Last Updated on August 23rd, 2023
This Policy may have changed since the last time You reviewed it. The date of the last update to this Policy is indicated above. If this Policy materially changes, We will use commercially reasonable efforts to notify You that the Policy has changed. This may be done by direct communication to You or indication via the Service.
I. INFORMATION WE COLLECT
When You use the Service, We collect and retain information (including personal information) from You. The information We collect may be provided by You, collected automatically by Us or by a third party, or received from a third party. By using the Service, You consent to the collection, retention, use, and disclosure of Your information. You may refuse or withdraw Your consent at any time. Please refer to VI. ACCESS, CORRECTING & DELETING YOUR PERSONAL INFORMATION. We will not disclose any personal identifying information without Your consent, unless as otherwise set out in this Policy.
As permitted by law, consent to the collection of Your personal information may be implied. In certain circumstances, express consent may be required, and We will do so if it is determined that We must obtain express consent from You. Otherwise, Your acceptance of this Policy, whether by use of the Service or otherwise, indicates Your consent to the collection, retention, use, and disclosure of Your information, including Your personal information. We will not use personal identifying information to contact You for any reason unrelated to Your use of the Service or for commercial reasons unrelated to Our business. We will not disclose any personal identifying information without Your consent unless required by law or as otherwise set out in this policy.
Subject to legal and contractual restrictions, You may refuse or withdraw Your consent at any time by notifying Us in accordance with this Policy. We note that some of the Service require Your personal information to function properly or the Service may only be offered if You provide Us with Your personal information. In such cases, if You refuse or withdraw Your consent, the Service may not be available to You. To refuse or withdraw Your consent, please refer to VI. ACCESS, CORRECTING & DELETING YOUR PERSONAL INFORMATION.
CROSS-BORDER TRANSFERS AND OUTSOURCING
NeXT is headquartered in Canada and the Service is hosted in Canada. However, some of Our development occurs outside of Canada, and may use hosting services located outside of Canada.
As detailed in the disclosure section below where We describe how We share information with third parties, We work with third parties who may be located outside of Canada and Your information may be processed and stored in a country outside of Canada. As a result, foreign federal and state governments, Canadian federal or provincial courts or law enforcement or regulatory agencies may be able to obtain disclosure of Your information through laws applicable in the foreign countries and Canada. Your use of the Service or Your submission of any information to Us will constitute Your consent to the transfer of Your information outside of Your country of residence, which may provide for different data protection and privacy rules than in Your country.
INFORMATION YOU PROVIDE US
We collect and retain Your personal information when You give it to us. Collection and retention may be facilitated through various means such as:
- Sign-up: When You register an account with the Service, We may collect and retain personal information including Your e-mail, cell number, name, gender, date of birth and postal code. You may subscribe to updates (such as newsletters) made available on the Service. As part of the subscription, You may be asked to enter Your name, telephone number and e-mail.
- Surveys: You may participate in surveys made available on the Service. If You participate in these surveys, You may be asked to answer various questions. Such questions may include personal information such as Your name and birthdate.
- Ratings and Reviews: When You submit reviews or ratings through the Service, We may collect and retain information from You relating to the ratings or reviews such as satisfaction score (e.g. NPS), and text review.
- Referrals: The Service may facilitate sharing to a friend, family or other connections that You may have through social media accounts, e-mails, messaging services and other sharing platforms, which may require You to enter personal information.
- Contact Us: When You contact us through the “Contact Us” form on the Service, We collect and retain personal information that You provide us through the form. Such information may include Your name, e-mail, telephone number, and other information requested on the form. We may provide support to You via chatbots, and other interactive platforms and We may collect and retain information from You, including Your name, e-mail, and the text You input into such platforms.
- Location: If You tell Us where You are (e.g., by allowing Your mobile device to send Us Your location), We may store and use that information to verify for eligibility to enter certain Contests and for fraud prevention purposes.
- Contests & Promotions: If You participate in a contest or promotion conducted on Our Sites, We may ask You for Your email address and/or phone number (to notify You whether you win or not). We may also ask for Your first and last names, and address details to verify Your identity. In some situations, We may need additional information in connection with the contest or promotion.
- Redemptions: If You choose to redeem some of Your points for products from the NeXT Rewards Catalogue, We may ask You for Your, name, email address, and delivery address so We can distribute Your product to You.
