EFFECTIVE: May 25, 2018
Important note to consumers entering ICG managed or hosted promotions:
What do we mean by personal information?
In this Policy, “personal information” means information or an information set that identifies or could be used by or on behalf of IC Group to identify an individual. Except as described in this Policy, IC Group will not give, sell, rent, or loan any personal information to any third party.
Personal information does not include “Usage Data” which we define as encoded or anonymized information or aggregated data we collect about a group or category of Services, features, or users which does not contain personally identifying information. Usage Data helps us understand trends in usage of the Services so that we can better consider new features or otherwise tailor the Services. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners, and Services providers for various purposes. This includes helping us better understand our customers’ needs, improving the Services, as well as for advertising and general marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.
How do we collect, use, and share your personal information and other information?
Information you provide to us
When we provide Services to you, answer your inquiries, or when you sign up to receive marketing communications, we may ask for personal information, such as your name, phone number, and email address, as well as certain related information like your company name and address. IC Group may use the personal information you provide for operating the Services, tailoring the Services to your needs, billing, identification and authentication, communicating with you about the Services and your use of the Services, sending you marketing materials (subject to your opt-out option), answering your questions, for research purposes, and to generally improve the content and functionality of the Services.
IC Group has legitimate interests in processing personal data:
- Providing marketing materials, and other educational materials that may require an email address to access.
- Emailing you helpful product information.
- Emailing you about ideas or feedback that you have provided to IC Group.
- Contacting you regarding questions you submit or requests you have made to IC Group or a customer of IC Group for which we are a data processor.
- Providing you with support content and measuring how and where content is viewed.
- Maintaining the security of the Services through log and backup retention.
- Logging and analyzing errors that occur while you are using the Services.
- Measuring performance of requests that you make to the Services.
- Analyzing your usage of the Services.
If you object to this processing of your data, please contact email@example.com. If we are unable to honor your objection, we will let you know that we are unable to do so and why.
IC Group may also share your personal information with its third-party Services providers (such as its hosting partners) to provide the necessary hardware, software, networking, storage, and other Services we use to operate the Services and maintain a high-quality user experience.
The Services do not support “do not track” requests.
Cookies and Log files
Other information sharing
In addition to the purposes described above, we disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our legal agreements, or as otherwise required by law.
Links to other websites
The Services may contain links to other websites and web applications that are not owned or controlled by IC Group. Please be aware that we do not determine, and we are not responsible for the privacy practices or content of such other sites. We encourage you to be aware when you leave the Services and read the terms of Services and privacy statements of other websites and web applications linked to the Services. This Policy applies only to information collected by the Services.
The Services may offer publicly-accessible blogs, forums, and ideas portals. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from a blog, forum, or ideas portal, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Customer testimonials, comments, and reviews
From time to time, we may post customer testimonials on the IC Group Websites which may contain personal information. We obtain the customers’ consent to post their names, and/or any other identifiable information, along with their testimonials.
Protection of information
IC Group is committed to ensuring the security of your personal information. We utilize precautions to protect the confidentiality and security of the personal information within the Services, by employing technological, physical and administrative security safeguards, such as firewalls and other security procedures. For example, we encrypt the transmission of sensitive information using Transport Layer Security technology (TLS). These technologies, procedures, and other measures are used in an effort to ensure that your data is safe, secure, and only available to you and to those you authorized to access your data. However, no Internet, email, or other electronic transmission is ever fully secure or error-free, so you should take care in deciding what information you send to us in this way.
IC Group is committed to ongoing compliance with the General Data Protection Regulation (“GDPR”), a European privacy law in effect as of May 25, 2018. We are also committed to helping our customers (including promotion Sponsors) meet the requirements of GDPR. To this end, we have implemented, improved, and will continue to review, numerous stringent technical and organizational measures to protect all personal information processed by IC Group.
For more information, please refer to our GDPR Statement.
Data Subject Rights
We will respect your rights with regard to your personal information. These include your rights to access, correct, and erase your personal information, to restrict or object to the processing of your personal information, and to have us transfer your personal information to you in a portable format. Please note that your exercise of these rights may be subject to certain restrictions for regulatory or legal reasons and may affect how we can provide services to you. You also have the right to complain to a supervising authority about our practices.
If you are an IC Group customer and would like to opt out of getting marketing communications from IC Group, please email us at email@example.com or follow the unsubscribe instructions included in each marketing email. Even if you opt out of getting marketing email, we will still send you transactional messages. These include responses to your questions.
Correcting and updating your information
If you would like to gain access to, or request deletion of information we have collected from you, please contact us at firstname.lastname@example.org.
IC Group will retain personal information we process on behalf of our customers for only as long as needed to provide Services to our customers, subject to our compliance with this Policy. We may further retain and use this personal information as necessary to comply with our legal or regulatory obligations, resolve disputes, enforce our agreements, and for legitimate interest uses.
We may make material changes to this Policy. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Services constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Services.
IC Group may assign or transfer this Policy, your information and data including any personal information to any person or entity that acquires all or substantially all of the business, stock or assets of, or is merged with IC Group.
If you have questions regarding this Policy or about the privacy practices of IC Group, please email us at email@example.com.
IC Group LP
383 Dovercourt Drive
Winnipeg, Manitoba, Canada
P: +1 204.487.5000
F: +1 204.489.7900