Last updated: October 12, 2019

42o Blaze Capital Corp. (“Blaze Capital”, “Blaze”, “we”, “our” or “us”) cares about your privacy and the security of your information. We want you to be familiar with how we collect, use and disclose information, including personal information. This Privacy Policy describes our practices in conjunction with your access to our digital products and services. These products and services include Slack (including all channels, DMs and interactions), our websites including but not limited to blazecapital.com and educational library (collectively, the “Websites”), educational material, coaching/mentorship, email newsletters, social media pages, mobile and other applications owned and operated by us, our offline contacts, and to any other services that display this notice (collectively referred to as the “Blaze Capital Services”). If we provide you with a different privacy policy applicable to a particular product or service, then this Privacy Policy will not apply to the personal information collected in relation to the use of such product or service.

The Blaze Capital Services are solely directed to and intended for individuals residing in Canada. This Privacy Policy was drafted with the objective of complying with or exceeding the requirements of Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and British Columbia’s Personal Information Protection Act (“PIPA”). PIPEDA and PIPA set out the ground rules for how B.C. and Canadian businesses may collect, use and disclose personal information. Those who choose to access and use Blaze Capital Services from jurisdictions other than Canada do so at their own risk, and are responsible for compliance with all laws, rules and regulations applicable thereto.

By continuing to access, link to, or use any of the Blaze Capital Services provided to you by Blaze Capital, you signify your acceptance and consent to this Privacy Policy. If you do not agree to these terms or Blaze Capital’s Privacy Policy, please do not use any of the Blaze Capital Services.

Collection of Your Information

For the purposes of this Privacy Policy, “Personal Information” is any information that alone or together with other information in Blaze Capital’s possession is reasonably capable of identifying a particular individual, such as a name, address, phone number, email address, contact information, credit card number, billing information, and password. “Other Information” is any additional information about you that is not Personal Information.

Blaze Capital, and designated service providers of Blaze Capital, may collect, process, use, and disclose Personal Information and Other Information in connection with your use of the Blaze Capital Services. Blaze Capital will take reasonable steps to handle such Personal Information and Other Information fairly and to ensure compliance with applicable laws in relation to the collection, use, and disclosure of such information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ Personal Information and allowing our clients to request access to, and correction of, their Personal Information.

Do not provide information about others unless you are authorized to do so and you consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

What Personal Information do we Collect?

Blaze Capital may collect the following Personal Information from or about you:

(1)       Personal Information we collect directly from you in connection with the use of our Websites, such as when you register to use the Websites or request information from us: Blaze Capital may collect and maintain Personal Information about you, and about any person or entity on whose behalf you are acting, that you provide to us on the Websites, such as when you register to use the Websites, obtain or use any of the Blaze Capital Services, request information or materials from us, or otherwise interact with our Websites. In addition, Blaze Capital or designated service providers of Blaze Capital may take photographs for security purposes and for inclusion in the people directory on the Slack Workspace, which is available to Blaze Capital users worldwide. The types of Personal Information we collect vary based on your particular interaction with us, but could include:

  • your name, company name, and primary role or title;
  • mailing address;
  • telephone number;
  • email address;
  • billing and credit card information;
  • username, password, and other account information; and
  • other information you provide to us online, such as information collected for identification or authentication purposes.

 (2)      Information from telephone, email, online chat, message board, or text message communications with Blaze Capital: If you communicate with Blaze Capital by telephone, email, online chat, message board, or text message, Blaze Capital may keep a record of that communication. If you post Personal Information online or anywhere on the Websites (e.g., sharing news stories of interest) or third-party websites that is accessible to the public or other users, you have made that information available to the public and it is no longer considered private and other people may receive, collect, and use that information. You should exercise caution when deciding whether to post or disclose any of your Personal Information or any Other Information in any chat room or forum, including any public or private chat room or forum on the Websites. Blaze Capital is not responsible for the information that you or others choose to disclose publicly on the Websites, and neither is Blaze Capital’s, our client’s nor others’ use of such information subject to this Privacy Policy.

What Information do we Collect Automatically?