- Other Activities: We may also collect and retain information at other points in our Service and during other activities where it is clear we are collecting such information.
INFORMATION AUTOMATICALLY COLLECTED
We may collect and retain Your information automatically when You use the Service. This collection may be done directly by Us, or via a third-party service provider. For third-party service providers, please also refer to the disclosure section below where We describe how We share information with third parties. To learn about your experience as a User and to make periodic improvements to the Service and Our business, We may automatically collect and retain certain information. We will automatically record information about your activity on the Service. Your information, including personal information, such as Your Internet Protocol (IP) address, telephone number, network information, Bluetooth information, device information, geo-location, identifiers (such as advertiser identifier) associated with Your computers and mobile devices, Your mobile carrier, browser information, operating system information, and interaction with the Service (e.g. screens viewed, actions taken), date and time stamps associated with transactions, system configuration information, metadata, and other electronic interactions with Us and the Service.
INFORMATION FROM OTHER SOURCES
We may collect and retain information about You from third-party sources. When You connect to the Service using Your social media accounts or other federated identity management services, We may receive information such as Your public profile, language, age group, country, and other information that such social media services or federated identity management services may provide. In addition to enabling the connection, We may use Your information for matching You with clients on the Service, as well as for delivering advertisements that may be relevant or of interest to You. Please see the Marketing and Remarketing section below.
II. PURPOSES OF COLLECTION, RETENTION, USE AND DISCLOSURE
We use the information collected for the purposes for which it was collected, which are listed below in the Purposes section. If a purpose is not listed, We will disclose the purpose before or at the time of collecting the information.
Your information may be collected, retained, used and disclosed for the following purposes:
- To communicate with You in accordance with applicable laws
- To provide Services to You, such as sending rewards to You and creating, updating, and managing Your account
- To verify Your identity
- To connect with Your other accounts such as social media accounts
- To provide recommendations and offers on products and services
- To develop new and improve existing products and services
- To respond to Your inquiries and comments
- To prevent fraud and abuse of the Service
- To protect other users of the Service, against security breaches and Our business
- To understand Our user base and effectiveness of the Service
- To improve the quality of your experience of our Sites and Service
- To administer, operate, and improve the Service and for internal business purposes
- To compile aggregated data, perform statistical analyses, and otherwise analyze Our business for internal and external business purposes
- To display relevant advertising and remarketing across the services
- To comply with legal and governmental requirements
- To process job applications
The purposes for which Your information is collected and retained may be applicable for Us to process Your information or for a third-party service provider to process Your information in relation to the Service.
III. HOW WE SHARE INFORMATION
We may disclose Your information to various parties as disclosed in this section. These parties include Our clients, business partners, third-party service providers, government authorities or other parties as described in this section.
We may share information with Our clients and their service providers who use the Service. The information sharing is provided as part of Our suite of products that are based on the Service and the information shared may include: Your identifiers, information collected when You signed up to the Service, information collected from You via surveys, information uploaded by You, ratings and reviews submitted by You, aggregated information that We generated using information from the Service that may incorporate Your information, and information automatically collected about You and Your devices.
We do not control the privacy practices of Our clients and their service providers. Please contact them directly to learn more about their privacy practices.
THIRD-PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS
We may use third-party service providers and business partners to perform functions in connection with the Service. Examples of such functions include: consultation, notifications, analytics, marketing and remarketing, catalogue redemption, any form of betting, offers & coupons, reviews and ratings, federated identity management, and referral services. Some of the third-party service providers and business partners may be provided or given access to Your personal information and they may be located outside of Canada.
Below is a description of how We share information with Our third-party service providers and business partners:
- Consultation: We may work with partners to continue to improve the Service We provide to You and the viability of Our business. Consulting partners may be provided broad access to Our information for them to have a holistic understanding of Our business. This may include Your information and the level of access may depend on the service provided by our consulting partners. For example, a consulting partner working with Us on privacy improvements may have greater access to Our data.
- Notification: We may use the services of companies that provide notification services for Us to reach Our user base. This notification may be via the Service (e.g. in-app notification) or outside of the Service (e.g. e-mail). To enable this service, We may share Your IP address, device information, operating system information, and activities on the Service (e.g. actions taken, screens viewed).
- Catalogue Redemptions: Redemptions made by You for the NeXT Rewards Catalogue may be provided by third-party service providers. To provide this service, these providers may have access to Your name, email address, and delivery address to provide the service.
