Welcome to Snapbets. Snapbets provides a fast and fun way for you to bet your friends. Create a bet, invite your friends, vote up your favourite responses, add comments (if you like) and share!
Our Policy applies to all visitors, users, and others who access the Service (“Users”).
10FOLD PRIVACY PHILOSOPHY
10Fold Inc. (“10Fold”) is committed to fairly and lawfully collecting and maintaining accurate personal information and to protecting the confidentiality of all personal information that we collect, retain, use or disclose to others in the course of our business activities.
OUR CONTINUING COMMITMENT TO YOU
Protecting the privacy and confidentiality of personal information has always been fundamental to the way we do business at 10Fold. We strive to meet or exceed all the privacy standards established by federal, provincial and industry authorities in all our dealings with past, current and prospective Users.
WHAT IS PERSONAL INFORMATION?
Personal information is information that identifies you as an individual. It includes your name and address, age and gender, also your personal financial records, and identification numbers.
WHAT IS IN THIS CODE
This Privacy Code has been developed to meet the standards set out in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and similar provincial legislation. The Privacy Code describes the principles 10Fold will use to protect the privacy of personal information we possess about our Users, and establishes ethical and fair information management practices with respect to personal information collected, used or disclosed by 10Fold. The Code informs Users and our business associates how personal information is handled within 10Fold.
APPLICATION OF THIS CODE
This Privacy Code applies to all 10Fold directors, officers, and employees with respect to any personal information in the possession or control of 10Fold.
This Privacy Code does not apply to information about business customers carrying on business as corporations, partnerships or in other forms of association. The confidentiality of information with respect to those entities is protected at 10Fold by our adherence to the applicable laws, our contracts with our business customers, and 10Fold’s other internal policies. This Code does, however, apply to information about officers, staff or principals of corporate clients.
THE REASONABLE PERSON APPROACH
PIPEDA is really about sound information management practices. It requires an ethical, common sense, “reasonable person” approach to requesting, validating and maintaining personal information as a part of our business activities. Confidentiality is a sensitive topic. Many people in today’s world have raised concerns about the privacy of their personal information. Within 10Fold we strive to understand what Users deem to be reasonable and then apply the principles in this Code.
10FOLD’S PRIVACY PRINCIPLES
10Fold endorses and has adopted the ten privacy principals set out in full in Schedule 1 of PIPEDA. These ten privacy principles summarized below, embody sound and prudent information management practices. These practices will provide the necessary assurances that personal information obtained and utilized by 10Fold in the course of its business activities will be accurate, held in confidence and be retained in a secure environment.
Principle 1: Accountability
10Fold takes responsibility for protecting and maintaining personal information under its control and has appointed a Privacy Officer to ensure compliance with these principles and PIPEDA.
Principle 2: Identifying the Purposes for Collecting Personal Information
10Fold will identify and disclose the reasons for which personal information is collected and used by 10Fold at or before the time the information is collected.
Principle 3: Consent
10Fold will obtain an individual’s informed consent for the collection, use or disclosure of personal information by 10Fold, except as otherwise required or permitted by law.
Principle 4: Limits to the Collection of Personal Information
10Fold will limit the amount and type of personal information collected to that, which is necessary for its intended purposes. Personal information will be collected by fair and lawful means.
Principle 5: Limits to the Use, Disclosure and Retention of Personal Information
10Fold will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual, or as required or permitted by law. Personal information will be retained only as long as it is necessary to fulfill those purposes.
Principle 6: Accuracy
To minimize the possibility of inappropriate information being considered in its decision-making processes, 10Fold will keep personal information as accurate, complete, and up-to-date as necessary for its intended purposes.
Principle 7: Safety & Security
10Fold will maintain appropriate safeguards to protect personal information from loss or theft, unauthorized access, disclosure, copying, use or modification regardless of the format in which it is retained.
Principle 8: Openness
10Fold will inform its Users about its policies and procedures regarding the management of personal information. 10Fold will ensure that these policies and procedures are easily understood and readily available.