Blaze Capital and our designated service providers may place, view, and use cookies, web server logs, web beacons, or other electronic tools to collect statistical and other information about your use of the Websites. This information may include information about the IP address of your computer, browser type, language, operating system, your mobile device, device ID, geo-location data, the state or country from which you accessed the Websites, the date and the time of your visit, the websites you visited immediately before and after visiting the Websites, the number of links you click within the Websites, the functions you use on the Websites, the databases you view and the searches you request on the Websites, the data you save on or download from the Websites and the number of times you view an advertisement.

There are also certain third-party cookies that reside on our Websites that collect Personal Information, such as information that uniquely identifies your IP address, browser and internet device that may be used by these third parties to, among other things, build a profile of your interests and show you relevant advertisements on the Websites and other websites.

We may combine the Personal Information and Other Information collected on the Websites with information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you, from publicly available sources, such as your company website, or from offline sources, such as information that we collect when you establish your account with us or call our customer service. We will treat such combined information in accordance with this Privacy Policy. If you do not wish to provide such information to Blaze Capital, we may be unable to provide certain services to you.

If you prefer that we not combine your information that has been collected, through cookies, about your use of the Websites, then please delete and disable cookies for each browser, on each computer you use to surf the web. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the web from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the Websites, such as the polls, surveys, contests, and product sales, and certain areas of the Websites for which you need to log in, will not function properly, and the advertising you receive when you visit the Websites may not be advertisements tailored to your interests.

How do we use Personal Information and Other Information?

We only collect, use, and disclose Personal Information and Other Information that is necessary for the following purposes:

  • for research and analysis to better serve visitors to the Websites (e.g., saving your preference and login information, providing access to certain sections of the Websites, providing customized content, and presenting online advertising on the Websites or other websites tailored to your interests as described further below);
  • to provide our services and products;
  • to communicate with you, notify you about important updates or changes to Blaze Capital’s products and services, and address relevant inquiries or complaints;
  • to help Blaze Capital improve our services and products and develop new services and products;
  • to provide support for our services and products, and for Blaze Capital internal quality control purposes;
  • to provide you with offers and promotions about services and products of Blaze Capital or of other parties that may be of interest to you;
  • to analyze the use of the Websites;
  • to enforce the terms and conditions of Blaze Capital;
  • for risk control and for fraud detection and prevention;
  • to protect the interests, rights, safety, or property of Blaze Capital or others and to monitor compliance with and enforce the terms of any agreement with Blaze Capital; and
  • to operate our services, products, and systems properly.

We may also use programs, software, and applications, including, without limitation, Google Analytics, to analyze typical user behavior, improve the Websites, and in connection with our business or operations; and, for security purposes and to ensure the availability of the Websites, we may also use programs, software and applications to monitor network traffic, identify unauthorized attempts to upload or change information, or otherwise cause damage to the Websites or Blaze Capital.

To Whom do we Disclose Personal Information and Other Information?

We may disclose Personal and Other Information to third parties for the following purposes, as permitted by law:

(1)       Affiliates: We may disclose Personal Information and Other Information to affiliates of Blaze Capital (including affiliated websites under common ownership or control) for the purposes described in this Privacy Policy. Affiliates of Blaze Capital may contact you by email, where permitted by law, to make you aware of Blaze Capital’s product and service offerings.

(2)       Service providers: We may disclose Personal Information and Other Information to our service providers, who use it to perform tasks on Blaze Capital’s behalf. Among other things, these service providers help us manage and improve the Websites, provide Blaze Capital services, mail disclosures and statements to you, and administer your accounts. Our service providers may collect, process, and retain information about you directly on behalf of Blaze Capital. Blaze Capital’s service providers include:

  • Any organization involved in providing, managing, or administering the Websites, related systems, or other Blaze Capital services, such as administrators, mail houses, email senders and providers, technology service providers, and third parties that provide analytics and advertising services; and
  • Blaze Capital’s consultants, legal advisors, and other professional advisors.

(3)       Sale or other transfer of the company: We reserve the right to disclose information to facilitate the licensing, merger, sale, assignment, acquisition, financing, securitization, insuring, bankruptcy, or other transfer of our technology or business, or a portion thereof, to third parties, as permitted by applicable law. By agreeing to the terms of this Privacy Policy, you are consenting to this disclosure.

(4)       Market research: We also may provide information to market research companies or affiliates of Blaze Capital for the purpose of assessing information about our business or client base. We may provide our clients’ or prospective clients’ contact details to market research companies to undertake research on behalf of Blaze Capital. For example, we may run client satisfaction surveys or run focus groups on proposed products.

