Privacy Policy

This privacy policy (the “Privacy Policy”) describes how Spring Activator Inc. (the “Company”) collects, uses and discloses information and data relating to your (i) access and use of the Website or (ii) contact or interaction with us, including as participants in our programs or services offered (the “Programs”). This Privacy Policy also outlines what rights you have with respect to such information and data. The Privacy Policy forms part of the Company’s terms and conditions accessible https://spring.is/old/terms-of-service/ (the “Terms”), and any capitalized terms used but not defined in the Privacy Policy have the meaning ascribed in the Terms.

If you do not agree with the terms and conditions of this Privacy Policy, do not access the Website or any other aspect of the Company’s business.

The Company reserves the right to update and change the Privacy Policy from time to time by posting updates and changes to the Website. By continuing to use the Website after such changes are posted, you agree to such changes.

1. Collection and Use of Personal Information

If you use the Website, you will end up submitting information to the Company. We may also collect or receive information in several ways, including but not limited to when you contact us by telephone or by email, sign-up for promotional or other communications, post Comments or apply for our Programs. Like most companies, we also receive other information that relates to you automatically or through third parties.

In the course of your accessing and using the Website, the Company may collect and/or generate the following types of information (collectively “User Information”):

(a) “Personal Information”, which means information that could be used by itself to identify you, such as your name, date of birth, gender, address, citizenship, email and phone number;

(b) “Service Information”, which means information generated by your use of the Website, including the following:

(i) Website Metadata. When you interact with the Website, metadata may be generated that provides additional context about the way you engage the Website. For example, the Company logs the type of activity engaged to better understand which features and tools are most used or in need of improvement.

(ii) Log Data. As with most websites and technology services delivered over the Internet, the Company servers may automatically collect and record information when the Website is accessed. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website, browser type and settings, the date and time the Website was used, information about browser configuration and plugins, language preferences and cookie data. This information is used to optimize the delivery of the Website.

(iii) Device Information. The Company may collect information about devices used to access the Website, including the type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether the Company collects some or all of this information often depends on the type of device used and its settings. This information is used to optimize the delivery of the Website.

(iv) Location Information. The Company may collect information to determine your approximate location, such as business address, IP address or any other location information from devices in accordance with the consent process provided by the device.

(v) Cookie Information. The Company may use cookies and similar technologies through the Website that help collect information about your engagement with the Website. The Website may also include cookies and similar tracking technologies of third parties. A cookie is a tiny element of data that our Website can send to your browser, which is stored on your hard drive so we may later be able to recognize your computer or other device while you interact with our Website. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so. However, please be aware that you may be unable to access certain parts of the Website if you block or disable the Company cookies. You may also visit www.allaboutcookies.org for details on how to delete or reject cookies or for further information on cookies generally. By using our Website without deleting or rejecting some or all cookies, you agree that we can place and use those cookies that you have not deleted or rejected on your device.

(vi) Third-Party Analytics. The Company may use third party analytics to help gather and analyze information about the areas you visit on the Website to evaluate and improve the customer experience and the convenience of the Website. To opt-out of third-party analytics tracking of your Website use, there are tools available that you may install in your browser or you may contact us. To analyze the web traffic and track user behavior, the Company may use the following services:

i. Facebook Ads Conversion Optimization – Facebook Pixel (Facebook, Inc.). The Company deploys Facebook Pixel to get insights on how users engage with our Website. When someone visits our Website and takes an action, the Facebook pixel is triggered and reports this action. Utilizing these reports, the Company gets better at delivering ads to people who are likely to take certain actions. This is called conversion optimization.

ii. Google Analytics. The Company uses Google Analytics which is a set of integrated data-and-marketing analysis products that lets us analyze consumer behavior, develop relevant insights, and then provide a more engaging brand experience. Google Analytics provides the information we need to improve the user experience and serve up the content our users find most useful. The Google Analytics cookies store information about what pages you visit, how long you spend on our Website, how you got there and what you click on. Google may use User Information collected to contextualize and personalize the ads of its own advertising network.

iii. LinkedIn Conversion Tracking (LinkedIn Corporation). LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website.

(c) Third Party Site. The Company may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to the Website from parent corporation(s), affiliates and subsidiaries, Company partners or others that the Company uses to make the Service Information more useful. This data may be combined with other Service Information and might include aggregate level data, such as which IP addresses correspond to zip codes or countries.

