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Privacy Policy

 

Privacy Policy

At Snöball Event Marketing Inc. (“Snöball”, “us” or “we”), one of our main priorities is the privacy of our visitors, Clients and Users. This privacy policy (the “Privacy Policy”) describes how Snöball collects, uses, discloses, and stores your personal information when you are using and/or accessing our websites https://snoball.events and https: //snoball.it (the “Websites”), the application programming interface (the “API”) and our Services in which this Privacy Policy is posted, linked, or referenced. 

If you have questions or require more information or assistance about our Privacy Policy, do not hesitate to contact us. Please refer to the “Contact Us” section of this Privacy Policy. 

1. DEFINITIONS

“Client” means the customer identified in the Order Form;

“Event” means trade show, conference, meeting, etc., with a specific start date and end date;

“Order Form” means a Snöball order form, renewal notice, purchase order, subscription form or other similar purchase document, including in electronic format, agreed by Snöball and Client from time to time and incorporated by reference into the Terms and Conditions, pursuant to which Client subscribes to the Services;

“personal information” refers to any information that directly or indirectly, taken independently or in combination with other information, identifies an individual, or any information about an identifiable individual. In general, personal information does not include an individual’s business contact information, such as his/her name, his/her title or position, his/her business address, his/her business phone number or fax number;

“Services” means any influencer marketing solutions and services regarding an Event that Snöball agrees to perform regarding an Event in accordance with the Order Form, including the access to the platform, any related APIs provided by Snöball, together with all related application or information that Snöball makes available to Client; and

“User” means any individual who is authorized to access the Services by Client. Each User may access the Services only to the extent such Services are made available to Client. 

2. CONSENT

Subject to applicable law, the collection, use and disclosure of personal information is subject to the consent of any visitor, Client or User of our Websites, API and Services. The consent must be free, informed and given for specific purposes, for instance, the purposes set out in this Privacy Policy. At all times, express consent must be given by an individual if the personal information is considered sensitive. 

By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. If we wish to use or disclose your personal information other than as described in this Privacy Policy, we will obtain your express consent before doing so.

Snöball might, under the applicable law, be authorized to collect, use or disclose personal information without the prior consent of the concerned individual. For example, personal information may be disclosed without prior consent from the individual to an authority responsible, by law, of the prevention or detection of a crime or statutory offenses. 

Personal information might also be collected from a third party other than from the individual to whom it relates if the collection from this third party is necessary in order to ensure the accuracy of the information.

At any time, an individual may refuse to provide Snöball with any or all his/her personal information. As the collection of some personal information is required for the purposes of the Services offered by Snöball, the refusal to provide personal information may prevent Snöball from providing its Services to the individual.

3. TYPE OF PERSONAL INFORMATION COLLECTED

In the course of providing our Services or Websites, we may collect the following information from our visitors, Clients and/or Users:

Third-Party Information

When you use the Websites or Services, Snöball may collect information of third parties that you provide to us or authorize us to collect (“Third-Party Data”). It is your responsibility to obtain the necessary consent for the collection and use of Third-Party Data and for the disclosure of this data to us. In order to provide our Services to you, we may obtain personal information from other sources, including social media platforms and other third parties. 

Log data

When you visit our Websites, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. The purpose of the collection of this information is for analyzing trends, administering the site, tracking users’ movement on the Websites, and gathering demographic information.

Device data

We may also collect data about the device you’re using to access our Websites. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us. The purpose of the collection of this information is for analyzing trends, administering the site, tracking users’ movement on the Websites, and gathering demographic information.

Personal Information

We may ask for the following personal information from you:

  • Contact information, such as your first and last name and your email address;
  • Account information, such as usernames and passwords; 
  • Social media profiles; 
  • Profile picture; and
  • All other personal information provided to Snöball in connection with the Services provided to the visitor, Client and/or User. 

Subject to the provisions of the applicable law, Snöball undertakes not to collect personal information relating to an individual under the age of 14 without first obtaining the consent of the tutor or the person having parental authority.

4. LEGAL BASES FOR PROCESSING

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process personal information about you only where we have legal bases for doing so.

These legal bases depend on the Services you use and how you use them, meaning we collect and use your information only where:

  • it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our Services, and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
  • we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

5. COLLECTION OF INFORMATION

Snöball undertakes to collect your personal information solely for the purposes identified in this Privacy Policy. In particular, personal information may be collected in the following circumstances:

  • when an agreement between a Client and us for the provision of our Services is in effect;
  • when a Client or a User’s personal information is provided to us by a third party who has been authorized by the Client or User to share such information with us;
  • when a User logs into its profile;
  • when a User edits its profile;
  • when a User uploads content within Snöball’s API;
  • when a Client or a User uses our Services;
  • when an individual contacts Snöball to obtain information about the Services offered; and
  • when a Client provides its payment information. 

