Privacy policy

In the course of your use of the FANBOX™ Web site, our MS2™ platform or any of our client’s or our own applications or services (collectively, “Services”), clients and users may elect to share certain personal information with our company or our clients, including information disclosed to FANBOX or one of our clients upon opening an account, and information you may elect to share from time to time, either directly with us or with any of our clients and business partners that use our services relating to their loyalty programs, gift cards (including e-gift cards), prepaid cards and/or customer relationship management (collectively, our “Clients”). This privacy policy seeks to disclose to our Clients, users of our Services and customers of our Clients how FANBOX collects, uses, discloses and otherwise manages personal information in its care, custody and control (our “Privacy Policy”).

From time to time, we may update or modify this Privacy Policy, including so as to reflect changes to our personal information practices and procedures. As the case may be, the updated Privacy Policy will be posted on our Web site (our “Site”) and be effective upon such posting. We encourage you to refer to this Privacy Policy often, for the latest information about our personal information practices and procedures.

What personal information do we collect and use?

If you are an individual, when you register to participate in one of the loyalty and/or gift card (or e-gift card) or prepaid card programs of our Clients (each a “Loyalty Program”), we may receive information about you from such Client to process information and/or manage the program at issue, such as your name, your contact information and certain other personal information that you disclosed upon enrolling in or using such program. Your information may be necessary for FANBOX to manage and administer the Loyalty Programs of its Clients, to process information for its Clients and/or to implement, execute and perform its Services, both towards you and its Clients.

Without limiting the generality of the foregoing, we may collect, receive or hold personal information about you upon:

For example, if you open an account with FANBOX or one of our Clients, we may collect information about you, in accordance with instructions from our Client, including your name and contact information. Similarly, if you open an account or adhere to a Loyalty Program run by one of our Clients, we may be provided with some of the personal information you provided our Client, so as to be able to run the said program and/or provide services relating thereto our Client and/or you.

Personal information relating to your account with us or one of our Client’s may include:


Other personal information which you may choose to share with us or our Clients may include:


How do we use your personal information?

We will not use your personal information, nor display it, share nor transfer it in a manner that is inconsistent with this Privacy Policy and our agreement with the Client from which we received your information. As such, what we may do with your personal information will be, in great part, dictated by the terms of the agreement we have signed with our Client, so as to provide services to them. In simple terms, we may not do anything with your personal information that you have not consented to or that has not been allowed by an agreement (or a policy) with you or our Client.

We collect personal information of users and individuals to maintain FANBOX or Client Loyalty Program membership records, to confirm users’ identities, to conduct the affairs of FANBOX that involve members or Client customers, and as may be required by law. We may also use your membership information to contact you about FANBOX member issues. Furthermore, we may use your personal information in the following circumstances and manner:


HOW DO WE PROTECT PERSONAL INFORMATION IN OUR CARE?

FANBOX seeks to take all necessary precautions to protect your personal information. To that end, we implemented certain measures to protect personal information in our care, custody and control, both online and offline. For example, we take all reasonable precautions to ensure that the personal information that you transmit online, via the secure areas of our Site, as the case may be, is protected against loss, errors and unauthorized access. We maintain reasonable administrative, technical and physical safeguards, including adhering to strict security guidelines, the whole in an effort to protect against unauthorized access, use, modification and disclosure of any personal information in our possession. Such safeguards do include technical measures such as implementing firewalls and antivirus protection on our servers, and organizational measures such as proper training of our employees and agents regarding the import of protecting the personal information of our users’ and our Clients’ customers’.

UNDER WHAT CIRCUMSTANCE MAy we disclose, share or transfer your personal information?

We will not disclose trade, rent, sell or otherwise transfer your personal information, to any third party other than as set out in this Privacy Policy. That being said, if we receive personal information about you from one of our Clients, for example because you subscribed to a Loyalty Program which they run, we may thereafter continue to share information about you with such Client, for the purpose of providing Services to this Client and you.

We may make your personal information available to third parties who provide services on our behalf, such as technical service providers to host our Site, operate certain of its features, send e-mail, run our surveys or contests, conduct customer research, or manage and analyze data. However, in such case, before making any such personal information available to such a third party service provider, FANBOX enters into an agreement with the service provider pursuant to which it is required to use the personal information solely for the purpose of providing the service and to maintain security and privacy measures at least as stringent as those of FANBOX. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.

In the event of a merger, reorganization, or acquisition of FANBOX, or of a purchase of its assets or subsidiaries, in order to ensure a smooth transition of Services relative to your account, your subscription or the activities of our Clients, FANBOX may transfer your personal information to a third party as a part of such merger, acquisition, reorganization, or sale. In such event, you will be notified of the transfer at issue and FANBOX will retain no copy of your information after the transfer is effected.

From time to time, FANBOX may disclose or make available certain personal information in our care, custody or control, including your contact information, upon being presented with a request by law enforcement, such as in the case of a search warrant or other legally valid inquiry or order, including in case of our receipt of a court order, in accordance with applicable law. If personal information about an individual is disclosed pursuant to a request by law enforcement or a court order, FANBOX shall, unless prohibited by law, use reasonable efforts to notify the individual at issue regarding such disclosure. FANBOX may also disclose your personal information should it prove necessary to establish, exercise or defend a claim before courts of law.

HOW CAN you Access your Personal Information that we hold?

The intent of this Privacy Policy is to state for the public how we address issues relating to personal information. Should you require access to your information or more detailed information about our practices or procedures relating to privacy and issues relating to personal information, please contact us by using the contact information provided below. Please note that at the time of your request, we may need further information from you to verify your identity, before we can proceed as requested.

Regarding information you provided us directly (and that we do not simply hold on behalf of a Client), from time to time, you may contact us to request access, deleting, updating or correcting your personal information.

Regarding information we received indirectly and that we hold on behalf of a Client, we will generally have to insist that you contact our Client directly, as they are responsible for having collected or used your information, including if you wish to request access, deleting, updating or correcting your personal information. Indeed, as our business is mainly to process information and/or manage loyalty and/or gift card (or e-gift card) or purchase card programs, for other companies, most information we hold about individuals will be held by us, simply as service provider, further to agreements with our various Clients. As such, most of the information we hold will be held and used solely as agent of our Clients, according to their instructions. In most case, our Clients simply use your information through the platform we provide them.

That being said, you may of course contact FANBOX if you have general questions or inquiries about our practices or your account, at the contact information set forth below, but you should be aware that in most cases, we will defer most questions or inquires to the Clients from which we received or for which we hold your information, as they are ultimately responsible for both the collection and use of your personal information.


FANBOX Inc.
c/o : Privacy Officer
50 de Lauzon Street, Suite 200
Boucherville (Québec)
J4B 1E6

Phone: (450) 463-3939
Fax: (450) 641-2872
E-mail: privacy@fanbox.net





Document Updated: September 30, 2011