Privacy Policy
Effective Date: December 19, 2019
This Privacy Policy describes how Subtleties Digital (“SD,” “we,” “our,” or “us”) collects, uses, and shares information about you and applies to your use of any online service location that posts a link to this Privacy Policy, including our website located at www.subtleties.ca, and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). By using the Service, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree with this Privacy Policy, then do not use the Service.
This Privacy Policy does not apply to information collection activities outside of the Service, such as SD’s products and services that SD’s clients may use to collect information on their own behalf (unless otherwise stated below or at the time of collection). For information about processing on behalf of our clients, please see the section entitled “Client Data” below.
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are in Europe or a California resident, please see our location-specific disclosures in the “Additional Disclosures for People in Europe” and “Additional Disclosures for California Residents” sections below.
Information Collection
Information You Provide to SD
SD collects information that you voluntarily submit to SD through the Service. The categories of information we collect and have collected in the last 12 months include:
• Contact Data, including your or your employer’s name, email address, phone number, and physical address; and
• Job Applicant Data, including your employment and education history, such as transcript, writing samples, and references as necessary to consider your job application for open positions.
Do not submit any information to us that we have not requested.
Information Collected Automatically
SD also automatically collects certain information about your device and how your device interacts with our Service. The categories of information we automatically collect and have collected in the last 12 months include your device’s IP address and other device identifiers, the type of internet browser you are using on your device, the type of operating system application software and peripherals you are using on your device, the domain name of the website from which your device linked to our Service, and your browsing habits on and usage of the Service through your device.
We use various current—and later—developed technologies to collect this information (“Tracking Technologies”), including the following:
• Cookies: A cookie is a small data file that certain websites write to your hard drive when you visit them. We may also use web bugs, clear gifs, and similar technologies that collect data similar to that collected by a cookie.
• Pixels: A pixel (also known as a web beacon) is code embedded in a website, video, email, or advertisements that sends information about your use to a server.
• Location-identifying Technologies: Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Analytics and Advertising” and “Your Rights and Choices” below.
Information on Behalf of
Our Clients
We provide marketing and advertising products and services for our clients and may collect and process information about individuals at the direction of our clients (“Client Data”). Client Data has historically included contact data, demographic data, social handles, content, internet activity, and location data, among other information. Our processing of Client Data is governed by the terms of our service agreements with our clients, and not this Privacy Policy. We are not responsible for how our clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.
SD acknowledges that you may have rights in connection with Client Data. If your information has been processed by SD on behalf of a client and you wish to exercise any rights you have with such information, please inquire with our client directly. If you wish to make your request directly to SD, please provide the name of the SD client on whose behalf SD processed your information. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request.
Information from Other Sources
We may obtain information about you from other sources. The categories of other sources from which we collect and have collected information from in the last 12 months include:
• Social networks when you reference our Service or grant permission to us to access your data on one or more of these services;
• Data providers, such as Cuebiq (Cuebiq’s privacy policy is available at https://www.cuebiq.com/privacypolicy/);
• Partners with which we offer co-branded services or engage in joint marketing activities; and
• Publicly available sources such as data in the public domain.
Use of Information
SD uses information we collect for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include:
• To operate and manage our Service;
• To perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service;
• To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
• To prevent and address fraud, breach of policies or terms, and threats or harm;
• To monitor and analyze trends, usage, and activities;
• To improve the Service or other SD websites, applications, marketing efforts, products, and services;
• To send you direct marketing about our products, services, offers, promotions, rewards, and events we think you may be interested in;
• To provide you with advertisements; and
• To fulfill any other business or commercial purposes disclosed to you and with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.
For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
Sharing of Information
SD shares information we collect through the Service in accordance with the practices described in this Privacy Policy. The types of entities to whom we disclose and have disclosed information with in the last 12 months include:
• Service Providers: Our agents, consultants, and other service providers (collectively “Service Providers”) may process your information in connection with their work on our behalf.
• Affiliates: We may share your information with our affiliates for internal business purposes.
• Vendors and Other Parties: We may share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies.
• Sweepstakes, Contests, Promotions: We may offer sweepstakes, contests, surveys, and other promotions jointly sponsored or offered by other parties.
• Clients: We share information with our clients in connection with us processing information on their behalf.
• Merger or Acquisition: We may share your information in connection with any proposed or actual merger or business combination.
• Security and Compelled Disclosure: We may share your information to comply with the law or other legal processes.
• Consent: We may share your information for any other purpose disclosed to you and with your consent.