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

6. USE OF INFORMATION

We may collect, hold, use and disclose personal information for purposes identified at the time of the collection, which include, but are not limited to, the following:

  • to enable you to customize or personalize your experience of our Websites;
  • to enable you to access and use our Websites, associated applications and associated social media platforms;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our Websites, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our Services and information about third parties that we consider may be of interest to you; and
  • to comply with our legal obligations and resolve any disputes that we may have.

Subject to prior and express consent or as otherwise determined by applicable law, personal information can also be collected for any other purpose determined between the visitor, Client or User and Snöball. 

7. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES

Snöball will not use nor disclose your personal information other than for the purposes for which it was collected, except with your consent or as required by law. In particular, Snöball may disclose personal information to:

  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; 
  • our employees, contractors and/or related entities;
  • sponsors or promoters of any competition we run;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights. Snöball may also disclose your personal information to investigate the breach of an agreement, including the Terms and Conditions;
  • third parties to collect and process data; and
  • explore and/or undertake corporate opportunities, including a merger, acquisition, amalgamation, reorganization or sale of Snöball, including the due diligence process and the transfer of information through to the closing of any such transaction.

Snöball will never rent or sell your personal information or use this information to send you spam. Snöball is based in Quebec, Canada. As some of our services providers are located outside the country, your personal information may be disclosed to such third-party service provider and additional legislation and regulations may apply. For each third party to whom Snöball may disclose personal information, we ensure via contractual means that the security measures employed by these third parties comply with applicable legislation and are aligned with our way of collecting, using and disclosing your personal information. Personal information transmitted to third-party service providers is limited to that which is necessary for the performance of their services. In the event that a third-party service provider is located outside of Canada, the government, courts or agencies having authority may be entitled to obtain authorization to disclose your personal information under their laws and regulations.

When needed, Snöball undertakes to perform privacy impact assessments, as required by applicable law, upon the disclosure of personal information to a third party outside the province of Quebec, Canada. Such privacy impact assessments must consider, among other factors, the sensitivity of the personal information and the purposes for which it is used.

8. NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code Section 1789.3, California Clients or Users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.

For more details about the personal information we collect from you, please see Section 3. We collect this information for the business and commercial purposes described in Section 6. We share this information with the categories of third parties described in Section 7. We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories of specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and not to be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at rachel@snoball.events. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California laws, 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 must provide a valid power of attorney, the requesters’ valid government issued identification, and the authorized agent’s valid government issued identification.

9. NOTICE TO EUROPEAN USERS

The information provided in this notice applies only to individuals in the European Economic Area, Switzerland, and the United Kingdom (collectively, the “EU”) and “personal information” as used in this Privacy Policy is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (“GDPR”).

Sensitive Data. Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.

Legal Basis for Processing. We only use your personal information as permitted by law. We are required to inform you of the legal basis of our processing of your personal information, which are described in the table below. If you have any questions about the legal basis under which we process your personal information, contact us at rachel@snoball.events. 

Processing Purpose

Legal Basis

To provide our Services

Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request for the Services.

To communicate with you


To optimize our Services


For compliance, fraud prevention, and safety


For research and development

These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted by law).

To comply with law

We use your personal information to comply with applicable laws and our legal obligations.

With your consent

Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime by contacting us at rachel@snoball.events. 

Use for New Purposes. We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for a related purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

Your Rights. Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you service-related and non-marketing communications.
  • Access. Provide you with information about our processing of your personal information and give you access to your personal information;
  • Correct. Update or correct inaccuracies in your personal information;
  • Delete. Delete your personal information;
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice;
  • Restrict. Restrict the processing of your personal information; and
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to rachel@snoball.events. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at rachel@snoball.events or submit a complaint to the data protection regulator in your jurisdiction.

10. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

The personal information we collect is stored and processed in Canada, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the EU to countries outside the EU will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EU country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

11. TRANSPARENCY

Snöball strives to ensure that all personal information collected, used and disclosed for the ends declared in this Privacy Policy are accurate and up to date. If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details in the “Contact Us” section of this Privacy Policy. Snöball undertakes that any change to correct or rectify an incorrect personal information shall be made quickly, within reasonable delays. A request for rectification, for instance, in cases where personal information is erroneous or out of date, and a request for deletion of personal information may also be made by any visitor or user, free of charge.

Subject to applicable law, a visitor, Client or User may, upon request, access and obtain a copy of his/her personal information collected by Snöball. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party. A reasonable fee may be charged by Snöball in the case a copy of the personal information is requested. 

At any time, a visitor, Client or User may withdraw or restrict his/her consent to the collection, use and disclosure of their personal information. The withdrawal of consent may prevent Snöball, in whole or in part, from providing Services to a visitor, Client or User and may affect your use of our Websites. To withdraw your consent, to request access, rectification or erasure of your personal information, please refer to the “Contact Us” section of this Privacy Policy. 

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details in the “Contact Us” section or opt-out using the opt-out facilities provided in the communication.

