Effective: May 4, 2022
AscendFS, Inc., its affiliates, and wholly-owned subsidiaries (collectively referred to as “Ascend”, “we”, “us”, or “our”) is committed to respecting and protecting the accuracy, confidentiality and security of your personal information when visiting our website(s) or visiting Ascend-hosted client web pages that use our products or services (the “Website” or “Websites”). This Privacy Notice sets out our policies concerning the collection, use, disclosure and protection of personal information we receive from individuals using our Websites, or from customers using our products and services, as well as the types of cookies that Ascend uses on our Websites.
“Personal Information” means all information about an identifiable person who can be directly or indirectly identified by reference to the information. In some jurisdictions, the term “personal data” is used in local privacy laws rather than the term “Personal Information”. Ascend uses the terms “Personal Information” and “personal data” interchangeably.
“Service(s)” means Ascend’s product and service offerings, including, but not limited to, electronic raffles in venue using mobile selling devices and printers, online raffles, sweepstakes, and Ascend’s “Make Change” application.
This Privacy Notice is available to the public on our Websites, so that information about our policies and practices relating to the management of information is readily available to everyone.
Please read this Privacy Notice carefully to understand our policies and practices for collecting, processing, and storing Personal Information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice).
This Privacy Notice 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”), as Ascend is incorporated in the Province of Ontario and its corporate headquarters are located in Ontario, Canada.
However, Ascend also does business in other countries, and non-Canadians also use the Website and the Services. Many of these other countries have their own laws applicable to the protection of Personal Information, which may or may not conflict with or contain more restrictive legal obligations than PIPEDA (including, for example, the European Union’s General Data Protection Regulation, known as “GDPR”). It is Ascend’s intention to comply with the privacy legislation of each of these jurisdictions where such privacy legislation is applicable to Ascend. As such, this Privacy Notice outlines the minimum standards for Ascend’s treatment of personal information. Where applicable laws contain additional requirements, Ascend will ensure compliance with those laws if those laws apply to Ascend. Should there be an inconsistency between this Privacy Notice and applicable local privacy laws, this Privacy Notice will be interpreted to give effect to the local privacy laws and Ascend’s compliance therewith.
Ascend is responsible for Personal Information under its control, and will take all reasonable steps to handle such Personal Information fairly and to ensure compliance with applicable laws in relation to the processing of Personal Information.
In order to oversee overall compliance with this Privacy Notice and with applicable data protection laws, Ascend has designated a Privacy Officer (who is also Ascend’s Data Protection Officer for the purposes of the GDPR). Contact information for Ascend’s Privacy Officer can be found at the end of this Privacy Notice.
You are under no obligation to provide Personal Information to us. However, certain Personal Information is essential for the use and quality of your experience using the Website and/or the Services.
Donations made through Ascend’s “Make Change” application using the Services must be made by credit or debit card. Any credit card, bank account, and other financial information is provided directly to third-party payment processors and is not retained, handled or accessed by Ascend. If you sign up as a user for the Make Change application, you will need to submit your name, contact information, credit or debit card number, expiration date, and CVV number, and billing information. By using the Services, you grant our third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to the terms of those third-party providers’ respective privacy policies. We encourage you to review the terms of service and privacy policies of our third-party providers, as well as the Program Terms of the Make Change application, available here.
If you sign up as a user on Ascend’s “Make Change” application, Ascend will have access to all of the credit and debit card transactions that are made using the credit or debit card that is connected to your program account and the donation transactions that you make using the cards you have connected to the “Make Change” application. This information is stored by our third party providers and not by Ascend directly, Ascend will not have access to payment account number information.
Ascend collects, uses and discloses Personal Information for the following purposes:
Ascend’s legal basis for collecting, using and disclosing Personal Information will depend on the Personal Information concerned and the specific context in which we collect it, including:
Ascend also creates and collects "non-personal information" - information that is not associated with or linked to your personal information, including personal information that has been aggregated, de-identified or otherwise anonymized so that it no longer relates to an identifiable individual. We use this information for product and service improvement purposes.
Ascend may share Personal Information with our employees, contractors, consultants, affiliates, service providers, business partners and other parties who require such information to assist us with providing you with the Services:
The use, collection and disclosure of Personal Information may involve Ascend transferring Personal Information across borders. Where we transfer Personal Information from Canada to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take steps to ensure that your data is treated securely and in accordance with this Privacy Notice. For example, we use approved contractual clauses, intragroup agreements and other measures designed to ensure that the recipients of your Personal Information protect it.
Ascend may use and disclose aggregated and anonymous or de-identified information to third parties, including the general public. For example, we may analyse and publish reports on usage trends or statistics from across our global customer base for information or marketing purposes, but only after we have removed any identifying Personal Information. This type of aggregated and anonymous or de-identified data can help Ascend improve our products, Services and advertising, and it can be used by customers and the public to better understand trends in the industry.
