PRIVACY POLICY – Terrace Global Inc.

Terrace Global Inc. (“Company”, “we”, “us”, “our”) are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that the Company collects from or about you, as well as how we use and to whom we disclose that information. Please review this entire document carefully.

Our policy is to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes such legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

For the purposes of this Privacy Policy, “personal information” is any information about an identifiable individual, other than an individual’s business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities. This definition would include, among other things, information about the physical or mental health of an individual.

 

Collected Personal Information

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes (i) contact and identification information, such as your name, address, telephone number, e-mail address, date of birth, and gender; (ii) personal information in connection with your request for certain products or services that you seek from us; and (iii) additional service-related information concerning the products or services that we provide to, or receive from, you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial and other advisors.

As a general rule, we collect personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

 

Our Website

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes.

We may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our websites to identify you and to record your passwords and preferences. The cookie allows us to track your visit to our website so that we can better understand your use of our website  so that we can customize and tailor them to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access our website.

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. We are not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Finally, our websites may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively “User Content”). You are solely responsible for the User Content that you post on our website. Unless explicitly stated otherwise, any User Content that you post onto our website will be made publicly available. As such, do not post any personal information onto our website if you wish to remain anonymous.

 

Use of Personal Information

We may use your personal information as permitted or required by applicable law or regulatory requirements, for the purposes described in this Privacy Policy and for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

As above, we may use your personal information to create Aggregated Information for the purposes of managing, maintaining, and developing our operations. Such purposes include: (i) identifying the demographics of our Website viewers; (ii) creating and selling benchmarks, reports, summary metrics, predictive algorithms; and (iii) developing new or improving our existing products and/or services. In this Privacy Policy, “Aggregated Information” means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.

 

Disclosure of Personal Information

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

For example, we may share your personal information from time to time with our third-party information technology, data processing, payment processing, advertising/marketing, call center and age/identity verification service providers so that we may operate our business.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of the Company through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate 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.

Finally, your personal information may be disclosed, (i) for the purposes described in this Privacy Policy; (ii) to third party databases for the purposes of verifying your age; (iii) as permitted or required by applicable law or regulatory requirements; (iv) to comply with valid legal processes such as search warrants, subpoenas or court orders; (v) as part of the regular reporting activities of the Company; (vi) to protect the rights and property of the Company; (vii) during emergency situations or where necessary to protect the safety of a person or group of persons; and (viii) with your consent.

 

Consent

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting us at info@terraceglobal.ca. All communications with respect to such withdrawal or variation of consent should be in writing.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

 

Protection of Personal Information

We will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

The security of your personal information is important to us, please advise us immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

 

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact us at info@terraceglobal.ca. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact us at info@terraceglobal.ca.

Your right to access the personal information that we hold about you is not absolute. 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. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

 

Questions or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your information, please contact us at info@terraceglobal.ca. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

 

Amendments to this Privacy Policy

The Company, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our websites, and we encourage you to refer back to it on a regular basis.

This Privacy Policy was last updated on November 1st, 2019.

 

Interpretation

This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon us any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal privacy laws and its provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and any such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

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