Spring Privacy Policy

By accessing or using the Services, you agree to our handling of your Personal Information according to this Privacy Policy. If you do not accept this Privacy Policy, do not access or use the Services.

Welcome to the Spring Activator Inc. (“Spring”, “we”, “us” or “our”) Privacy Policy (the “Privacy Policy”). We are committed to securely handling Personal Information in accordance with the most comprehensive privacy regulations and procedures applicable to us, including the Personal Information Protection Act (British Columbia).

This Privacy Policy describes how we collect, use, share and store Personal Information as a result of your (“user”, “you” or “your”) access and use of our website located at https://spring.is/ (the “Site”), and any of our services accessible thereby (collectively, with the Site, the “Services”).

  1. Definitions

“Aggregated Information” means information that has been made anonymous or aggregated so that it can no longer be used to identify an individual, whether in combination with other information or otherwise.

“Contact Information” means information to enable an individual at a place of business to be contacted (e.g., name, position name or title, business telephone number, business address, business email or business fax number).

“Personal Information” means information about an identifiable individual (e.g., name, address, e-mail address, phone number). Personal Information does not include: (a) Aggregated Information; or (b) Contact Information.

“Process” or “Processing” means any action that a person can take with respect to Personal Information, including collecting, using, sharing, altering and storing Personal Information.

  1. Why We Collect Personal Information

We may collect Personal Information in order to fulfill the following purposes (the “Purposes”): 

  1. To Deliver the Services.  To provide you with the Services that we offer and which you have procured. This includes our acceptance of any of your applications to the programs offered by us and our partners.
  1. To Respond to Inquiries.  To respond to your communications with us (e.g., if you send us a message through the contact form on our Site).
  1. To Send you Marketing and Promotional Offers.  To send you email newsletters containing news, updates and promotions regarding Spring’s products and services. By agreeing to the handling of your Personal Information in accordance with this Privacy Policy, you consent to receiving such promotional emails from Spring. You can withdraw your consent to receiving such promotional emails at any time and for any reason by either: (i) clicking an “unsubscribe” link contained within the email; or (ii) contacting us as provided in Section 16 (Contact Us) of this Privacy Policy.
  1. To Improve our Services. For internal statistical and operational purposes in order to better understand how our Services are used and to improve our Services.
  1. Other Purposes.  To carry out any other purpose which is disclosed to you and for which you consent, or as is otherwise permitted by applicable law.
  1. What Personal Information We Collect

Information that we may collect in connection with the Services includes the following, some or all of which may be considered Personal Information under applicable law:

  1. your first and last name; 
  1. your email; 
  1. information about how you use the Services (e.g., your length of visits to our Site, and the time and frequency of your visits to our Site); and 
  1. information about your computer or mobile device, such as your Internet protocol (IP) address, device ID, browser and operating system type, resolution of your screen, language settings in your browser, referring URLs, and other technical information. 
  1. How We Collect Personal Information

There are three primary ways that we may collect Personal Information: (1) when you provide it to us through your access and use of our Services, and/or your communications with us; (2) when it is automatically collected through your access and use of the Services; and/or (3) when we receive it from a third-party source:

  1. Provided by You.  We may collect Personal Information:
  1. when you provide information to us through your access and use of our Services, such as filling out a form on our Site, or subscribing to our newsletter;
  1. when you attend our events and provide us with Personal Information; or
  1. when you otherwise communicate with us.
  1. Automatic Collection.
  1. Cookies.  We may use cookies and similar technologies to track and analyze user activity in order to improve our Services and improve your experience. A cookie is a tiny element of data sent to your browser from a website. The cookie is stored on your hard drive so that your computer or other device may be recognized while you interact with the website.

Most web browsers allow you to modify your settings to notify you when you receive a cookie or to reject cookies entirely. Your computer also 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 Services if you block or disable our cookies. For more information about cookies, please see: https://www.allaboutcookies.org/.

  1. Web Analytics.  We may use web analytics services (e.g., Google Analytics) in order to better understand the user experience on our Site, including: 
  1. how you reached our Site; 
  1. the website you came from; 
  1. how long you stayed on our Site; 
  1. what pages you looked at;
  1. how many pages you looked at;
  1. what buttons you clicked;
  1. what browser you are using; and
  1. what device you are using. 

Any use of analytics services by us may result in analytics providers collecting certain Personal Information when you access and use our Site. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your device identifier, site usage information, and related information about you.