Principle 9: Individual Access
Upon request, 10Fold will inform an individual of the existence, use and disclosure of his or her personal information and will provide the individual access to that information to verify and or update its accuracy and completeness.
Principle 10: Handling Inquiries
An individual will be able to direct an issue or concern regarding compliance with the above principles, or 10Fold’s practices to 10Fold’s Privacy Officer or to other accountable employees.
WHAT INFORMATION DOES 10FOLD COLLECT?
We collect the following types of information.
Information you provide us directly:
Your username, password and e-mail address when you register for a Snapbets account.
Profile information that you provide for your user profile (e.g., first and last name, picture). This information allows us to help you or others be “found” on Snapbets.
User Content (e.g., photos, videos, comments, and other materials) that you post to the Service.
Communications between you and Snapbets. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.
Finding your friends on Snapbets:
If you choose, you can use our “Find friends” feature to locate other people with Snapbets accounts either through (i) your contacts list, (ii) third-party social media sites or (iii) through a search of names and usernames on Snapbets.
If you choose to find your friends through (i) your device’s contacts list, then Snapbets will access your contacts list to determine whether or not someone associated with your contact is using Snapbets.
If you choose to find your friends (iii) through a search of names or usernames on Snapbets then simply type a name to search and we will perform a search on our Service.
*Note about “Invite Friends” feature: If you choose to invite someone to the Service through our “Invite friends” feature, you may select a person directly from the contacts list on your device and send a text or email from your personal account. You understand and agree that you are responsible for any charges that apply to communications sent from your device, and because this invitation is coming directly from your personal account, Snapbets does not have access to or control this communication.
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, addons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
Cookies and similar technologies:
More information is available in our About Cookies section.
Log file information:
Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Snapbets.
A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other’s APIs then, your latitude and longitude will be stored with the photo or video and searchable (e.g., through a location or map feature) if your photo is made public by you in accordance with your privacy settings.
WHY INFORMATION IS COLLECTED AND HOW IT IS USED
- Help you efficiently access your information after you sign in;
- Remember information so you will not have to re-enter it during your visit next time you visit the Service;
- Provide personalized content and information to you and others, which could include online ads or other forms of marketing;
- Provide, improve, test, and monitor the effectiveness of our Service;
- Develop and test new products and features;
- Monitor metrics such as total number of visitors, traffic, and demographic patterns;
- Diagnose or fix technology problems; and
- Automatically update the Snapbets application on your device;
Snapbets or other Users may run contests, special offers or other events or activities (“Events”) on the Service. If you do not want to participate in an Event, do not use the particular Metadata (i.e. hashtag or geotag) associated with that Event.
In general, you can choose not to provide us with some or all of your personal information. However, you must understand that if you make this choice, 10Fold may not be able to provide you with the product, service, or information that you requested or that was or could be offered to you.
DISCLOSURE OF PERSONAL INFORMATION OUTSIDE OF 10FOLD
10Fold has a strict policy of not renting or selling personal information about our Users. 10Fold will not release your information to third parties outside of Snapbets, subject to the important exceptions discussed below.
The most common reason for release of your personal information is that you have given your consent, such as information or content you have voluntarily disclosed or posted to the Service. As with any information you disclose or post virtually, the level disclosure to the public depends on the applicable privacy settings you have chosen. Once you have shared User Content or made it public, that User Content can be re-shared by others. We may also share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that Snapbets is part of, or that become part of that group (“Affiliates”). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates’ own services (including by providing you with better and more relevant experiences). But these Affiliates will honor the choices you make about who can see your photos.
We also may share your information as well as information from tools like cookies, log files, and
device identifiers and location data, with third-party organizations that help us provide the Service to you (“Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information
Other reasons may include if we have a legal obligation, such as a court order, or if we need to protect assets (e.g. collection of overdue accounts) or the public’s interest. For example, we may release personal information about a customer to legal authorities in cases of criminal activity, or for the detection and prevention of fraud. If we release information for any of these reasons, we keep a record of what, when, why and to whom such information was released.