(d) Additional Information Provided to Company. The Company may receive other information from you through Comments, if you request support, interact with the Company social media accounts or otherwise communicate with or through the Company.

Generally, you are not under a statutory or contractual obligation to provide any information or data to the Company. However, certain information and data is collected automatically when accessing and using the Website, and blocking such collections may result in the Company’s inability to provide you with access and use to any part or whole of the Website.

Our Website is not directed to children under the age of 18 (“Minors”) and we do not knowingly collect personal information from Minors without obtaining parental or guardian consent. If you are a Minor, then please do not use or access the Website at any time or in any manner. If we learn that Personal Information has been collected via the Website from a Minor without verifiable parental or guardian consent, then we will take appropriate steps to delete this Personal Information. If you are a parent or guardian and discover that a Minor has provided Personal Information, then you may alert us as set forth in the “Contact” section below and request that we delete such Minor’s Personal Information from our systems.

If you provide us with Personal Information about any other individual (such as your co-founder(s) or partner(s), you confirm that you have obtained the consent of such individual(s) prior to providing any Personal Information to us.

2. Information Use

User Information will be used by the Company to provide the Website to you in accordance with the Terms, your instructions from time to time and as required by applicable law, legal process or regulation. Without limiting the foregoing, User Information may be used by the Company for the following purposes:

(a) to provide, update, maintain and protect the Website;

(b) to process and respond to your application or registration to Programs or Company events;

(d) to help us understand our participants, evaluate our impact and to enhance our Programs;

(e) to process and respond to any application for current and future career opportunities with the Company;

(f) to communicate with you by responding to your requests, comments and questions;

(g) to develop and provide additional features;

(h) to send you service, technical and other administrative emails, messages and other types of communications. This may include communications relating to changes in the Website, changes to the Programs offered, and important Website-related notices, such as security notices. These communications are considered part of the Website and you may not opt out of them;

(i) to send you marketing and promotional emails, messages and other types of communications. This may include communications relating to new Programs. You may opt out of these communications by following the “unsubscribe” instructions provided in our email or you can contact us, using the information below;

(j) for billing, management and other administrative matters. The Company may need to contact you for invoicing, management and similar reasons; and

(k) to investigate and help prevent security issues and abuse.

3. Information Retention

We also collect information from participants, investors or other third parties contributing to Programs for internal research and analysis in order to identify, evaluate and better understand the factors that contribute to successful Programs.

In general, the Company keeps your User Information throughout your relationship with the Company. The Company uses Google Drive and Airtable to manage, collect, store and organize data from its users. If you terminate your relationship with the Company and your use of the Website, the Company will generally continue to store archived copies of your User Information for legitimate business purposes and to comply with applicable law, except when the Company receives a valid erasure request.

If User Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, the Company may retain and use it for any business purpose. Otherwise, your User Information will be deleted from our systems pursuant to the Company’s standard purge process.

4. Information Sharing

This section describes how the Company may share and disclose User Information.

(a) Customer’s Instructions. The Company will only share and disclose User Information in accordance with the Terms, your instructions from time to time, and as required by applicable law. Your consent to the Company’s sharing and disclosing of certain User Information may be reasonably determined by your action through the Website.

(b) Third-Party Service Providers and Partners. The Company may engage third party companies or individuals as service providers or business partners to process User Information and support the Company business. These third parties may, for example, provide virtual computing and storage for the Website, send emails or other communications or provide payment processing services. For instance, we may use Eventbrite – a U.S.-based event management and ticketing website. Eventbrite allows users to browse, create, and promote local events. The Company may use Eventbrite to inform users of upcoming Company events and sell tickets for these events (unless the event is free). All the payments for tickets sold are processed by Eventbrite.

(c) Corporate Affiliates. The Company may share User Information with its corporate affiliates, parents and/or subsidiaries.

(d) During a Change to Company’s Business. If the Company engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of the Company’s assets or stock, financing, public offering of securities, acquisition of all or a portion of the Company business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g., due diligence), some or all User Information may be shared or transferred, subject to customary confidentiality arrangements.

(e) Aggregated or De-identified Data. The Company may disclose or use aggregated or de-identified User Information for any purpose. For example, the Company may share aggregated or de-identified User Information with prospects or partners for business or research purposes.