- Any Type of Betting: We may work with third-party service providers to allow You to bet with other users or place single instance bets using Your points. To provide this service, these providers may have access to Your name, email address, cell number, and age to provide the service and qualify accessibility.
- Offers & Coupons: We may work with third-party service providers to allow You to receive offers and coupons. To provide this service, these providers may have access to Your name, email address, cell number and device information to provide the service.
- Reviews and Ratings: The reviews and ratings functionality in the Service may be provided by a third-party service provider. These reviews and ratings may be used by to improve the level of Our Service. To ensure the authenticity of the reviews and ratings, these providers may use Your information such as network information, advertising identifiers, and camera.
- Federated Identity Management: We may in the future work with companies that provide federated identity management. To enable such a service, We may provide Your personal information to such companies to verify Your identity.
- Referral Services: We may work with companies that enable You to refer a friend, family or other connections via e-mail, messaging services, social media platforms, and other communication means. We may share Your name, e-mail, device information and IP address to enable this referral service.
COOKIES AND OTHER TRACKING TECHNOLOGIES
- Web Beacons: Web beacons (also known as pixels) allow activities to be tracked and We may use it to track Your activities on the Service, help us with Our marketing and remarketing efforts, offer You products and services You may be interested in. Web beacons may collect Your information that is similar in nature to information stored in cookies such as Your login information (except passwords), session information, device information, network information, and activities on the Service (e.g. actions taken, screens viewed).
- Software: The Service may incorporate software from third-party service providers to enable tracking of users on the Service. Such software may collect Your information such as Your location, identifiers, e-mail, network information, device information, and information in Your account to provide Us tracking services.
If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of Our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith. Specifically, We may disclose information about You to third parties without Your consent where We believe that such disclosure is necessary to determine whether to proceed with a prospective business transaction or to complete a transaction in progress or where the information is necessary to carry on the activity that was the object of the transaction. A “business transaction” includes:
- the purchase, sale or other acquisition or disposition of an organization or a part of an organization, or any of its assets;
- the merger or amalgamation of two or more organizations;
- the making of a loan or provision of other financing to an organization or a part of an organization;
- the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities of an organization;
- the lease or licensing of any of an organization’s assets; and
- any other prescribed arrangement between two or more organizations to conduct a business activity.
INVESTIGATIONS AND LAW
We may disclose information about You to third parties without Your consent if We believe that such disclosure is necessary to:
- Investigate fraud and abuse on the Service;
- Take action regarding suspected illegal activities;
- Enforce or apply this Policy or other agreements with Us;
- Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
- Protect Our rights, reputation, safety, and property, or that of users or others;
- Respond to claims and legal process (for example, subpoenas); and/or
- Protect against legal liability.
Where obliged or permitted to disclose information without consent, We will not disclose more information than is required.
Aggregated information that We compiled or created may be shared with third parties. The aggregated information does not contain Your personal information.
IV. RISK OF HARM
We take security seriously and have taken steps to safeguard Your personal information by implementing physical, procedural, contractual, and technical security measures. However, no measures are perfect, and Your personal information may be compromised despite all of Our efforts. Please review this section carefully to understand the risk associated with providing Us Your information.
We protect Your personal information as follows:
- Physical: Our offices are located in a modern, professionally managed, and well-maintained commercial building with restricted access.
- Procedural: We have put in place various organizational and operational processes to ensure that access to and use of Your personal information is limited.
- Contractual: We have put in contractual obligations with third parties with whom We share Your personal information to ensure that Your personal information is secure and protected.
- Technical: The Service includes technical securities such as encryption to ensure that Your personal information is secure. Further, We ensure end-point security of Our devices through strong password protection.
We retain Your personal information for as long as You use the Service and for a reasonable time thereafter. The exact retention period for information varies on the type of information and the purpose for which such information was collected. Some information is necessary to maintain, safeguard, and operate the Service and as a result, such information may be kept indefinitely. When Your personal information is no longer required, We will destroy, erase or convert it to an anonymous form.
