Privacy Policy

Privacy Notice

Last updated: June 2020



AdPerfect Dynamic Advertising Solutions Ltd. (“AdPerfect,” “we,” “us,” “our”) is committed to protecting your personal information.  This Privacy Notice describes the personal information that we collect about you, how we use and disclose this information, and the steps we take to protect this information.  For purposes of this Privacy Notice, “personal information” means any information that relates to you as an individual and could reasonably be used to identify you. 



This Privacy Notice applies to our collection and use of personal information through this website and any related websites, applications, tools, or platforms (the “Services”), as well as through any other means where a link or reference to this Privacy Notice is provided at the time of collection.   



Our Services



AdPerfect is a software-as-a-service provider that licenses the use of its obituary and classified advertisement creation tool to newspapers (our “Customers”). As part of providing these Services, we collect and store personal information from individuals who visit our Customers’ websites and interact with our platform for purposes of creating an obituary or classified advertisement (“End Users”).  While this Privacy Notice applies to our collection and use of suchEnd User personal information, it does not apply to the use of such information by our Customers.  For information on how Customers use End User personal information, please see the relevant Customer’s privacy notice.



Personal Information We Collect



When you access or use the Services or otherwise interact with us—whether you are a Customer, an End User, a visitor to this website, or another individual—we may collect certain categories of personal information about you from a variety of sources.   



Categories of personal information that we may collect from you directly include:



  • Contact information (for example, name, phone number, mailing address, email address, company name and website)
  • Account information (for example, username and password, payment card details)
  • Communications (for example, submitted questions, marketing preferences, survey responses)
  • Biographical and end-of-life information (for example, date of birth, date of death, death certificate, names of family members, funeral details, and any other personal information included in an obituary)
  • Classifieds information (for example, items for sale or wanted, services offered or desired, interests and preferences, skills and qualifications, and any other personal information included in a classified advertisement)



Categories of personal information that we may collect automatically when you use the Services

include:

  • Technical information (for example, browser type, IP address, cookies, and operating system)
  • Usage information (for example, pages visited, search terms entered, and frequency of visits)
  • Finally, we may collect personal information pursuant to a legal or contractual requirement, and failure to provide such information may impact our ability to fulfill our obligations.



How We Use Your Personal Information



We may use the personal information we collect for the following purposes:



  • Identification and authentication. We may use your personal information to verify your identity when you access and use the Services and ensure the security of your personal information.
  • Provide and improve the Services. We may use your personal information to provide and improve the Services and to fulfill our contractual obligations.
  • Communication and marketing. We may use your personal information to communicate with you about the Services, respond to your questions, or offer you additional products or services. 
  • Corporate transaction. We may use your personal information in the event we undertake or are involved in or contemplating any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event.
  • Comply with the law and exercise our rights. We may use your personal information as reasonably necessary to assess and ensure compliance with applicable laws, legal requirements, and company policies; to protect our assets or to investigate or defend

against any claims of illegality or wrongdoing (including to obtain legal advice or to establish, exercise or defend legal rights); and in response to a court order or judicial or other government subpoena or warrant.



We may also aggregate, anonymize, or otherwise de-identify your personal information and use it for any purpose permitted by applicable law. 



Some jurisdictions require that we determine a “lawful basis” for processing personal information.  Where such requirements exist, we rely on the following lawful bases for our processing activities: that you have consented to the processing; that the processing is

necessary for the performance of our contract with you; that we have a legal obligation; or that we have a legitimate interest in providing and improving the Services and managing our business operations. With respect to personal information we process on behalf of our

Customers, we rely on the lawful basis as determined by our Customers.



Use of Cookies



When you use the Services, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device, to help analyze our web page flow, customize our content, measure promotional effectiveness, and promote trust and safety.  You are always free to decline our cookies if your browser permits, although doing so may interfere with your ability to use the Services or certain features of the Services. We may also use Google Analytics or a similar service that uses cookies to help us analyze how users use the Services.



We also allow certain third parties such as advertising networks, analytics providers, and widget providers to place cookies in order to collect information about your online activities over time and across different websites when you access or use the Services.  Currently, various browsers offer a “Do Not Track” option, but there is no standard for how “Do Not Track” should work on commercial websites.  Due to the lack of such standards, this website does not respond to “Do Not Track” consumer browser settings.



How and When We Disclose Your Personal Information



We may disclose your personal information to the following categories of recipients, to be used only for legitimate purposes in keeping with this Privacy Notice:



  • Group companies and affiliates. We may disclose, share, or transfer your information to any business entity that is part of our corporate family. 
  • Service providers. We may disclose your information to third party vendors who provide services in support of our business operations, such as website development, marketing management, service optimization, and data analytics.
  • Parties involved in a corporate transaction. We may disclose your information to relevant third parties in the event of a divestiture, merger, consolidation, or asset sale, or in the unlikely event of a bankruptcy.
  • Law enforcement or other governmental entities. We may disclose your information if required to do so by law or if we believe in good faith that such action is necessary to comply with the law, prevent unlawful activity, defend our rights, or maintain security.
  • Other third parties with your consent. We may disclose your information to any other third party where you have provided consent to such disclosure.



