Protecting Your Privacy

This privacy statement applies to Spring Advertising Ltd. (“Spring”, “we”, “us”, “our”) and outlines how we collect, use and disclose personal information in Canada. Generally, “personal information” is information about an identifiable individual, subject to more particular definitions or interpretations under applicable law. This privacy statement does not apply to personal information about employees, contractors or other temporary or permanent staff, volunteers or other individuals assigned to Spring (collectively, “Members of Spring”), or to any information which is not personal information as defined in or interpreted under applicable law.

Spring offers and provides marketing, advertising and communications services and information to a wide range of clients. As part of the services we provide, we are sometimes asked or do sometimes come into possession of personal information about our clients and their customers. This policy sets forth our general guidelines in dealing with such “personal information”.

Compliance with the Law

Spring will comply with all applicable laws in the regions within Canada and other countries in which it operates.

Information Collection & How It’s Used

Information in relation to clients, their customers and others, generated in the course of providing our services

The kinds of personal information we may collect and use in relation to clients and their customers will depend upon the information and services requested. However, subject to applicable law, it may include: name, address, e-mail address, contact details, financial, credit, billing and account information, and other incidental information relating to the services we provide; information material to the services we provide for you and your business operations; information about you contained in communications within Spring and between us and you, whether online or offline; and information we may collect with your consent or as permitted or required by law.

We use this information:

To offer and provide services to you; to deal with third parties on your behalf or in furtherance of providing services to you; to communicate with you regarding the services you request and to respond to your requests and inquiries; and as permitted or required by law or for purposes for which you otherwise provide your consent.

Information in relation to potential Members of Spring

If you apply for a position at Spring, we will collect the personal information contained in, and generated in relation to, your application package, in order to evaluate your application and assess whether to offer you a position at Spring. For candidates who are not offered or do not accept a position, we normally retain this information for a reasonable period in the event that an appropriate position becomes available or that you re-apply to Spring. If you accept a position at Spring, the information will be retained in accordance with our privacy procedures applicable to the personal information of Members of Spring.

Information about our agents, vendors, suppliers and foreign associates:

Spring may collect information about third-party agents, vendors, suppliers and foreign associates (“Service Providers”) who provide goods, services and information to Spring. This information would include name and contact information as well as any information (such as banking information) that we need to pay you for your services and other relevant information, such as experience and qualifications of Service Providers.

We use this information in order to assess suitability for particular assignments; to contact you, where necessary, in relation to the goods, services and information you are providing to Spring; and to pay you for your services.

What cookies are and how are they used:

Cookies are small data files that your browser may place on your computer when you visit different websites to mark that you have been there. Cookies and other technologies, such as your device’s unique identifier, are used on our website to optimize the website-browsing experience. For example, they allow us to track a browser’s movement through the website over several sessions. Through these technologies, the website can recognize repeat visitors, facilitate the visitor’s access to and use of the website and allows the website to track usage behaviour that will allow content and service improvement and enable us to tailor our website to better match your needs and preferences. We may also use these technologies to allow you to select and prioritize your preferences when you enter our Site.

No Personal Information is stored in or gathered from these cookies or other technology. However, you may choose to set up your browser to delete and/or refuse cookies or alert you when cookies are sent. Please note, though, if you don’t have a cookie from our Site, it may limit our ability to customize and improve our Site features.

How Information About You Is Collected

We typically collect personal information directly from you or through our interaction with you, in particular where such information is deliberately disclosed to us for the purposes of providing particular services. You may sometimes provide us with the personal information you collect from your customers to aid Spring in providing its services to you.

In relation to potential Members of Spring, in addition to personal information that you provide, we may collect personal information from: the third parties you provide as references in support of your application; and individuals involved in the evaluation and review process.

Disclosure and Sharing of Your Information

We may use and disclose the personal information we collect about clients or other individuals we deal with to third parties, including: where you have instructed us to disclose your personal information to a third party for a designated purpose; where the use of the personal information is necessary in the course of providing services to you; where we reasonably believe a third party requesting your information is your agent; and where you consent or as permitted or required by law.

We may disclose personal information about past Spring Members in order to provide an employment reference to a third party where you have requested, or consented to, the provision of the reference.

Service Providers. Spring may also transfer your personal information to our Service Providers hired to administer or provide products, services or information on our behalf. We use reasonable measures to require the organizations with whom we share your personal information for these purposes to use your personal information only to perform the services we have hired them to provide. Note that some of the Service Providers that process or handle personal information on our behalf are located outside of Canada. As a result, your personal information may be transferred, stored and/or processed outside Canada in connection with the purposes described in this privacy statement Contractual or other measures we may use to protect your personal information are subject to the legal requirements of the foreign jurisdictions where your personal information may be transferred, stored or processed, for example lawful requirements to disclose information to government authorities in those countries.

Confidentiality and Non-Disclosure

Spring will hold personal information in strict confidence and except where required by applicable law will not disclose the personal information to any person, other than those Members of Spring who require access to the personal information in order for Spring to perform the services for which they have been retained. All Members of Spring, upon their employment with Spring sign a confidentiality agreement protecting the confidential information of Spring and its clients.

Your Consent

We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question. For example, in most cases, a client’s consent to the collection, use and disclosure of personal information by Spring may be implied by the fact that the client has engaged Spring to provide services, where the collection, use and disclosure of personal information relates to the performance of those services by Spring. If you provide personal information about another person to us, including your customers, we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this policy and as instructed by you. If you choose to provide personal information to Spring, we assume that you consent to the collection, use and disclosure of your personal information as outlined in this privacy statement.

Security

Spring has implemented reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized Members of Spring have access to your personal information. With regard to clients and information about our client’s customers, only those Members of Spring authorized to have access, as determined is necessary to provide you with services shall be provided with access to such data. Spring has implemented policies and procedures related to limiting access to programs and data to relevant persons, and ensuring our operations maintain security, environmental protection and risk mitigation initiatives.

Access, Correction, Inquiries and Complaints

If you wish to request access to, or correction of, your personal information in custody or control of Spring, please make your request in writing to the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example if it contains the personal information of other persons, if it constitutes confidential commercial information, if it is protected by solicitor-client privilege, or if it is otherwise not properly the subject of an access request. Where the request for access is made by a customer of a client, Spring will report such request to the client prior to providing such information to the customer, provided we continue to be in compliance with applicable privacy legislation.

Since we predominantly use personal information to provide services, it is important that the information be accurate and up-to-date. Please inform us as soon as possible of any changes to your personal information.

If you have any questions, requests or complaints about our personal information practices, please contact us at Suite 301, 1250 Homer Street, Vancouver BC, or via telephone at 604-683-0167.

Cessation of Use

Upon receipt of a withdrawal of consent, Spring will cease using such personal information.