Despite all Our efforts in safeguarding Your information, We cannot guarantee the safety of Your information. There are numerous sophisticated adversaries who may employ tactics to defeat Our security measures or the security measures of Our service providers and partners. If You determine that the residual risk remaining from providing Us Your information after taking into consideration the mitigation measures (both security and retention) described above, and the potential for such measures to be defeated, is greater than the benefit obtained from Your use of the Service or is beyond Your risk tolerance, then please do not use the Service. As explained in this Policy, You may refuse or withdraw Your consent at any time. By using the Service, You acknowledge that You understand and assume the risk associated with using the Service.
WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS OR CAUSES BEYOND OUR CONTROL.
In the event the personal information of a User is disclosed as the result of any breach of security of the SERVICE or its servers, regardless of who is at fault, we will take steps to advise all known affected Users within a reasonable timeframe of learning of the breach.
V. LINKS TO OTHER WEBSITES AND THIRD-PARTY ADVERTISERS
You acknowledge that this Policy applies only to the Service that We own or operate. We do not have access to or control over the practices, content or information of other parties and thus, WE DO NOT GUARANTEE, REPRESENT OR WARRANT THAT SUCH PRACTICES, CONTENT OR INFORMATION IS ACCURATE, LEGAL, NON-INFRINGING OR INOFFENSIVE, OR THAT THIRD-PARTY ADVERTISING OR LINKS TO OTHER WEBSITES ARE FREE FROM VIRUSES OR OTHER MALICIOUS CODE. YOU AGREE THAT WE ARE NOT RESPONSIBLE FOR OR LIABLE, DIRECTLY OR INDIRECTLY, FOR ANY DAMAGES OR LOSSES CAUSED OR ALLEGED TO BE CAUSED BY SUCH THIRD PARTIES ADVERTISING, LINKS, CONTENT, PRACTICES OR INFORMATION.
Please contact them directly for more information about their privacy practices.
VI. ACCESS, CORRECTING & DELETING YOUR PERSONAL INFORMATION
We do not routinely update Your personal information but will correct Your personal information when You have indicated to Us that it is inaccurate or incomplete. To guard against fraudulent requests for access, We may require sufficient information to allow Us to confirm that the person making the request is authorized to do so before granting access or making corrections.
If you wish to access or amend Your personal information or to request that We permanently delete Your personal information from Our servers, please send an email to firstname.lastname@example.org. We will ensure Your personal information is accessible, amended and/or deleted in a reasonable time after receiving that request. Deleting such information may require Us to terminate any account You may have created in its entirety and prevent You from using the Service.
So long as Your account remains active, We will preserve Your personal information in accordance with the Policy.
You may decline to share certain personal information with Us, in which case You may not be able to use the Service, either in its entirety or certain features.
When deleting Your information, whether by request or due to inactivity, We will use standard electronic means to remove Your personal information from our files.
We will also retain any and all information that We are required to retain under any applicable laws for the full duration of time required under those laws
You can withdraw Your consent to Our use of Your personal information at any time by emailing Us at email@example.com. Withdrawal of consent does not operate retroactively and may affect Your ability to use the Service.
To communicate with Us regarding this section or about this Policy in general, please contact Us at firstname.lastname@example.org. For some of Your personal information, You may withdraw consent or refuse collection through Your device. For example, You may disable location services or cookies.
VII. USE OF SERVICE BY MINORS
USE OF SITES BY MINORS
With the following restrictions, the Service may be accessed in certain circumstances by persons under the age of 18.
We take the following precautions to protect the safety and information of persons under the age of 18:
- Persons under the age of 16 are prohibited from using the Service without the express permission of a parent or guardian. Persons under the age of 16 are prohibited from submitting any personal identifying information through the Service. We will immediately delete any personal identifying information submitted in violation of this Policy.
- We do not knowingly collect personal information from an individual under age 16. If You are under the age of 16, please do not submit any personal information through the Service.
- If You have reason to believe that We may have accidentally received personal information from an individual under age 16, please contact Us immediately at email@example.com.
VIII. AMENDING THIS POLICY
This Policy may be updated and amended from time to time. We reserve the right to change this Policy at any time, and any amended Policy is effective upon posting to the Service. We will make efforts to communicate any changes to this Policy we deem material, in Our sole discretion, via email or notifications on the Service. Your continued use of the Service will be deemed acceptance of any amended Policy.
IX. CONTACT US
We encourage You to send Us questions and inquiries on this Policy and the steps We take to keep Your personal information secure. Please send Us an email at: firstname.lastname@example.org.
We will respond to all inquiries on the Policy within 10 days.