Privacy Policy

Purpose

The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected?

4. The rights of users of the Site; And

5. The Site’s cookie policy.

This privacy policy applies in addition to the terms and conditions of our site.

GDPR

GDPR For users in the European Union, we adhere to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the UK, we adhere to the GDPR as enshrined in the Data Protection Act 2018. Consent By using our site, users agree that they agree to:

1. The conditions set out in this privacy policy. Legal basis for processing

Consent

By using our site, users agree to:

1. The conditions set out in this privacy policy.

Legal basis for processing

We collect and process personal data from users in the EU only where we have a legal basis to do so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process users' personal data in the EU:

1. The processing of the user's personal data is necessary for us to take measures, at the request of a user, before entering into a contract or for the execution of a contract to which a user is a party. If a user does not provide the personal data necessary for the execution of a contract, the consequences are as follows: No transaction will take place.

Personal data we collect

We only collect data that helps us achieve the purpose set out in this privacy policy. We will not collect any additional data beyond the data listed below without first notifying you.

Data collected automatically

When you visit and use our site, we may automatically collect and store the following information:

1. Location;

2. Links clicked; And

3. Content viewed.

How we use personal data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this privacy policy.

The data we collect automatically is used for the following purposes:

1. Statistics.

The data we collect when the user performs certain functions may be used for the following purposes:

1. Communication and delivery.

Who do we share personal data with

Employees

We may disclose User Data to any member of our organization who reasonably needs access to User Data to achieve the purposes set out in this Privacy Policy.

Third party

We may share user data with the following third parties:

1. Groove Platform; And

2. GroovePay.

We may share the following user data with third parties:

1. Links clicked while using the site.

We may share user data with third parties for the following purposes:

1. Targeted advertising.

Third parties will not be able to access user data beyond what is reasonably necessary to achieve their intended purpose.

Other disclosures

We will not sell or share your data with other third parties except in the following cases:

1. If required by law;

2. If necessary for any legal proceedings;

3. To prove or protect our legal rights; And

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How long we keep personal data

User data will be retained until the purpose for which it was collected is achieved.

You will be notified if your data is kept longer than this period.

How we protect your personal data

To protect your security, we use the strongest browser encryption available and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a violation of this agreement would result in termination of the employee.

Although we take all reasonable precautions to ensure user data is secure and protected, there is always a risk of harm. The Internet as a whole can sometimes be insecure and we are therefore unable to guarantee the security of user data beyond what is reasonably practical.

Your rights as a user

In accordance with the GDPR, you have the following rights:

1. Right to be informed;

2. Right of access;

3. Right of rectification;

4. Right to erasure;

5. Right to restrict processing;

6. Right to data portability; And

7. Right to object.

Children

The minimum age to use our website is 16 years. We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16, the personal data will be deleted as soon as possible. If a child under 16 has provided us with personal data, their parent or guardian may contact our Data Protection Officer.

How to access, modify, delete or contest the data collected

If you want to know whether we have collected your personal data, how we have used your personal data, whether we have disclosed your personal data and to whom we have disclosed your personal data, whether you want your data deleted or changed in any way way, or if you wish to exercise any of your other rights under the GDPR, please contact our Data Protection Officer here:

[email protected]

Do not follow the advice

Do Not Track (“DNT”) is a privacy preference you can set in certain web browsers. We do not track users of our site over time and across third-party websites and therefore do not respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how third parties who interact with our site and your data will respond to DNT signals.

How to opt out of data collection, use or disclosure

In addition to the methods described in the How to Access, Modify, Delete or Challenge Collected Data section, we offer the following specific opt-out methods for the forms of collection, use or disclosure of your personal data specified below:

1. You can refuse the use of your personal data for marketing emails. You can unsubscribe by clicking “Unsubscribe” at the bottom of any marketing email or by updating your email preferences under “Your Account”.

Cookie Policy

A cookie is a small file stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

1. Functional cookies

Functional cookies are used to remember the selections you make on our Site so that your selections are saved for future visits;

2. Analytical cookies

Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, the length of your stay on our Site, etc.

3. Targeting cookies

Targeting cookies collect data about how you use the Site and your preferences. This allows us to personalize the information you see on our site for you; And

4. Third-party cookies

Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

A. Monitor user preferences to tailor ads to their interests.

Changes

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we change this Privacy Policy, we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are informed of any updates. If necessary, we may notify users by email of changes to this privacy policy.

Complaints

If you have any complaints about how we process your personal data, please contact us via the contact methods listed in the Contact Information section so that we can, where possible, resolve the problem. If you believe that we have not addressed your concern satisfactorily, you can contact a supervisory authority. You also have the right to lodge a complaint directly with a supervisory authority. You may file a complaint with a supervisory authority by contacting the office of the Privacy Commissioner of Canada at: https://www.priv.gc.ca/en/.

Contact Information If you have any questions, concerns or complaints, you can contact our Data Protection Officer at: [email protected]