(5)       Direct sharing through third-party websites and services: The Websites may enable you to share information directly with websites or online services operated by third parties. If you choose to use these features, you may disclose information to users of those websites or services and the public more generally. These websites and services may also set and access a cookie on your device. Because these third-party websites and services are not operated by Blaze Capital, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of information through these websites and services will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy.

(6)       Offers and promotions: Blaze Capital may also share your Personal Information (excluding security photographs) with a sponsor or other third party that provides you with offers or promotions that may be of interest to you. If you choose to participate, we or third parties may request your name, address, telephone number, email address, and other information where it is necessary to ensure your eligibility and to comply with lottery and gaming regulations.

(7)       Aggregated information: Blaze Capital may share with other third parties information about the users of our Websites and the services provided on the Websites, but only on an unattributed and aggregate basis.

Advertisements

Blaze Capital, its designated service providers, third-party advertisers and their advertising servers may also place or recognize unique cookies on your computer or use other electronic tools in order to help display advertisements that you see on the Websites. Information about your visits to, and activity on, the Websites, an IP address, the number of times you have viewed an advertisement, and other such usage information is used, alone or in combination with other information, to display on your device screen advertisements that may be of particular interest to you. We may use web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits the Websites, and to learn which banner ads bring users to the Websites. Our third-party service providers and third-party advertisers will ensure that they handle your Personal Information in accordance with the requirements of PIPA and PIPEDA. Blaze Capital adheres to the industry’s Self-Regulatory Principles for Online Behavioral Advertising located here.

Consent

As a general principle, Blaze Capital will obtain your consent before collecting, processing, storing, using or disclosing your Personal Information for any purpose other than as identified in this Privacy Policy. Blaze Capital will make an exception only where legal, medical or security reasons make it impossible or impractical to obtain consent, as discussed further below. We will make reasonable efforts to ensure you understand how your Personal Information may be used or disclosed.

Blaze Capital may collect, use or disclose Personal Information without your knowledge or consent in the following limited circumstances:

·       when the collection, use or disclosure of Personal Information is permitted or required by law (including subpoenas, search warrants, court orders and government orders);

·       in an emergency that threatens an individual’s life, health or personal security;

·       when we require legal advice from a lawyer;

·       for the purposes of collecting a debt;

·       in connection with criminal justice, taxation or regulatory activities;

·       to protect ourselves from fraud or to protect the rights and property of Blaze Capital;

·       to investigate an anticipated breach of an agreement or a contravention of law; or

·       in the event of a reorganization, merger or sale of Blaze Capital.

Withdraw Consent and Opt-Out

We provide you with the ability to access, review, correct, delete, or inquire about information that we hold about you, as required and permitted under applicable law. You also may have a right to oppose or limit the collection and processing of your information as described in this Privacy Policy, or to revoke your consent, although we may be unable to provide services to you if you oppose this processing or if you revoke consent. While Blaze Capital will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws.

If you would like to access, review, correct, delete, or inquire about your information, place limitations on the collection or processing of your information, or revoke your consent, you may send us a request at the address or email provided in the Contact Us section below. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete. Please note that we may need to take additional steps, such as to verify your identity, before we can grant your request. As permitted by law, we will notify you of the basis for any denial of your request. Please note that (i) the opt-out process may take some time to complete, consistent with applicable law; and (ii) even after such opt-out process is completed, your Personal Information may continue to be shared with our affiliates (including affiliated websites under common ownership or control) and designated service providers.

To opt out of advertising cookies placed by participating companies in the Self-Regulatory Program for Online Behavioral Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here. To opt out of advertising cookies placed by the Network Advertising Initiative’s online behavioral advertising member networks, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here. To opt-out of advertising cookies for Your Online Choices if you are based in the EU, please click here.

DoubleClick for Publishers and other designated service providers assist Blaze Capital with advertisement display functions and related analytics for the Websites. To opt-out of Google Analytics for Display Advertising, including Demographics and Interest Reporting, please click here. To opt out of Facebook advertising on OTT devices, please click here.

Please note that Personal Information you have published on any chat room or forum, including any chat room or forum on the Websites, may remain publicly available even if you request that such Personal Information is internally deleted by Blaze Capital.