12. CONTACT US

To ensure that the personal information we collect, use and disclose is protected, Snöball has appointed a person in charge of the protection of personal information (the “Privacy Officer”). The roles and responsibilities of the Privacy Officer include, among others:  

  • the approbation of Snöball’s Privacy Policy and practices; 
  • the participation to privacy impact assessments; 
  • the proposition and implementation of protective measures; 
  • the management of requests for access, rectification or erasure of personal information; and
  • the duty of assistance to any person with the above-mentioned requests or with a complaint.

For all questions with respect to this Privacy Policy, which include the report of a confidentiality incident, requests for access, rectification or erasure of personal information and complaints, or for assistance, we invite you to contact us at the following contact details:

Data Controller & Privacy Officer 

Rachel Stephan

Email: rachel@snoball.events

13. PRIVACY-RELATED COMPLAINTS

Any Client, User or visitor may address a complaint to Snöball if he or she is unsatisfied with Snöball’s handling or management of his/her personal information. For example, a complaint can be filed in the case where an individual, the plaintiff, had suffered a prejudice as a result of Snöball’s processing of his/her personal information.

Complaints are processed and treated by Snöball’s employees and Privacy Officer. As a complaint is received, the employee(s) targeted to proceed to the investigation or the Privacy Officer acknowledges it within a reasonable delay and begins the review process. During the investigation, all relevant information is collected and reviewed. Changes or solutions are then proposed to the plaintiff and performed, upon acceptance of the plaintiff, to correct the object of the complaint.

All complaints will be addressed and resolved by Snöball within ninety (90) days from the reception of the complaint. Upon reception of a complaint by an individual, an acknowledgment of receipt will be provided to you within ten (10) days from the reception of the complaint. As one of our main priorities is the privacy of our visitors, Clients and Users, Snöball undertakes to respond promptly to all complaints.

If you wish to address a privacy-related complaint, in order to facilitate the processing and the resolution of complaints, the following information may be included in your communication:

  • Your full name; 
  • A short description of the circumstances surrounding the complaint; and
  • A copy of the relevant documents, if any.

All complaints or questions regarding a potential complaint can be addressed to the Privacy Officer of Snöball, whose contact information can be found in the “Contact Us” section of this Privacy Policy. 

14. COOKIES

We use “cookies” to collect information about you and your activity across our Websites. A cookie is a small piece of data that our Websites stores on your computer, and accesses each time you visit, so we can understand how you use our Websites. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.

15. BUSINESS TRANSFERS

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this Privacy Policy.

16. THIRD PARTY PRIVACY POLICIES

Our Websites may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices. We are advising you to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

17. PRIVACY POLICY UPDATES

Snöball reserves the right to amend or modify, at its sole discretion, this Privacy Policy at any time in order to comply with applicable legislative provisions currently in force and with any relevant and upcoming legislative changes pertaining to the protection of personal information.

Upon significant modifications to the Privacy Policy, Snöball may send a notice to its Clients and Users informing them of such changes. Alternatively, the publication of the amended Privacy Policy shall constitute sufficient notice with respect to the amendments and modifications of this Privacy Policy.

18. KEEPING AND DESTRUCTION OF PERSONAL INFORMATION

The life cycle of personal information includes the following stages: collection, use, disclosure, keeping and destruction. 

Snöball is required to keep your personal information only as long as necessary for the fulfillment of the purposes for which it was collected. In accordance with applicable law, personal information may also be retained for a specific period of time for tax purposes. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

Snöball implements appropriate security safeguards to protect your personal information against loss and theft, as well as unauthorized access, disclosure, copying, use or modification. These measures must be applied when personal information is stored and kept, and must be proportional with the sensitivity of the personal information, its purpose and its quantity. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. The security measures currently in place at Snöball include the following: 

  • Restricted access to documents on digital media containing personal information on a strict need-to-know basis; and
  • Password protection.

It should be noted that when personal information is the subject of an access or rectification request or of a complaint, Snöball must retain the personal information for the duration of the process.

Subject to applicable law, personal information must be destroyed once the purposes for which it was collected have been fulfilled. Destruction methods such as formatting, rewriting and digital shredding may be used by Snöball to satisfy its obligations.

If you have any questions or need further clarification about how Snöball stores or destroys the personal information it collects, please contact us. Please refer to the “Contact Us” section of this Privacy Policy in order to do so.

19. PRIVACY INCIDENT

We will comply with laws applicable to us in respect of any data breach. Snöball keeps a registry of confidentiality incidents, which includes all incidents involving personal information in our possession. Snöball undertakes to inform you of any breach of our security procedures relating to your personal information if it is reasonable, in the circumstances, to believe that the incident could present risk of serious injury to you or your personal information.

20. COMPLIANCE WITH CANADA PRIVACY LAWS

This Privacy Policy and our practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) and Québec’s An Act Respecting the Protection of Personal Information in the Private Sector (R.S.Q. c. P-39.1) and any amendments thereof.