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LUGITAL® POLICY
Last Revision – January 2010
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Return, Refund & Cancellation
Customer satisfaction is our top priority, as Lugital® is a services based company, we are
commited to deliver exactly what is states on each signed legal contract, web based service description
and any other oral or written mutual engagement.
If a customer level of satisfaction is getting lower, we commit to work as much as possible
to reach our commun objectives. If there is no way to reach those objectives, we can negotiate a
contract cancellation and if needed, perform an evaluation of what were delivered in the
original agreement in order to proceed with a partial or total refund of the invested capital.
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Commitment to Privacy and Security
Protecting your privacy is important to Lugital®. As part of our
commitment to privacy protection, we have implemented this Privacy Policy, which
explains our privacy practices, including those of our Websites. We may change this
Privacy Policy from time to time to better serve your needs. Notice of any changes
will be provided on our Websites and a copy of all amendments is on file at our
offices. You can be sure that our Privacy Policy satisfies all of the requirements
of applicable privacy law, including Canada’s Personal Information Protection and
Electronic Documents Act (“PIPED Act”).
For legal & security matter, Credit Card number and any other banking information will never be
stored on our hands. When a visitor submit those sensitives information, they will be
only used once for validation and authentification purpose. All personal and banking
information communication between internet browser client and our server are always secured using
an industry standard 128bits encrypted certificate issued by a recognized root certificate
provider.
This Privacy Policy governs the way we manage your Personal Information. If you
have any questions or concerns about your privacy, please contact us, using the
contact information at the end of this policy.
Whenever you provide us with Personal Information, whether in writing, over the
telephone, or online, you will be referred to this Privacy Policy. If you do not
agree with our Policy, please contact us at the address given at the end of this
Policy, we would be pleased to address your concerns.
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What is “Personal Information”?
“Personal Information” is information about you as an individual. Examples include
your name, mailing and e-mail addresses, age, birthday telephone number, picture
and voice recording. Your personal preferences, such as your favourite colour or
flavour of ice cream, could also qualify as Personal Information if connected with
other information that identifies you. This Privacy Policy describes the types of
Personal Information that we collect, how we collect it, why we collect it and what
we use it for.
“Non-identifiable Information” is information that cannot be associated with, or
traced back to, a specific person. Non-identifiable information includes: anonymous
aggregated information, information about your visits to our Websites which is not
linked to you, information about your computer’s operating system and web browser
software. Your computer and its operating systems, browsers, and memory contain
vast quantities of transaction data and records of your use of it. This Personal
Information could be gleaned from these systems by outsiders if you do not take
steps to protect your system. It is our policy not to associate this information
with customers, even though we verify some kinds of technical information to ensure
that our Websites are optimized to serve our customers.
When you interact with our Websites, we may use a browser feature, known as a “cookie”,
to verify non-identifiable information about visitors to our Websites and measure
visitor traffic patterns. We do this to maintain the best possible Websites. A cookie
is a small computer file. When you first visit our Websites, the Website manager
may have implemented a program that creates a small computer file stored on your
computer’s hard drive. We ensure that the minimum information required is placed
in the cookie only so that we can recognize returning Website visitors. The cookie
does not contain Personal Information and we will not combine information in the
cookie with Personal Information that would enable us to identify you individually.
On subsequent visits to the Website, our server communicates with your computer,
reads the cookie, recognizes and confirms that you are a returning visitor. Our
server uses this information to provide you with a “short cut” that facilitates
the quickest, most efficient and best possible Website experience.
Most browser softwares allow you to delete cookies. You should consult your Internet
service provider for information on how to delete cookies. This may interfere with
our ability to personalize your experience at our Websites and be recognized, or
may slow down performance.
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Collection and Use of Personal Information
We collect Personal Information in the following circumstances:
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When you become a member through this Website;
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When you enter a contest or other promotion through this Website;
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When you subscribe to our e-mail newsletter(s);
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When you respond to online questionnaires;
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When you participate in interactive online activities;
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When you shop online at our Websites; or
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When you contact us to make requests or comment on our services.
We take particular care in the collection of Personal Information from children
under the age of 13. We do not require Personal Information from children to obtain
access to, surf or view the content on any of the Websites of Lugital®.
However, certain Personal Information may be required for a child to participate
in one of our contests or promotions. In these circumstances, we may collect the
first and last name (or user name) of the child, the child’s e-mail address, home
address, birth date and gender, as well as the name, home address, e-mail address
and telephone number of the child’s parent or guardian.
We only collect the Personal Information from a child under the age of 13 that is
reasonably necessary for the purposes of verifying the child’s age, administering
the child’s participation in the contest or promotion and, if the child wins a prize,
contacting the child’s parent or guardian. We will not use, maintain or disclose
this Personal Information for any other purpose.
At the time of collection of any Personal Information, we generally recommend to
the child to print a copy of this Privacy Policy and give it to his or her parent
or guardian. The parent or guardian can contact us at any time to get more information
about our personal information practices or to remove the child’s Personal Information
from our records.
Lugital® strives to ensure that our Internet experiences for young people
are safe and fun, and we urge parents and guardians to take an active role and explore
where their children are roaming on the Internet.
This Website may include links to third party websites. These third parties have
separate and independent privacy policies. Any personal information you share with
these third parties through their websites will be administered under their privacy
policies. Lugital® has no control over third party privacy policies and
therefore has no responsibility or liability for the manner in which third parties
may collect, use or disclose and otherwise treat your personal information.
