1. Who We Are
We are JWA Group, Inc. as well as our family of affiliated companies (collectively referred to herein as “JWA,” “we,” “us,” or “our”). We are an advertising agency and promotions company.
2. What We Do
We develop micro-sites, promotions, loyalty programs, sweepstakes and contests (“Services”) for our clients. These Services may include the receipt, collection and processing of personally identifiable information (“Information”) from individuals who elect to participate in such Services, which we do on behalf of our clients by use of both online and offline technologies.
3. Purpose of This Privacy Policy
Privacy concerns are tremendously important to us and our clients. This privacy policy (“Policy”) describes how JWA Group collects, uses and shares such Information. This Policy also applies to any of our other websites that post this Policy (the “Site”). This Policy does not apply to websites that post different statements. If you have questions, comments or concerns about our Privacy Policy, please contact us at info@jwagroup.com.
4. Why We Collect Personal Information
We collect Personal Information in order to facilitate the Services that are offered through the Site which may include: completing your registration for the Service, establishing and verifying your identity, activating and maintaining your account profile, providing you technical support, offering updates, communicating with you about products and services, and fulfillment and processing of transactions.
Be aware that the Site may contain links to other websites provided and maintained exclusively by third parties, not subject to this Privacy Policy. Please review the privacy policies on any external websites to determine their information handling practices. JWA will not be liable in any circumstances for any damages whatsoever, direct or indirect, resulting from any third-party website linked to the Site, whether or not we are advised of the possibility of such damages.
5. How We Collect Personal Information
Information You Provide Us
As part of the services provided by JWA Group Inc. with respect to a Service, we may collect Information from you when you elect to participate in such Services, (including information such as your name, postal address, email address, phone number, username and password). This Information is used by us solely for the use of our clients and in the operation of the Services. Such uses may include assisting with registration, validation of entries, notification of potential winners, fulfillment of rewards and other prizes, and marketing analysis. We maintain this Information only for so long as necessary to verify and conduct the Service and to provide redundancy for our clients. We do not provide this Information to any entity other than our client and others involved in the operation of the Service. It is our policy to retain Information necessary for the selection, notification and awarding of prizes in promotions and any tax or Regie forms that are legally required to be completed for awarding those prizes, for only as long as legally required or as requested by the client, whichever is longer. Also if identified in a particular client Service, we would use and share your Information as set out in that particular client’s privacy policy.
Information Clients Provide Us
During the set up or execution of a Service we may receive Information from our clients. This Information is used by us solely in the operation of the Service.
Information Automatically Collected
Like most websites, our Sites gathers traffic patterns, site usage information and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Site. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Site with others outside our company, or we may allow third-parties to collect aggregate data through our Site.
Cookies
We may also log Information using “cookies”, in order to improve user experience or personalise your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our site more “user-friendly”. Cookies provide us with information about your use of the Site that can help us improve the Site and your experience with it. Any Personal Information collected about you through cookies will be treated in accordance with this Privacy Policy. If you have set your browser to warn you before accepting cookies, you should receive a warning message with each cookie. You may refuse cookies by turning them off in your browser, however you should be aware that our site, like most other popular sites may not work well with “cookies disabled.”
Mobile Devices
JWA may also operate mobile programs on behalf of its clients, in connection with a client Service. We may receive information about your location, your mobile device or any Information submitted in the course of such programs.
7. Security Of Your Information
We operate secure data networks protected by industry-standard password protected systems, and maintain physical, encryption, electronic and procedural safeguards to guard the integrity and privacy of these systems and of your Personal Information. Although we cannot guarantee that there will never be a security problem, we and our agents that have access to your information carefully guard against the loss, misuse or alteration of the information we collect on our Site.
We will retain your Personal Information for as long as your account is active or as needed to provide Services to you. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
8. Sharing Your Information With Others
We will share your Information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. We may provide your Information to service providers that provide services to help us with our business activities such as website hosting, data verification and analysis, email delivery, reward procurement and delivery or customer service. These companies are authorized to use your Information only as necessary to provide these services to us. We may also disclose your Information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; to any other third party with your prior consent to do so. We may also share Information with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
9. Changes to this Privacy Policy
In order to enhance our Services, it might be necessary to change this Privacy Policy from time to time. We therefore reserve the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.
10. For More Information or Assistance
If you have any questions regarding this Privacy Policy or the privacy practices of JWA or its affiliates, or if you require assistance to withdraw your consent to our processing of your Personal Information or wish to request that your Personal Information be deleted, please contact us by sending an email to info@jwagroup.com or writing to us at 39 Charterhouse Crescent, London, Ontario N5W 5V3 Attention: Chief Privacy Officer.
Last Updated: July 27, 2021