SHARING YOUR PERSONAL INFORMATION
If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Snapbets API have copied or saved that information.
Your personal information is shared, to the extent permitted by law, and to the extent necessary to provide you with the best service, within 10Fold and our Affiliates in order to provide the Service.
EXCEPTIONS TO THE “NO COLLECTION, USE OR DISCLOSURE WITHOUT CONSENT” RULES
The limited exceptions, applicable to 10Fold, relating to obtaining consent for the collection, use or disclosures of personal information include the following:
10Fold is authorized by PIPEDA to collect personal information without the knowledge or consent of the individual where:
- collection of the personal information is clearly in the interests of the individual and consent cannot be obtained in a timely manner;
- it is reasonable to expect that collection of the personal information with the knowledge or consent of the individual would compromise the availability or accuracy of the information and the collection is reasonable for purposes of investigating a breach of an agreement or contravention of federal or provincial law; or
- the information is publicly available and is specified by regulations issued by federal legislation.
10Fold is authorized by PIPEDA to use personal information, without the knowledge or consent of the individual, in circumstances including where:
- the personal information was originally collected without consent, express or implied, and collection was clearly in the interests of the individual and consent could not be obtained in a timely manner;
- the information was originally collected without consent, express or implied, in circumstances where collection with the knowledge and consent of the individual would compromise the availability or accuracy of the information and the collection was reasonable for the purposes of investigating a breach of an agreement or a contravention of federal or provincial law;
- 10Fold has reasonable grounds to believe the information could be useful in the investigation of a contravention of federal, provincial or foreign law, that has been, is being, or is about to be committed, and the information is used for the purpose of investigating that contravention;
- it is used with respect to an emergency that threatens the life, health or security of an individual;
- it is used for statistical, or scholarly study or research purposes, under limited conditions approved by the Privacy Commissioner; and/or
- the information is publicly available and is specified by the Regulations to PIPEDA.
PIPEDA authorizes 10Fold to disclose personal information without the knowledge or consent of the individual in circumstances including if such disclosure:
- is made, within the Province of Quebec, to an advocate or notary or, in any other province, a barrister or solicitor who is representing 10Fold;
- is for the purpose of collecting a debt owed by the individual to 10Fold;
- is required to comply with a subpoena or warrant issued, or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records;
- is made to a government institute that has identified its lawful authority to obtain the information, and which has indicated (i) it suspects the information relates to national security, the defense of Canada, or the conduct of international affairs, or (ii) disclosure is requested for the enforcement of federal, provincial or foreign law, carrying out an investigation relating to such enforcement, or gathering intelligence for the purpose of such enforcement, or (iii) disclosure is requested for the purpose of administering a federal or provincial law;
- is made to an investigative body or government institution on the initiative of 10Fold, and relates to a breach of an agreement or a contravention of federal, provincial or foreign law; or where 10Fold suspects the information relates to national security, the defense of Canada or the conduct of international affairs;
- is made because of an emergency that threatens the life, health or security of an individual and 10Fold informs the individual without delay of the disclosure; and/or
- is made for statistical or scholarly study and research purposes, under limited conditions, approved by the Privacy Commissioner.
SAFEGUARDING OF PERSONAL INFORMATION
Your personal information is secure within 10Fold. We have comprehensive security controls to protect against unauthorized use, alteration, duplication, destruction, disclosure, loss or theft of, or unauthorized access to, your personal information.
10Fold may use other companies to provide services to you on our behalf, such as the storage of your files in a secured environment or to conduct customer satisfaction surveys on our behalf. In such cases, we will have contracts in place holding these companies to the same high standards of confidentiality by which we are governed and requiring that any information provided by us must be kept strictly confidential and used only for the purposes of the contract.
10Fold ensures the physical, organizational and electronic security of your personal information through the use of secure locks on filing cabinets and doors, and restricted access to our information processing and storage areas. 10Fold limits access to relevant information to authorized employees only, and through the use of pass keys and computer passwords and, where necessary, the encryption of electronically transmitted information.
