart (e.g., purchase of tickets) to make it easier for users to use the website. It is important to know that, depending on the settings, enabling cookies may allow other servers to install cookies in your system. You can set your browser settings to receive cookie notifications giving you the option to accept or decline cookies.

Please note that our website may contain links to third-party sites. This Policy ceases to apply the moment you leave our website and Circular Innovation Fund holds no liability for the collection or processing of personal information by such third parties or through such external sources. You can choose not to share your personal information with us. In certain circumstances, if you choose not to provide the requested information, you may be unable to use certain website features and we may be unable to provide certain products/services. For example, we may be unable to process your booking.

Viewing, editing or deleting your information 

You may contact us directly to request to view, edit or delete your personal information.

11. Retention of personal information

Circular Innovation Fund retains the collected data for different periods of time depending on the type of information and its use in the provision of our products/services. During the retention period Circular Innovation Fund will take physical and technical measures to ensure the security of the data containing personal information.

Our main personal information retention centres are located in cities where Circular Innovation Fund has offices or facilities and in cities where PG2 and Carbone Safe CE 23.3 hold servers containing data collected by Circular Innovation Fund.

Personal information may be retained outside of the country where you reside if a third-party service provider or other entity to which we have disclosed personal information in accordance with this Policy is located outside of the country. In such cases, the personal information may also be subject to local laws in the jurisdictions in which they were collected, used, disclosed or stored, and government authorities and law enforcement officials may access such information.

The personal information will be destroyed at the end of the retention period. Only statistics or reports containing depersonalized and anonymized data will be kept beyond the retention period.

We reserve the right to make changes to this Policy at any time. Should the Policy be updated, the date will be changed and the most recent version will be posted on our website.

12. Personal information protection officer

Amendments to this Policy:

This Policy may be modified from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always provide the date of the latest changes and access to all previous versions for reference purposes. Should material changes be made, we will post a notice on our website (and send an email notification for certain services)

Compliance Officer: Marie Brisebois

If you have any questions, comments or complaints regarding this Policy, please contact our Privacy Policy Compliance Officer:

Marie Brisebois
Secrétaire corporative
Corporate Secretary
[email protected]
C: +1 514 817-6401