Residents of California have additional rights. Click here to learn more.
California’s "Shine the Light" law provides that California residents who provide Personal Information to us are entitled to request and obtain from us, once per calendar year, information about the Personal Information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the type of Personal Information and the names and addresses of those businesses with which we shared Personal Information for the immediately prior calendar year.
To obtain this information sharing disclosure, please send an email message to email@example.com with "California Personal Information Request " in the subject line. We will reply with the requested information within 30 days.
Please be aware that not all Personal Information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
We use certain types of Cookies on the Website. "Cookies" are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and websites faster and easier.
The following describes the types of cookies that Ascend currently uses or may in the future use on our Website:
If you would prefer to opt out of cookies, it is possible to manage them by opting out on our Website homepage the first time you visit or changing the cookie settings on your device, in your browser settings. Existing cookies that have already been set can be deleted from your hard drive. You can also block some or all cookies. However, you should be aware that you might lose some features and functionality of our Website or Services if you do so. For more detailed information about cookies and how to manage and/or delete them, please visit http://www.aboutcookies.org or http://allaboutcookies.org.
Ascend’s Website contains links to third party sites, including the websites of our partners, and we recommend and encourage you to read the privacy policies posted on those third party sites. Ascend is not responsible for and has no control over information that is submitted to, or collected by, these sites.
Ascend will retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, or to comply with applicable legal, tax or regulatory requirements Ascend retains your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice or such longer retention period as may be required or permitted by applicable law.. After this time, any Personal Information you have provided to us will be deleted or made anonymous.
Please note that we may be required in certain circumstances to retain your Personal Information indefinitely (for example, in order to comply with our policies and procedures in connection with self-exclusion). We will take all necessary steps to ensure that the privacy of your Personal Information is maintained for the period of retention.
You have a number of rights with regard to your Personal Information, which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
Any request to exercise your rights with respect to your Personal Information must be made in writing (by mail or e-mail) to Ascend’s Privacy Officer and provide sufficient detail to identify the Personal Information and the action being sought.
We will respond to written requests within thirty (30) days of receiving such 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 fulfil the request. We reserve the right to confirm your identity to process your requests to exercise your rights as listed above. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you may still have to provide valid government-issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
If Ascend cannot fulfil your request in full or in part, you will be provided with a response in writing that explains the reason for refusal and the further options available to you.
Nevada law permits our Nevada consumers to request that their personal information not be sold (as defined under applicable Nevada law), even if their Personal Information is not currently being sold. Requests are free of charge and may be sent to firstname.lastname@example.org with "Nevada Personal Information Request " in the subject line. We will reply with the requested information within 30 days.
Ascend will make reasonable security arrangements and use appropriate technical and organizational measures to protect all Personal Information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Ascend as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the Personal Information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Ascend’s security safeguards include locked filing cabinets, physically secured offices where Personal Information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures. Accordingly, we assume no liability for any disclosure of data due to unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.
Ascend will use appropriate security measures when disposing of and destroying Personal Information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.
Ascend will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.
This section applies specifically to Ascend customers residing or carrying on business in the European Union or European Economic Area, where the GDPR (or local legislation implementing the GDPR) applies.
For the purposes of GDPR, Ascend will be the “Processor” and our customers will be the “Controller” (as these terms are defined in the GDPR) with respect to any Personal Information that Ascend processes on behalf of our customers through use of the Services. Ascend will comply with its obligations as Controller under the GDPR with respect to personal information processed by Ascend on its own behalf.
The Website and Services are not intended for use by minors. Ascend does not knowingly collect Personal Information about minors. If you believe that we have mistakenly or unintentionally collected a minor’s Personal Information, please contact Ascend’s Privacy Officer.
It is our policy to post any changes we make to the Privacy Notice on this page with a notice that the Privacy Notice has been updated on the Website home page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page. We include the date the Privacy Notice was last revised at the top of the page. You are responsible for periodically visiting our Website and this Privacy Notice to check for any changes. Your continued use of this Website after we make changes indicates that you accept and consent to those changes
Complaints, concerns or inquiries about Ascend’s data protection practices, including compliance with this Privacy Notice, should be made in writing (by mail or email) to:
1 Yonge Street, Suite 700
Toronto, ON M5E 1E5
Complaints, concerns or inquiries regarding this notice should be made in writing (by mail or email) to Ascend’s Privacy Officer. You also have the right to your local national data supervisory authority.
All complaints and inquiries will be investigated and responded to in accordance with this Privacy Notice and applicable laws. If the Ascend Privacy Officer is unable to address your concerns, the issue will be escalated in accordance with Ascend’s escalation policy.
By using our Websites, you will be deemed to have consented to the collection, use and disclosure of your Personal Information by Ascend in accordance with this Privacy Notice.