(f) To Comply with Laws. If the Company receives a request for information, the Company may disclose User Information if the Company reasonably believes disclosure is in accordance with or required by any applicable law, regulation or legal process. The Company is released of any liability associated with any such disclosures made in good faith.

(g) To Enforce Rights, Prevent Fraud, and for Safety. The Company may disclose or use User Information to protect and defend the rights, property or safety of the Company or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

(h) With Consent. The Company may otherwise share User Information with third parties when the Company has your consent to do so.

5. Information Control

The Company understands that you have legal rights over your User Information, and takes reasonable steps in accordance with applicable laws to allow you to access, correct, amend, delete or limit the use of your User Information. Please contact the Company to make the required changes. For certain instances of your User Information that is shared with third parties, the Company may be unable to access, correct, amend, delete, or limit such User Information.

6. Feedback

Any suggestions, questions or comments relating to improving or modifying the Website that are included in your communication with the Company (the “Feedback”) will be deemed to be non-confidential and non-proprietary to you, and you agree that: (a) the Company is therefore not subject to any confidentiality obligations with respect to the Feedback; (b) the Feedback is not confidential or proprietary information of any third party and you have all of the necessary rights to disclose the Feedback to the Company; (c) the Company (including all of its affiliates, successors and assigns) may irrevocably freely use, reproduce, publicize and exploit the Feedback; and (d) you are not, nor is any other party, entitled to receive any compensation or reimbursement of any kind from the Company in relation to the Feedback.

7. Security

The Company takes commercially reasonable steps to protect User Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the User Information and the current state of technology. By using our Website, you consent to the transfer or storage of User Information on servers located outside of the country where you live. These countries may have different data protection rules than your country. While such User Information is outside of Canada, it is subject to the laws of the country in which it is held. Our practices regarding your User Information will at all times continue to be governed by this Privacy Policy and, if applicable, we will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of Personal Information from European Union/European Economic Area (“EU/EEA”) to third country. The Company follows industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, user details and any other Personal Information entrusted to the Company. No method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to protect your User Information, the Company cannot guarantee the security of any information you transmit to us.

8. Users in the European Union and European Economic Area

We are the data controller of your Personal Information you provide on the Website. We have lawful bases to collect, use and share your User Information. As explained above, we process User Information in various ways depending upon your use of the Website. We process Personal Information on the following bases: (a) with your consent; (b) to provide you with the Website or Programs; and (c) as necessary for our legitimate interests in providing you with our Website or Programs, enhancing and customizing our Website or Programs, conducting analytics and delivering relevant advertising.

If you are in the EU/EEA, then you have certain rights relating to your Personal Information.

a) Access and Confirmation. You have the right to ask us if we process Personal Information about you, and in some circumstances, to obtain a copy of your Personal Information.

b) Deleting and Blocking. Under certain circumstances, you may have the right to have your Personal Information deleted or blocked without undue delay.

c) Direct Marketing. You have the right to object to our processing of Personal Information for direct marketing purposes.

d) Right to Withdraw Consent. To the extent we are processing Personal Information on the basis of your consent, you have the right to withdraw consent at any time.

e) Data Portability. Under certain circumstances, to the extent we are processing your Personal Information on the basis of consent, or that it is necessary to provide Programs, and the processing is carried out by automated means, you have the right to receive the Personal Information in a structured, commonly used and machine-readable format. To exercise those rights, please contact us using the contact information below.

f) Right to Lodge a Complaint. You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country.

We may transfer, store, and process your User Information outside of your country. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored. By providing us with Personal Information, you consent to the storage or processing of Personal Information outside of your country and acknowledge that the Personal Information will be subject to the laws of British Columbia, Canada, including the ability of governments, courts, or law enforcement or regulatory agencies of British Columbia, Canada to obtain disclosure of your Personal Information. If you want to learn more about your rights under GDPR, you can visit the European Commission’s website on Data Protection at: https://ec.europa.eu/info/law/law-topic/data-protection_en.

9. Contact

If you have any questions or comments about the Privacy Policy, the practices of this site, or your dealings with this site, please contact our Privacy Officer at help@spring.is or at the following mailing address:

300-225 W 8th Avenue
Vancouver V5Y 1N3 – BC , Canada