This Policy will inform you of the privacy practices and policies implemented on this BrandSpark website and all the sites of BrandSpark and all its authorized affiliates, including BrandSpark International Inc. and Best New Product Awards Inc. (altogether “BrandSpark” or “we” or “us” or “our”). It describes how we collect, use, process and share information about you, your rights and choices about such use and sharing, and how we manage the personal information collected through our websites www.BrandSpark.com , www.BestNewProductAwards.com , www.BestNewProductAwards.biz, and www.BrandSparkMostTrusted.com , www.ShopperArmy.ca , www.ShopperArmy.com and their programs, as well as related internal websites, social media pages, intranet, mobile applications and other online communications (collectively the “Site” or “websites”). This policy applies to your use of any of our services that reference this policy or that are otherwise described in this policy as a BrandSpark offering or method of information collection (collectively, the “Service”).
“Consent” is voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of BrandSpark. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
“Personal information” is broadly defined as information about an identifiable individual that could be used to specifically identify you as the user, including information such as your name, address, telephone number, birth date and e-mail address. Personal information does not include the name, title, business address, or telephone number of an employee of an organization. Data we collect with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not considered personal information.
“Respondent” is a member of the public who provides personal information to BrandSpark, for example in the course of participating in a panel survey or during quantitative or qualitative marketing or social research.
“Third party” is an individual or organization outside of BrandSpark.
“User-submitted Content” or “Submissions” means information or content that you voluntarily choose to submit or post to the Site/Service for public display, such as photos, comments, reviews, and your public profile information.
BrandSpark will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information will be destroyed, erased or made anonymous.
We carefully limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. We collect personal information in a variety of ways, including: directly from you, from third parties, through technologies, and when you are interacting with us online or through our mobile applications. The following are examples of the ways we collect information about you.
Directly from you:
You may provide personal information to us on our site, by mail, by email, over the telephone, through our websites or mobile applications or in any other direct manner.
From Third Party or Other Sources:
Occasionally, we may receive personal information from other sources. In these cases, we receive your personal information from these other sources with your consent or if the law requires or permits us to do so. Such information may be from:
From Technologies, Website and Applications
We may collect personal information through various types of technologies, including, for example, anonymous analytics which allows us to track numbers of individuals and consider certain demographic information about our user base on an anonymous basis, which we may use from time to time. This data is treated as non-Personal Information, except as required under applicable law, since it is de-identified and becomes anonymous.
Automatically certain information is collected electronically about you through interaction with our Services, sites, email, mobile applications, social media accounts; use of our or a third party’s technologies, which include Cookies and other tracking technologies’ and monitoring and analyzing trends, usage, and activities. This information helps us understand what actions you take on our websites and mobile applications and allows our websites and mobile applications to work correctly.
We may combine this information with other information collected such as your online shopping transaction history. We do this to support our customer understanding using website and mobile analytics and to provide you with more tailored bonus offers and campaigns.
The information we collect sometimes includes personal data, which is information relating to identified or identifiable natural persons. Some examples of the types of information we may collect include (and much of which is optional to submit):
We do not sell your personal information to any organization or person.
Without limiting the following, in our sole discretion, we may share non-personal aggregated information which does not identify you (or de-identified information about you) with third parties or affiliates for any purpose except as prohibited by applicable law. Also, such aggregate information allows us to study the general shopping habits, behaviours and patterns of our members which can provide very useful information to brands, who can then customize offers and target their media more effectively. Shopper Army members benefit when we work with brands and retailers to be able to offer our members extra and exclusive bonuses and special offers and we are also then able to offer our members most of the affiliate marketing commissions that we earn. The brands’ offers may also show up as bonus cash back percentage offers or as offers obtained through exclusive promo codes. Members also benefit when brands sponsor special offers with Shopper Army to introduce members to their new products or bestsellers.
