(Last Updated June 21, 2010)
What is Personal Information?
Unless permitted by law, we will not collect, use or disclose Personal Information for any purpose without first obtaining the consent of the individual to whom the Personal Information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the Personal Information for a new or different purpose.
In most cases, and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, our products or services can only be offered to you if you provide specific Personal Information to us. Consequently, if you choose not provide us with any required Personal Information, we may not be able to offer you the products or services requested. We will inform you of the consequences of the any such refusal or withdrawal of consent.
Why We May Collect Personal Information
We may collect Personal Information from you when you voluntarily provide it to us in order to:
(a) Deliver our products and services to you;
(b) Improve our products and services;
(c) Process payments for our products and services;
(d) Provide you with information about our products, services, promotional offerings and contests (including direct marketing);
(e) Provide you with support in respect of our products and services;
(f) Conduct surveys and customer research;
(g) Meet legal and regulatory requirements; and
(h) Such other purposes consistent with these purposes
How We Collect and Use Personal Information
We only collect, use and disclose Personal Information for purposes that would be considered reasonable in the circumstances and we only use fair and lawful methods to collect Personal Information.
When We May Disclose Your Personal Information
We may disclose your Personal Information:
(a) To individuals or organizations who are involved in:
(i) providing products, services, promotional offerings and contests on our behalf;
(ii) maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading of our computer systems; or
(iii) a transfer of all or part of the assets or business of Bet Smart;
(iv) a corporate re-organization of Bet Smart; and
(b) For any other purpose to which you consent.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where we are obliged to disclose information without consent. Such circumstances may include:
(a) Where required by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity;
(b) Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of Bet Smart, or its licensors, affiliates, users or other third parties;
(c) Where it is necessary to establish or collect monies owing to us, our licensors or affiliates;
(e) Where the information is public.
Where obliged or permitted to disclose Personal Information without consent, we will disclose no more Personal Information than is reasonably required.
The Accuracy And Retention Of Personal Information
We endeavour to ensure that any Personal Information in our possession is as accurate, current and complete as necessary for the purposes for which we use and/or disclose such Personal Information. If we become aware that Personal Information in our possession is inaccurate, out-of-date or incomplete, we will endeavour to revise such Personal Information accordingly.
We will retain your Personal Information only for so long as it is required for the purposes it was collected. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is reasonably necessary for us to have sufficient information to respond to any issues that may arise after the end of your relationship with us. When your Personal Information is no longer required, we will destroy, delete or convert it into an anonymous form.
Protection of Personal Information
We endeavour to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of Personal Information.
PLEASE NOTE: Some or all of the Personal Information that we collect may be stored or processed on servers located outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to disclosure to governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions and without notice to us or you. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that jurisdiction to maintain protections of your Personal Information that are equivalent to those that apply in the jurisdictions in which you live.
Access To Your Personal Information
We permit the reasonable right of access and correction of Personal Information by the individual to whom such Personal Information relates and will endeavour to provide access to such Personal Information within a reasonable period, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require additional information to allow us to confirm that the individual making the request is authorized to do so before granting access or making corrections to such Personal Information.
We reserve the right to refuse, but have not obligation, to apply requested changes to Personal Information if we reasonably believe that such changes are inaccurate, out-of-date or incomplete. Where we refuse to make requested changes to Personal Information, we will inform the individual making the request as to the reasons for our refusal.
We reserve the right, but have no obligation, to refuse to provide access to Personal Information where the Personal Information requested:
(a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other confidential information that may harm Bet Smart, or its licensors, affiliates, users or another third party;
(b) Would interfere with contractual or other negotiations of Bet Smart, or its licensors, affiliates, users or another third party;
(c) Is subject to solicitor-client, litigation or other legal privilege;
(d) Is not readily retrievable and the burden or cost of retrieving such Personal Information would be disproportionate to the nature or value of such Personal Information;
(e) Does not exist, is not held, or cannot be located by us;
(f) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
(g) May harm or interfere with law enforcement activities or other investigative or regulatory functions of a body authorized by law to perform such functions; or
(h) Is requested to be withheld by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity.
Where we refuse to provide access to Personal Information, we will inform the individual making the request as to the reasons for our refusal.
We will not charge you for accessing or correcting your Personal Information, however, to the extent permitted by applicable law, we may charge you a fee if you request a copy of any records containing your Personal Information.
How Do We Gather Data By Automatic Means?
We may use cookie technology, web beacons and other similar devices on the Site to enhance functionality and navigation for our users. Information tracked through these mechanisms includes, but is not limited to: (i) user IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the website a user visits; and (iv) other websites a user visited before visiting the Site. If you wish to disable cookies, refer to your web browser instruction manual or help facilities. Please note that if you disable cookies, you may be unable to access some of the features on the Site. Cookies that we use in association with the Site do not collect or contain your Personal Information.
Internet tags, graphic tags and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on the Site to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize the Site website and improve your experience at the Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Like cookies, the web beacons use by us in association with the Site do not collect or contain your Personal Information.
Links To Other Websites
Chat Rooms, Message Boards, Forums, and User-User Messages
The Site may provide chat rooms, message boards, forums and/or the ability to send messages to other users of the Site. You should be aware that when you voluntarily disclose your Personal Information using any of these features, your Personal Information may be collected, used or disclosed by other users of the Site without restriction. This may result in unsolicited messages from third parties, identity theft and other harm to you. Any Personal Information that you disclose to users of the Site is entirely at your own risk. Bet Smart assumes no responsibility or liability as to any harm that you may suffer as a result of such activities.
Resolving Your Privacy Concerns
We welcome your feedback. If you have questions, comments or concerns about
(a) Access or correct your Personal Information in our possession;
(b) Request that we not send you mailings or otherwise contact you; or
Please contact our Privacy Officer, in writing, at:
Bet Smart Media Inc.
Attn: Privacy Officer
19 Bastion Square, 2nd Floor
Victoria, BC, V8W 1J1, Canada