SPHERE DEVELOPMENTS’ PRIVACY POLICY

Sphere Developments respects your right to privacy. This policy summarizes what personally identifiable information we may collect, and how we might use this information. This policy also describes other important topics relating to your privacy.

You (the “User”) acknowledge that in the course of your dealings with any Sphere Developments entity or affiliate thereof (collectively, “Sphere Developments”), whether via this website at https://spheredevelopments.ca/ (the “Website”), electronic mail and other downloadable materials, web portals or other online resources maintained by Sphere Developments, the User may provide personal information to Sphere Developments. This policy does not apply to personal information collected from offline resources and communications, except in cases where such personal information is consolidated with personal information collected by Sphere Developments via the Website and other online resources described above. This policy also does not apply to third-party online resources to which the Website may link, where Sphere Developments does not control the content or the privacy practices of such resources.

Sphere Developments reserves the right to alter or modify this policy from time to time in its sole and absolute discretion. By using the Website and other online resources described above, you acknowledge and agree to be bound by the provisions of this policy.

This policy has been implemented to comply with Canada’s Anti-Spam Legislation (“CASL”) which came into effect July 1, 2014.

Sphere Developments PRIVACY OBJECTIVES
It is Sphere Developments’ policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our employees, customers, business partners and others who share their personal information with us.

CONSENT
To the extent required by applicable law, whenever Sphere Developments collects personal information, we will:

• collect the User’s personal information only for specific, limited purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;

• process the User’s personal information in a manner consistent with the purposes for which it was originally collected or to which the User consented pursuant to this policy;

• take commercially reasonable steps to ensure that the User’s personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;

• not use the User’s personal information for direct marketing purposes without giving you an opportunity to opt-out.

By using the Website and other online resources described above, the User consents to the collection, use, and disclosure of the User’s personal information on the foregoing basis and as otherwise set out in this policy. If the User does not consent to this policy, as set out herein, the User must immediately cease use of the Website and other online resources. Please note that the User’s access and continued use of the Website and/or other online resources will be deemed as consent by Sphere Developments.

Any personal information collected or disclosed without the consent of a User will only be collected or disclosed in limited circumstances that are expressly permitted by law. For example, privacy legislation permits the collection or disclosure of personal information in certain circumstances where there is a concern for health and safety, or in an emergency.

If a User withdraws or limits its consent for Sphere Developments to collect or disclosure personal information, Sphere Developments may be limited in its ability to provide services – as this may limit Sphere Developments ability to access essential information, or limit its ability to contact a User.

Importantly, this Website is intended for users who are over 18 years of age. Persons who are 18 years of age or less should not provide any personal information directly to Sphere Developments, and Sphere Developments will require a parent or guardian to communicate directly with Sphere Developments for all services related to children or minors.

In certain limited circumstances, Sphere Developments may be required to release or provide access to personal information in response to a subpoena, search warrant, court order, law, or regulation. In such case, Sphere Developments will take all appropriate measures to ensure that Users’ personal information is protected to the greatest extend possible while Sphere Developments cooperates fully with court and law enforcement authorities in this regard.

WHAT IS PERSONAL INFORMATION?
Personal Information is defined in Personal Information Protection and Electronic Documents Act (“PIPEDA”) as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records. Personal Information includes, but is not limited to, a User’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, interests, browsing preferences, web logs, Internet protocol addresses, network and server particulars, and/or other information relevant to the Website, promotional and marketing activities.

PRIVACY LEGISLATION
Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the PIPEDA and the Canadian Standards Association Model Code for the Protection of Personal Information, incorporated by reference into PIPEDA. These obligations extend to Sphere Developments and are integrated into This policy herein.

HOW IS PERSONAL INFORMATION COLLECTED?
Sphere Developments collects Users’ personal information in order to enable us to communicate with Users and provide them with our services. Sphere Developments collects a User’s Personal Information in one of two ways: unsolicited information provided by a User and information collected from a User’s computer or other electronic device.