Further details regarding our collection and use of Personal Information is set
out below.
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Memberships
Many of our sites offer you the opportunity to become a member or belong
to a club, so that you can participate on a regular basis in games, bulletin boards,
contests and other activities offered on the site. We do collect Personal Information
when you join in accordance with the following principles:
- We collect only the information necessary for the activities offered; and
- Access to our activities is never conditional upon you providing more Personal Information
than is necessary for such activities.
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Contests
When you enter a contest, you may be required to provide the following Personal
Information: your name, address1 or province of residence, e-mail address, telephone
number 2 and, where an age eligibility requirement applies, your age range. This
Personal Information is collected solely for the purpose of identifying and communicating
with contest prizewinners. Personal Information from non-winners is destroyed, in
accordance with applicable legal requirements. When an affidavit of eligibility
and release is sent to the prizewinner’s parent or legal guardian, it must be signed
and returned before the prize can be awarded. If the release is not returned within
the specified time period, the winner forfeits the prize and an alternative winner
may be chosen.
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Newsletter Subscriptions
When you subscribe to our online newsletter(s), you are required to provide
the following mandatory Personal Information so that we can deliver the newsletter
to you electronically: your first name, e-mail address and your province of residence
(in the last case, for statistical purposes only). Subscribers (and their parents
or guardians, where applicable) can cancel a newsletter at any time by following
the “unsubscribe” instructions at the bottom of the newsletter or by using the information
at the end of this Privacy Policy. Personal Information is deleted from our database
immediately when a subscriber cancels its subscription.
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Online Questionnaires
From time to time, we may request your feedback on an activity, product or service
that we offer or provide or on content on our Websites. We ask for your name and
e-mail address when you are providing us with feedback so that we may reply to you,
but you always have the option of providing us the feedback without sharing this
information.
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Other Online Activities
When you visit our Websites and participate in other online activities, we may collect
information such as your name, nickname, age category, preferences, opinions, etc.
Whether or not you are required to join a club or become a member of the site to
participate in these activities we always comply with the principles stated in subsection
(a) above with respect to memberships or clubs.
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Online Shopping
You must be 18 years of age (or any other applicable minimum age in your province
of residence) or older to make an online purchase on our Websites. Our shopping
Websites collect only basic ordering information, including your name and shipping
address, telephone number and e-mail address, and credit card number. This is for
the sole purposes of processing and delivering products or services that you buy
online. We do not share this information outside Lugital®, except with
our approved agents, who help us to process your order. All of our approved agents
are required to provide a level of privacy protection comparable to that provided
in this policy and are not permitted to use your information for any other purpose,
such as to market to you.
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Contacting Customer Service
If you telephone, write or e-mail us to comment on one of our services
or Websites, we will retain the information for our records during a certain period
of time. Disclosure of your name and Personal Information is voluntary in this circumstance.
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Disclosure of Personal Information
We will not disclose your Personal Information unless required by law.
We must provide your Personal Information in response to a search warrant or other
legally valid enquiry or order, or to an investigative body in the case of a breach
of an agreement or contravention of law, or as otherwise required by law. We use
your Personal Information for internal purposes only. We do not sell, rent or trade
in Personal Information. We may transfer information to third parties who need such
Personal Information to provide services on behalf of Lugital®. Any such
service providers are contractually bound to maintain the confidentiality of such
transferred Personal Information and are prohibited from using the Personal Information
for any other purpose. Your consent to our use of Personal Information can be withdrawn
at any time by following the directions at the end of this policy. We will obtain
your consent before using your Personal Information for any purpose other than these
above. Once your Personal Information is no longer required for the purposes above,
it will be deleted.
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Security and Safeguards
We know how important privacy is to you. That is why we protect and safeguard your
Personal Information. Our security policies govern the protection of the information
on our information systems, the way we protect our Websites from malicious attack,
and the way in which we dispose of information no longer needed. We screen and train
our employees carefully to ensure that they will always have the
highest regard for you and your privacy, and we restrict access to your Personal
Information to only those with a need to know.
We make best efforts to keep our servers in a safe environment and protect our information
technology infrastructure from abuse. Security on the Internet is a continuously
evolving problem and we hire experts who keep up with the latest trends. If you
receive any electronic communication which purports to be from a member of Lugital®
that you have any questions or concerns about, please contact us. Spam,
improper use, and pirating of domain names and email addresses is a growing problem,
so we appreciate hearing about incidents in order that we may investigate them and
provide you the best customer service.
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Accessing Your Personal Information
You have the right to access, verify and amend Personal Information that we collect
about you. To keep your Personal Information current, you can amend inaccuracies
and make corrections by contacting us as described at the end of this Privacy Policy.
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Contact Us With Concerns, to Update Your Personal Information, to Opt Out or
To Complain
We have tried to anticipate and meet all of your expectations with respect to the
treatment of your Personal Information and the privacy of your online experience
with us. If you have any concerns or questions, please contact us at the address
below. This is the address to contact if you:
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Have questions or concerns about our treatment of your Personal Information;
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Wish to update or access your Personal Information;
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Want to withdraw your consent to the collection and use of your Personal Information,
or the information of your child if you are a parent or guardian; or
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Wish to cancel an on line newsletter subscription.
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