If you do not wish to participate in web analytics, you may be able to download an opt-out browser add-on. Your web browser may also allow you to set a “Do Not Track” signal when you use online services. To learn more about “Do Not Track” signals, visit http://www.allaboutdnt.com/. You may also contact us at the “Contact Us” section below regarding any questions about web analytics services that we may use.

  1. Third Party Data.  We may also obtain Personal Information from third parties. We protect such Personal Information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data and applicable laws.   
  1. Grounds for Processing Personal Information
  1. General.  We will not process your Personal Information without your consent, unless we are permitted or required to do so by applicable law. Your consent may be expressed or implied. The type of consent we may rely on in processing your Personal Information will vary based on your reasonable expectations, the sensitivity of your Personal Information, and the circumstances surrounding the collection of your Personal Information. Express consent is when you willingly agree (e.g., orally, in writing, or electronic agreement) to the processing of your Personal Information for particular purposes. Implied consent is when: (i) you do not expressly give consent, but you rather volunteer Personal Information for obvious purposes that a reasonable person would consider appropriate in the circumstances; or (ii) you are given notice and a reasonable opportunity to opt-out of your Personal Information being processed for specified purposes, and you do not opt-out. For certainty, by accessing or using our Services, you hereby consent to our processing of your Personal Information pursuant to this Privacy Policy.
  1. European Union.  If you are located in the European Economic Area and the General Data Protection Regulation (“GDPR”) is applicable to our services, we may process your Personal Information on the following grounds, in addition to any other grounds that may be available pursuant to applicable law:
  1. Consent.  Where you have given us consent through a statement or clear affirmative action agreeing to the processing of your Personal Information. For instance: submitting your Personal Information on a form on our Site for a specified purpose.
  1. Contract.  Where processing of Personal Information is necessary to perform a contract to which you are a party with us, or which you have agreed to enter into with us.
  1. Legal Obligation.  To comply with a legal obligation to which we are subject.
  1. Legitimate Interests. Where the processing of Personal Information is based on our legitimate interests, provided that these do not override your own interests and fundamental rights. We have legitimate interests in the following:
  1. to properly operate and deliver our Services to you; 
  1. to understand how users engage with our Services;
  1. to improve our Services;
  1. to market our Services; and
  1. to provide customer service, including responses to inquiries and feedback.
  1. Disclosure of Personal Information
  1. Service Providers.  We may provide your Personal Information to third party service providers in order to help us achieve the Purposes. For example, we may use third party service providers to help us: (i) process payments; (ii) analyze usage of our Services; (iii) track the effectiveness of our marketing strategies and communications; (iv) assist with the prevention, detection and investigation of potentially illegal acts and security breaches; and (v) collect and process error and crash reports and store data. If we provide your Personal Information to service providers, we limit the information to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality and security of such information.
  1. Corporate Transactions.  We may also disclose or transfer your Personal Information to affiliates or third parties in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity, subject in each case to customary confidentiality agreements.
  1. Legal Disclosure.  We may disclose Personal Information if we reasonably believe disclosure is in accordance with or required by any applicable law. This includes the disclosure of Personal Information where necessary for the establishment, exercise, or defense of legal claims, or as otherwise permitted by applicable law. We will have no liability associated with any such disclosures made in good faith. 
  1. Storage and Retention of Personal Information

Personal Information that we collect is stored on servers located in Canada. We will retain Personal Information only as long as necessary to: (a) fulfill the Purposes; (b) protect our legal rights; and (c) comply with applicable law. We will securely delete or anonymize the Personal Information once it is no longer necessary for us to hold it. We are not responsible for any liability or loss you experience as a result of such disposal of Personal Information.

  1. Security of Personal Information

We protect Personal Information using appropriate technical and organizational measures to reduce the risks of unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. However, no method of security is 100% secure. Therefore, we cannot guarantee absolute security. We review and update our security policies and controls over time as technology changes to ensure ongoing security.

