We value your privacy and are committed to protecting your personal information. This Privacy Policy outlines what information we collect from you. It also describes how we retain, use, disclose, and protect your personal information. This Privacy Policy applies to information collected by T.H.E. Senior Paper Ltd. (“us”, “we”, “our”) through the ‘theseniorpaper.com’ website operated by us (the “Website”) as well as other places where, or means by which, we may collect personal information, including, but not limited to, our interactions and communications with you by mail, telephone, or electronically through any other digital medium owned or operated by us.

Capitalized terms used in this Privacy Policy that are not defined have the meanings assigned to them in our Terms and Conditions.

1. Definition of Personal Information

Personal information is defined as information that can identify an individual and information about an identifiable individual, which means a person can be identified by the information either directly or in combination with other information.

2. Collection of Personal Information

We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you use our Website, register for an Account, provide us information on a web form, update or add information to your Account, participate in community discussions, chats, or dispute resolution, or when you otherwise correspond with us.

Personal information that we may collect may include:

(a) Identifying information such as your name, address(es), telephone number(s), or email address(es) when you register for an Account;

(b) Any content that you submit, post, or publish on the Website;

(c) Other content that you generate or that is connected to your Account as a result of creating or responding to submitted, posted, or published content;

(d) Financial and billing information (such as credit card or bank account numbers) in connection with your Account;

(e) Any other information you provide us through a web form, by updating or adding information to your Account, through your participation in community discussions, chats, dispute resolution, or when you otherwise correspond with us; and

(f) Additional information we are required or authorized by applicable laws to collect and process in order to authenticate or identify you or to verify the information we have collected.

3. Use of Personal Information

We use the personal information we collect to:

(a) Provide, improve, and personalize our content and services;

(b) Communicate with you about your Account and our Website;

(c) Provide you customer service;

(d) Provide you with personalized advertising and marketing communications;

(e) Detect, prevent, mitigate, and investigate fraudulent or illegal activities; and

(f) Enforce our Terms and Conditions and this Privacy Policy.

4. Security and Retention of Personal Information

We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed Accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions, and take other actions permitted or required by applicable laws. After it is no longer necessary for us to retain your personal information, as determined by us in our sole discretion in accordance with applicable laws, we dispose of it in a secure manner according to our data retention and deletion policies.

In recognition of our legal obligations to protect your personal information, we have made arrangements to protect against unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information.

Notwithstanding the above, we do not store your financial or billing information. When you submit your credit card information to us, it is transmitted directly to our payment processors which are PCI DSS compliant service providers.

5. Location of Servers

We may create, maintain, and archive information on servers that are not located on our immediate premises and are located in Canada or the USA. Please be advised that a foreign government may be able to access data relating to you or your Account, including your personal information, for lawful access purposes. If you continue to use the Website, you consent to us creating, maintaining, and archiving information on servers located on a third party’s premises within Canada and in the USA.

6. Disclosure of Personal Information

We do not disclose your personal information to third parties for their marketing and advertising purposes without your explicit consent. There are, however, certain circumstances in which we may share your personal information with certain third parties without further notice to you. This disclosure may be required for us to provide you access to our Website, to comply with our legal obligations, to enforce our Terms and Conditions, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Website. These circumstances include, but are not limited to:

(a) Law Enforcement. We cooperate with government and law enforcement officials or private parties to enforce and comply with applicable laws. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect our property or rights or the property or rights of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with applicable laws.

(b) Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganization, or sale of assets, or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

(c) Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.

7. Consent for Collection, Use, and Disclosure

By accessing and using our Website, we consider you to have given us consent to the collection, use, and disclosure of your personal information. Once this consent has been given, we will continue to collect, use, and disclose personal information for the purposes set out in this Privacy Policy without obtaining further written or verbal consent to do so. We may also collect, use, or disclose personal information about an individual without that individual’s consent as permitted under applicable laws.

8. Cookies

We use cookies and other technologies to passively collect demographic information, personalize your experience on our site and monitor advertisements and other activities. Cookies are small files downloaded to your computer to track movements within websites. We may link cookie information to personal information. Cookies link to information regarding pages you have viewed and articles, posts, and links that you have clicked on. This information is used to enhance user experience on our Website and to track article views as well as advertisements and sponsored content. We also use cookies to deliver content specific to your interest and to monitor website usage. We may, from time to time, use an outside ad company to display ads. These ads may contain cookies. Our ad companies collect cookies received with ads, and we do not have access to this information. Most browsers are automatically set to accept cookies whenever you visit a website. You can disable cookies or set your browser to alert you when cookies are being sent. However, some areas of our Website may not function properly if you do so. Please note that this Privacy Policy covers the use of cookies by us only and does not cover the use of cookies by any advertisers.

9. Third Party Services

From time to time, our Website may also include links to other websites. Certain products or services available on our Website are provided to you in partnership with third parties and may require you to disclose personal information in order to register for and access such products or services. Such products or services shall identify the third party partners at the point of registration. If you elect to register for such products or services, your personal information will be transferred to such third parties and will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy practices and policies of such third parties and, therefore, you should review the privacy practices and policies of such third parties prior to providing your personal information in connection with such products or services.

10. Withdraw Consent

You can choose not to provide any personal information to us or to withdraw your consent for the collection, use, or disclosure of your personal information for purposes set out in this Privacy Policy. If you choose to do so, you may not have access to all parts of our Website and we might not be able to provide you all of the services and customer support offered to our visitors and users under this Privacy Policy and our Terms and Conditions.

11. Requests for Access and Correction

We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it. You can view and change your personal information by signing in to your Account. Please update your personal information immediately if it changes or is inaccurate.

Upon your request, we will close your Account and remove your personal information from view as soon as reasonably possible, based on your Account activity and in accordance with applicable laws.

Contact

If you have any questions or concerns about our Privacy Policy, or how we have handled your personal information, please contact us in writing. Our contact information can be found at: theseniorpaper.com/contact