Unsolicited Information

Sphere Developments may collect unsolicited personal information provided by a User voluntarily, such as data entered into forms or data fields on the Website or via any other online resources.

Information Collected from a User’s Computer or other Electronic Device

Sphere Developments collects information from a User’s computer and other electronic devices when a User accesses the Website and other online resources. The information that is collected during this process includes but is not limited to a User’s Internet Protocol (IP) address, domain name, browser type, date and time of a User’s request and information provided by tracking technologies, such as cookies and single-pixel tags, which are defined below.

If a User is accessing the Website from a mobile device, Sphere Developments may collect information about the User’s device, such as a User’s device ID and device type, as well as usage information, use of mobile websites and other mobile resources.

“Cookies” are small text files placed on a User’s hard drive that assists Sphere Developments in providing a customized browsing experience. Cookies contain a unique identification number that identifies a User’s browser, but not the visitor, to Sphere Developments’s computers each time a User visits the Website. Sphere Developments uses cookies to make navigation of the Website easier for visitors and to facilitate efficient registration procedures. If a User is concerned about cookies, most browsers permit individual to refuse to accept all cookies or to notify Users when a User has received a cookie. However, a User should note that if the User refuses to accept cookies, the User may not be able to use some of the features available on the Website and other online resources.

“Single-pixel tags”, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible. Single-pixel tags are used to collect information in web logs that do not identify a User personally such as web pages viewed, the web site a User came from and the advertisement the User clicked on to visit the Website. Single-pixel tags are also used to confirm whether promotional or other commercial e-mail messages that are sent via the Website are opened.

In order to properly manage the Website, Sphere Developments may also anonymously use log information on operational systems, and identify categories of Users by items such as domains and browser types. Statistics may be reported to a party assisting Sphere Developments in offering the Website, such as webmasters.

REQUESTS FOR NON-DISCLOSURE OR LIMITATION
A User may withdraw their consent to Sphere Developments ‘s collection, use and disclosure of personal information at any time, subject to legal and/or contractual restrictions and upon reasonable notice, by contacting Sphere Developments at the address listed below. Please note certain personal information will be collected automatically when a User visits the Website. A User’s continued use of the Website will be deemed consent to obtain any personal information that derives from the User’s use of the Website.

A User may choose not to provide Personal Information to Sphere Developments by electing not to enter any personal information into a form or data field, and by not using any personalized services provided by the Website or by any other online resources. However, some of the Website may only be available to Users that provide personal information or request the use of personalized services.

If a User previously agreed to permit the use of Personal Information for marketing or promotional purposes, a User may revoke consent by following the opt-out instructions in each communication or by writing to Sphere Developments at the address listed below.

HOW MAY A USER ACCESS AND CORRECT PERSONAL INFORMATION?
Users may access, update, and correct personal information in the possession of Sphere Developments, subject to certain exceptions prescribed by law.

Upon written request, Sphere Developments will provide a User with any personal information in its possession to the extent required by law.

If a User would like to access any of its personal information, or believes that any of the personal information collected by Sphere Developments relating to a User is incorrect or incomplete, please send an electronic message to Sphere Developments at the address listed below.

COMPLIANCE WITH CASL
Sphere Developments is committed to reducing the harmful effects of spam and related threats to electronic commerce and is working towards a safer and more secure online marketplace.

CASL regulates certain forms of electronic contact, consisting of, the sending of commercial electronic messages, the alteration of transmission data in electronic messages, and the installation of computer programs on another person’s computer system, in the course of a commercial activity. The fundamental underlying principle of CASL is that such activities may only be carried out with consent.

Sphere Developments complies with CASL and works with its affiliates, customers and partners to seek consent, as required by CASL, before communicating any commercial electronic messages.

FOR MORE INFORMATION; CONTACT INFORMATION
For more information about this policy, please contact the Sphere Developments as follows write to us at:

170 Robert Speck Parkway, Unit 203 Mississauga, ON L4Z 3G1
905-744-4545
info@spheredevelopments.ca

For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:

Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.