10Fold has procedures in place when destroying, deleting or disposing of personal information when it is no longer required for the purposes as set out in this Code, or by law, to prevent unauthorized access to such personal information.
Your account information and profile/privacy settings:
Update your account at any time by logging in and changing your profile settings.
Unsubscribe from email communications from us by clicking on the “unsubscribe link” provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
RETENTION OF YOUR PERSONAL INFORMATION
10Fold only keeps your personal information for as long as we need it to meet the purposes set out in this Code. The length of time we retain your personal information is also affected by: (1) the type of product or service you have from us, and (2) any legal requirements we may have to meet such as regulatory file retention periods or for being able to respond to any concerns you may have even if you are no longer a User.
HOW TO CONTACT US ABOUT A DECEASED USER
In the event of the death of a Snapbets User, please contact us. We will usually conduct our communication via email; should we require any other information, we will contact you at the email address you have provided in your request.
Snapbets does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us.
HOW YOU CAN HELP US PROTECT YOUR PERSONAL INFORMATION
If you want to review or verify your personal information, or find out to whom we have disclosed it as permitted by this Code, you can contact us by email. We may provide you with a form to sign if your request is complicated, and will help you complete the specific information we will need from you to enable us to search for, and provide you with, the requested personal information we hold about you. We may charge you a fee to do this and will advise you of the fee in advance.
There are a few instances where we will not be able to provide the personal information we hold about you that you request. Some of these instances include, if:
- it contains references to other persons;
- it is subject to solicitor-client or litigation privilege;
- it contains our own proprietary information that is confidential to us;
- it has already been destroyed due to legal requirements or because we no longer needed it for the purposes set out in this Code;
- it is too costly, in our determination, to retrieve;
- we are prohibited by law from disclosing to you.
If we are unable to provide you with access to your personal information, we will explain the reason why.
KEEPING YOUR PERSONAL INFORMATION ACCURATE
We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes set out in this Code. You play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your personal information, that amendments are required, please advise us.
DO YOU HAVE QUESTIONS OR CONCERNS?
If you have privacy questions, concerns or complaints, we want them to be answered satisfactorily or resolved as quickly as possible and ask that you follow, in order, the following three steps.
Contact us by email. Most questions or concerns can be addressed in this manner.
If the Customer Service Representative or the employee you dealt with is unable to resolve the matter to your satisfaction, advise them that you wish the matter to be reviewed by the department manager who will contact you to resolve the issue. You may be asked to put your concern or complaint in writing.
If you are still not satisfied contact 10Fold’s Privacy Officer at:
5206 – 39 Street
Ponoka, Alberta, T4J1C8
Upon completion of review by 10Fold’s Privacy Officer, if the above steps fail to resolve your concern to your satisfaction, your issue may be reviewed by the Privacy Commissioner of Canada who you may contact at any time in this process, by writing to:
The Privacy Commissioner of Canada 112 Kent Street
Ottawa, ON KlA OH2
by telephone, toll free, at 1-800-282-1376
Any 10Fold employee who believes personal information is not being handled in accordance with this Policy should immediately so advise their manager and the Privacy Officer.
Department Managers required to resolve privacy issues (as per the second step in our privacy question and complaint handling process) shall maintain appropriate records of the same and shall report them to the Privacy Officer.
Department Managers are responsible for oversight of this Policy within their department, including establishing, implementing and regularly reviewing the necessary procedures and standards to give effect to this Policy and to train their staff accordingly.
The Privacy Officer shall act as a resource to Department Managers in the handling of disputes and will assist Department Managers with developing procedures, standards, guidelines and interpretations, promoting awareness of privacy issues and developing staff training programs.
KEEPING THIS PRIVACY CODE CURRENT
Changes to this Privacy Code and the information handling practices of 10Fold will result in amendments to this document from time to time. 10Fold may add, delete or modify sections at its discretion.