  1. Rights Relating to Personal Information
  1. General.  You have certain rights relating to your Personal Information, subject to applicable law in each instance:
  1. Right to be Informed.  To know how your Personal Information is collected, how it is used, and how it is disclosed and stored. This further includes:
  1. Right to Withdraw Consent.  To withdraw your consent to the processing of your Personal Information at any time. Please be advised that withdrawing your consent to the processing of Personal Information may impact the provision of the Services. For further information on this, please contact us as provided in the “Contact Us” section below.
  1. Right to Make a Complaint.  To make a complaint about the processing of your Personal Information.
  1. Right to Access.  To receive a copy of your Personal Information.
  1. Right to Rectification.  To request correction of your Personal Information. 
  1. European Union.  If the GDPR is applicable to our Services, and you are an individual to whom the GDPR applies, then you have the following additional rights relating to your Personal Information, subject to applicable law in each instance:
  1. Right to Erasure.  To request the deletion of Personal Information when: (A) you believe it is no longer necessary for the purposes collected; (B) you withdraw your consent or otherwise object to the processing of your Personal Information; or (C) your Personal Information was unlawfully processed.
  1. Right to Restriction of Processing.  To restrict the processing of Personal Information if you dispute its accuracy or object to its processing.
  1. Right to Portability.  To request that your Personal Information be transferred to another organization. 
  1. Right to Information about Automated Decision Making.  To receive information about the basis of any automatic decision making (e.g., algorithms).  
  1. Right not to be Subject to Automated Decision Making.  To not be subject to decisions based solely on automated processing, unless this is necessary pursuant to a contract between us. 
  1. Right to Object to Processing Activities.  To object to the processing of your Personal Information based on our legitimate interests.

If you want to learn more about any rights under the GDPR, you can visit the European Commission’s page on Data Protection at https://ec.europa.eu/info/law/law-topic/data-protection_en.

  1. Exercising Your Rights.  If you would like to exercise any of your Personal Information rights, please refer to our “Contact Us” section below. When doing so, please tell us which right you wish to exercise and provide us with contact information to direct our response. Your use of the Services may be affected depending on the nature of the rights you seek to exercise.

Subject to applicable law: (i) we may verify your identity before fulfilling requests to exercise any rights; and (ii) we may request additional information if we cannot initially verify your identity, or if we require such additional information in order to properly assess your request. Any Personal Information that you disclose to us for the purposes of verifying your identity and/or exercising your rights will solely be used for those purposes.

  1. Communications with Us

To opt-out of receiving certain communications from us through your use of the Services, including our email newsletter (the “Communications”), you may either contact us as provided in the “Contact Us” section below, or, if applicable, click “Unsubscribe” if such function is supported in the particular Communication. Please note that certain Communications may be necessary for the proper functioning and use of the Services, and opting out of those Communications may prevent the proper use of the Services. In the event that you unsubscribe from newsletter emails, we may still communicate with you in other cases, such as to send you service-related messages that are necessary to respond to service requests, or for other non-marketing purposes.

  1. Personal Information About Other Individuals

Before providing any Personal Information on behalf of another individual, you confirm that you have received all necessary authorizations under applicable law to do so.

  1. No Warranty

This Privacy Policy applies with respect to Personal Information only. We do not provide any warranty, express or implied, with respect to any other information that you may provide to us in connection with our Services.

  1. Third-Party Policies

The Services, including our email newsletters, may contain links to third-party websites or applications that are not owned, maintained or operated by Spring. Some examples of third-party websites that we may link to include Eventbrite and Luma, which are used to register users for our events. Any such third-party links are provided solely as a convenience to you and not as an endorsement by Spring. Spring is not responsible for the content of such linked third-party websites or applications and does not make any representations, warranties or guarantees regarding the content or the privacy practices of such third-parties. We cannot guarantee the privacy or security of your Personal Information once you provide it to a third-party and we encourage you to evaluate the privacy and security policies of each such third-party before any such engagement or disclosure. This is true even where the third-parties to whom you disclose Personal Information are other parties using our Services. For certainty, Spring disclaims any liability associated with your access to, use of, download of, or reliance on, such third-party websites or applications and their content. If you decide to access, use or download any such third-party website, application or content, you do so at your sole risk.

  1. Changes to Our Privacy Policy

We may amend this Privacy Policy from time to time in our sole discretion, so please review it periodically. Unless otherwise expressly indicated by us, any amendments to this Privacy Policy will apply immediately upon our posting of the amended Privacy Policy to our Site. Your continued use of the Services after any amendments to the Privacy Policy will be conclusively deemed as your acceptance of the Privacy Policy as amended.

  1. Interpretation

Unless the context otherwise requires, words importing the singular include the plural and vice versa, and words importing gender include all genders. Where the word “including” or “includes” is used in this Agreement, it means “including (or includes) without limitation”.

  1. Contact Us

If you have any questions about this Privacy Policy, or wish to exercise any applicable rights, please contact us at help@spring.is .