Additionally, when you visit the website of one of our Customers and use our platform to create an obituary or classified advertisement, your personal information will likely be made accessible to the general public, in accordance with your intentions and pursuant to the policies of our Customers.  We encourage you to consult the privacy notices of our Customers for more information on their disclosure practices.



Security, Retention & Transfer of Personal Information



We have implemented and maintain commercially reasonable and appropriate technical and organizational measures designed to protect the confidentiality, integrity, and security of your personal information.  Please note, however, that no security measures are perfect or impenetrable.  We therefore cannot guaranty and do not warrant the absolute security of your personal information.  We retain your personal information for no longer than reasonably necessary to fulfill the purposes for which we collected it or to comply with the law, prevent fraud, facilitate an investigation, defend against legal claims, or exercise our legal rights.



Depending on your location, the personal information we collect about you may be transferred to a jurisdiction that does not provide the same level of protection of personal information as the jurisdiction in which you reside.  Where such transfers occur, we have adopted appropriate safeguards to better protect your personal information, consistent with applicable legal requirements.  You may contact us using the contact information provided below to learn more about the appropriate safeguards that apply to your personal information and to request a copy of such safeguards.  Transfers from the European Union to Canada are made pursuant to European Commission Decision 2002/2/EC, which determined that Canada is considered as providing an adequate level of protection of personal information. 



Your Choices & Rights



You may decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.  Once you have registered for an account with us, you may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the Services. If you do not wish to receive marketing communications from us, you can opt-out by using the unsubscribe process at the bottom of the email, but you may still receive transactional or administrative emails from us.  Although your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics.



Depending on your location and subject to local law, you may have certain rights with respect to your personal information.  These may include: the right to access, correct, and delete your personal information; the right to restrict or object to our use of your personal information; and the right to receive a portable copy of your personal information in a usable format.  If you provide us with consent to use your personal information, you may withdraw that consent at any time, however, such withdrawal will not impact the lawfulness of our use of your personal information based on your consent up to that point.



To make a request related to your personal information or otherwise exercise your rights, you may contact us using the contact information provided below.  In order to fulfill your request, we may require additional information from you.  We will respond to requests within the relevant time periods established by applicable law.  We are committed to finding a fair and reasonable

resolution to any request, concern, or complaint you bring to our attention.  However, if you are unsatisfied with our response to your request, you may have the right to lodge a complaint with applicable governmental authorities, subject to local law. 



Children’s Privacy



We do not knowingly collect or maintain information from persons under 16 years of age (“children”), and no part of the Services is directed to children.  If you are under 16 years of age, then please do not use or access the Services at any time or in any manner.  If we learn that information has been collected through the Services from children and without verifiable parental consent, then we will take the appropriate steps to delete this information.  If you are a parent or guardian and discover that your child has provided us with personal information without your consent, please contact us using the contact information below to request that we delete the information from our systems.



California Residents



Supplemental to the above, the following additional information pertains to California residents only:



Collection and Use of Personal Information



  • Categories of personal information collected about California residents in the past twelve months include identifiers, other identifying information, characteristics of protected class, commercial information, internet or other electronic network activity information, professional or employment-related information, and education information. For examples of specific pieces of personal information collected, please see the “Personal Information We Collect” section above.
  • Categories of personal information disclosed to Customers and service providers for a business purpose about California residents in the past twelve months include identifiers, other identifying information, characteristics of protected class, commercial information, internet or other electronic network activity information professional or employment-related information, and education information.
  • We do not sell personal information.



Your California Privacy Rights



As a California resident, you have the following rights with respect to your personal information:



  • You have the right to request to know about personal information collected, disclosed, or sold.
  • You have the right to request the deletion of personal information.



Finally, you have the right to not be discriminated against as a result of exercising your privacy rights.  Accordingly, unless permitted by law, we will not deny you goods or services, charge you different prices or rates for goods or services, provide you a different level or quality of good or services, or suggest you will receive a different price or rate for goods or services or a different level or quality of goods or services. 



To exercise your rights, you may contact us using the contact information provided below, use our online contact form, or call 1-866-475-0555.  In order to fulfill your request, we may require additional personal information for purposes of verifying your identity.  If you make a request through an authorized agent, we may require additional information to verify your authorization of the agent.



Changes to Privacy Notice



We reserve the right to make changes to this Privacy Notice at any time, without notice.  We will notify you about changes that significantly impact our use of your personal information by placing a prominent notice on this website or by sending you an email.  Please revisit this page periodically to stay aware of any changes to this Privacy Notice.  For the avoidance of doubt,

disputes arising hereunder will be resolved in accordance with the Privacy Notice in effect at the time the dispute arose.



Contact Us



Please contact us with any questions, comments or concerns about this Privacy Notice or our use of your personal information by e-mail at legal@adperfect.com or by mail at:



11 Eighth Street, Suite 1402

New Westminster, BC, V3M 3N7

Canada



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