We may share your personal information within our affiliates and subsidiaries or with our service providers (companies operating on our behalf) and other third parties (companies with which we provide programs, products or services) for the purposes described in this policy and in accordance with applicable law. When we share with our affiliates and subsidiaries for purposes consistent with this policy – including customer support, marketing, and technical operations – they will also meet the data protection obligations contained in this policy.
We may share your information, including personal information or data, under the following circumstances:
With Service Providers In the course of providing our programs, products, services, promotions, contests and events we may share personal information with our service providers (companies operating on our behalf). These service providers help us operate our business, technology systems and applications, internal procedures, infrastructure and advertising and marketing. We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and to comply with our privacy requirements. Service providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.
With our Partners that are engaged in joint sales or product promotions. We also allow certain third parties to integrate components of our services into their own websites and apps. Please be aware that we do not control our business partners’ use of such information. Our partners are responsible for managing their own use of the information collected in these circumstances. We recommend you review the privacy policies of the relevant partner to find out more about their handling of your personal data.
With Third Parties (companies with which we provide programs, products or services) for purposes of facilitating your requests and in connection with tailoring offers, and measuring and improving our Service and marketing effectiveness. In the course of providing certain of our programs, products and services, we may do so through arrangements with third parties. As a result, your personal information may be collected, used and shared by us and the applicable third party. These third parties may have their own privacy policies and terms and conditions, which will govern their use of your personal information. You will be informed upon signing up for the relevant program, product or service of the third party arrangement so that you can review the relevant privacy policies that apply.
With our Clients in connection with our processing of your information on their behalf. For example, we share your information with our clients to conduct market research services, respond to your questions and comments, comply with your requests, market and share offers or promotions, and otherwise comply with applicable law.
With your Consent
Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of BrandSpark in accordance with applicable law. Information is also shared where the respondent has consented to such disclosure. We may share your information for any other purpose with your express consent
By subscribing to our programs, products and services and/or submitting information to us in connection with using our programs, products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.
We will obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this policy or in the terms and conditions of a specific program, product, service, contest, promotion or event you signed up for, participated in or purchased. Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of our group of companies, in accordance with applicable law.
Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us. If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the programs, products, services, contests, promotions, events or information that you requested or that could be offered to you.
In attaining consent, BrandSpark will use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed, and these purposes will be stated in a manner that can be reasonably understood by the respondent. BrandSpark will generally seek consent to use and disclose personal information at the same time that it collects the information. However, BrandSpark may seek such consent after the personal information has been collected but before it is used and/or disclosed for a new purpose. In determining the appropriate form of consent, BrandSpark will take into account the sensitivity of the personal information and the reasonable expectations of respondents.
Participation in a BrandSpark quantitative or qualitative marketing or social research study or survey or emailing a BrandSpark employee may constitute implied consent for us to collect, use and disclose personal information for the identified purposes, including communicating with the individual.
By participating as a member of Shopper Army you consent to Shopper Army being able to utilize and/or provide information or insights through the generalized aggregate data (“User Data”) on your shopping cart preferences and shopping behaviours. This User Data may include (a) demographic information such as age, gender, and postal code, (b) information regarding the offers that the user has participated in or offers that the user has claimed or redeemed, (c) any transactional or other data that is generated, collected or obtained by Shopper Army through a collaboration pertaining to a sponsored offer.
All non-personal information shared in the Site and all BrandSpark surveys will be considered non-confidential and non-proprietary and shall immediately become the property of BrandSpark. Users of the Site may from time to time be encouraged to submit, post, email or upload survey responses, answers, remarks, opinions, comments, information, feedback, ideas, suggestions, graphics, images, photos and other materials or user submitted content to the site, through surveys, emails, email surveys or other channels connected to the Site (collectively the “Submission”). BrandSpark will not be required to treat any such Submission as confidential, and will not be liable for any ideas for its business (including, without limitation, product or advertising ideas) and will not incur any liability as a result of any similarities that may appear in future BrandSpark operations or contents. BrandSpark will be entitled to use the Submission for any commercial or other purpose whatsoever without compensation to any person sending the Submission.