Accuracy, Security, and Retention of your Personal Information

Any Personal Information you provide to Blaze Capital is kept on secure servers. Blaze Capital uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures to: (a) safeguard Personal Information against loss, theft, unauthorized use, disclosure, or modification; and (b) ensure the integrity of the Personal Information. Please be aware that despite our best efforts, no data security measures can guarantee security all of the time. If you have online account access, we recommend that you take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user name and password private.

Blaze Capital retains Personal information for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements. After this time, any Personal Information you have provided to us will be securely destroyed, deleted or made anonymous. If we use Personal Information to make a decision that directly affects our clients, we will retain that Personal Information for at least one year after we make a decision so that they have a reasonable opportunity to request it.

Requests for Access to Personal Information

You have the right to access your Personal Information, subject to limited exceptions under applicable laws such as solicitor-client privilege, disclosure that would reveal Personal Information about another person, legal obligations and proprietary rights. Blaze Capital will assist you with your request. This includes:

  • identification of and access to any or all of your Personal Information under Blaze Capital’s custody or control;
  • an explanation of how that Personal Information is or has been collected, used or disclosed by Blaze Capital; and
  • the names of any individuals and organizations to which your Personal Information has been disclosed by Blaze Capital.

All requests should be made in writing and provide sufficient detail to identify the information being sought, and be directed to Blaze Capital. Blaze Capital may require further information defining the request more succinctly.

We will respond to written requests within 30 business days of receiving such a request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Blaze Capital cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you. Please note that our ability to grant you access and answer the above requests regarding Personal Information that has been disclosed on certain Websites operated by third parties is limited. 

A minimal fee may be charged for providing access to Personal Information, where permitted under applicable law. Where a fee applies, we will inform you of the cost and request further directions from you on whether or not we should proceed with your request.

Transfer of your Personal Information to other Countries

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your Personal Information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in the United States. As a result, the Personal Information and Other Information that we collect through or in connection with the Websites may be transferred to and processed in other countries for the purposes described above, pursuant to methods permitted by PIPA and PIPEDA for ensuring that information about you will be adequately protected. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. Further, Personal Information might be disclosed to governments or law enforcement agencies in these countries where required by law.

Third-Party Websites

The Websites may contain links to and embedded videos from third-party websites, including social networking websites, which are not owned or controlled by Blaze Capital. In addition, the Blaze Capital Services may utilize third-party websites such as youtube.com/blazecapital to collect Personal Information. By visiting third-party websites through the Blaze Capital Services, you agree to be bound by the terms of services and privacy policy of such third party. Blaze Capital has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third-party websites. In addition, Blaze Capital may not be able to censor or edit the content, or remove or correct your Personal Information that is posted on such third-party websites. By visiting these third-party websites in connection with the Blaze Capital Services, you expressly release and hold Blaze Capital harmless from any and all liability arising from your use of such third-party websites. We encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Ability to Accept this Privacy Policy

The Websites are not directed to people under the age of 18, and Blaze Capital does not collect information from anyone it knows is under the age of 18. By using the Websites and the Blaze Capital Services, you represent that you are 18 years of age or older and have full power and authority to consent to the use of your Personal Information in accordance with this Privacy Policy, and doing so will not violate any other agreement to which you are a party.

Modifications to this Privacy Policy

Blaze Capital reserves the right to change this Privacy Policy at any time, in its sole direction and without prior notice, by posting revisions on this webpage, and you agree to be bound by such modifications or revisions. Such changes will be effective upon posting the revised Privacy Policy. If we make any material changes to this Privacy Policy, we will announce that these changes have been made on the home page of our Websites. However, it is your responsibility to review the most current version of our Privacy Policy.

Contact Us

If you have questions regarding this Privacy Policy, please contact us at  info @blazecapital.com or call us at 833-420-3330. Please include “Privacy” in the subject line of your inquiry. If you have complaints about Blaze Capital processing of your Personal Information, you may have the right to contact the applicable supervisory authority.

If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of British Columbia:

Office of the Information and Privacy Commissioner of British Columbia

4th Floor, 947 Fort Street,

Victoria BC V8V 3K3

Phone:            (250) 387-5629         

Toll Free:        Callers outside Victoria can contact the office toll-free by calling Enquiry BC requesting a transfer to (250) 387-5629

Email:             [email protected]         Website:         www.oipc.bc.ca