Critical information such as passwords are encrypted upon signup. BrandSpark does not request, collect, use, disclose, store, process or otherwise handle information about any identifiable individual Personal Information beyond what is necessary to provide the offers to members or collaborations or as prescribed by law. We do not request, process or collect any Personal Information that is considered sensitive personal information under applicable privacy laws, including without limitation specific health information, financial/credit information, government ID numbers, or date of birth of minors.
We do not gather credit card or banking information. While we do gather limited purchase order information, only authorized staff can view this for verification purposes. Shopper Army is a portal site where we guide you to the Affiliate Store online retailers and you complete your purchase transactions via these sites. Make sure you understand the privacy policies of any such sites where you provide your credit card or personal information.
We will protect the personal information we collect with security safeguards appropriate to the sensitivity of the information. We take appropriate steps including technical and organizational measures designed to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented measures designed to help protect personal information and we maintain reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control. Through such appropriate security measures and regardless of the format in which the personal information is held, we will protect it against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Unfortunately, no collection or transmission of information over the Internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information you provide to us.
We have personal information retention processes designed to retain personal information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements. We endeavor to protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. BrandSpark employees will be required to respect the confidentiality of personal information.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics providers, such as Google Analytics, to help us analyze your use of the Service, compile statistical reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We use analytics to better understand who is using the Site, how people are using it and how to improve and enhance it. Therefore, as you navigate through this Site, some of your anonymous user information may be passively collected (which you did not actively provide) including, but not limited to, time of visit, pages visited, the length of your user session, time spent on each page of the Site, IP address, type of operating system used, browser type used, and domain name, possibly using various technologies and means, such as Internet Protocol address, cookies, Internet tags, navigational data collection, digital fingerprinting, etc. Most browsers have an option for disabling the cookie feature, which will prevent your browser from accepting cookies. No such above-described information that is collected is shared by BrandSpark with third parties for advertising or other purposes except that it may be disclosed to those of BrandSpark’s contractors who assist with programming and technical aspects of hosting and operating the Site. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others
Navigational Data is not Personal Information in that we do not use it, either alone or coupled with other information, with the intent of revealing your identity. The Navigational Data is used solely for the purposes expressed in this Policy.
In general, you can visit our Website without telling us who you are or submitting any personal information. However, BrandSpark might also collect general anonymous information about visitors to our site, including date and time of the visit, particular pages of the site visited, type of browser used, the IP (Internet Protocol) address of the device, the number of clicks during your visit, the type of device you used, your general geographic location (province or country), the advertisements or videos that you watched during your visit, the name of the internet service provider. We do not in any way link IP addresses with any personal information about individual visitors. We use this information only to determine how to make future visits more convenient and productive.
Navigational Data is collected by means of “Cookies” which are small text files a website can use to recognize repeat users. They provide the convenience to recognize visitors and more quickly provide personalized content or grant you unimpeded access to the website. With cookies enabled, you will not need to fill in information that you have already entered.
Unless you expressly authorize us to do so, we will not share your Navigational Data with any third parties other than our Partners. Even when we share the Navigational Data with our Partners, they are also bound by the rights, uses and limitations disclosed in this policy. We aim to ensure that the Navigational Data is solely used per our instructions and in accordance with this policy, and all applicable laws, security measures and confidentiality requirements. We may also use a third party to help us gather and analyze information about the areas that you visit on the Website to evaluate and improve the customer experience and the convenience of the Website, and to help us evaluate some of the specific information related to your Website visits.
We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: managing your preferences within your account(s), contacting us directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.
You may access, review, update, or remove certain information that you have voluntarily submitted to us through the Service by sending an e-mail to the e-mail address set forth in the “Contact Us” section. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
You have the right to opt-out of any marketing or survey communications from BrandSpark.
You can opt-out of receiving promotional e-mails or surveys from us at any time by following the instructions as provided in e-mails or surveys, clicking on the unsubscribe link, or e-mailing us at the e-mail address set forth in the “Contact Us” section with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your account, transactions, servicing, or BrandSpark’s ongoing business relations.