PRIVACY POLICY

Last Updated:  May 30, 2025

This Privacy Policy describes how Ray Jack Investments Inc. o/a Balsam Promotions (“Balsam Promotions”, “we”, “us”) collects, uses and discloses personal information of users (“you”) through our website www.balsampromotions.com (the “Website”), any webstore that we operate for our clients (the “Webstores”) and other interactions with you during the provision of other services we offer (the “Services“).

By accessing the Website, making a purchase on a Webstore with your own payment information, or providing your personal information to us, you acknowledge and agree to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Website, make purchases on the Webstores using your own information, or otherwise use any of our Services and do not provide us with your personal information.

This Privacy Policy forms part of our Terms and Conditions, which are incorporated herein by reference.

1. SCOPE

This Privacy Policy applies in relation to the provision of the Services and in particular to your use of, or engagement with either or both of the following:

a] the Website;

b] the Webstores; and

c] any other communications or interactions (whether over telephone, email, SMS message or otherwise) between you and us in connection with the provision of the Services.

“Personal information” refers to any information that can be used to, directly or indirectly, identify an individual. Information about a business or that is limited to business contact information collected and used to communicate for business purposes is generally not personal information and not covered by this Privacy Policy.

IMPORTANT: When you make purchases on a Webstore using funds that are designated for your use by a client of Balsam Promotions (for example, your employer), that client’s privacy policy applies to how your information is collected, used and disclosed by them in connection with the Webstore. In those cases, Balsam Promotions acts as a service provider to its clients who have Webstore contracts with Balsam Promotions and Balsam Promotions processes information according to its clients’ instructions. In those cases, Balsam Promotions does not access or use your personal information related to Webstore transactions for its own purposes.

However, in cases where you make a purchase on a Webstore and the purchase is not paid for by a Webstore client (for example, if you make a purchase in an amount that exceeds your designated maximum purchase amount assigned by your employer, and you enter your own credit card information to make the purchase), then Balsam Promotions does collect, use and disclose your personal information for the purpose of processing that transaction, as detailed in this Privacy Policy.

2. COLLECTION OF PERSONAL INFORMATION

Information You Provide to Us Directly

We may collect certain personal information that you provide when you use our Website, our online social pages, or our other Services, including when you participate in activities such as:

  • making a purchase on our Website,
  • creating an account on our Website,
  • purchasing our Webstore services,
  • making a purchase on a Webstore that is not paid for by a Webstore client (e.g. by using your own credit card),
  • participating in our contests, promotions or surveys,
  • contacting us with a question, comment or complaint,
  • engaging with us on social media, or
  • otherwise communicating with us.

The types of personal information that the we might collect from you include, without limitation:

  • information related to your use of the Website, including when you set up an account, such as your name, email address, phone number, and account username;
  • information provided by your employer if they are a Webstore client, such as your name, office location, employee number, and address;
  • information related to our Webstore services if you are a representative of a Webstore client, such as your company contact information and payment information;
  • information related to purchases that you make on the Website or a Webstore, such as your name, contact information and payment information; and
  • any additional information you provide to us, such as comments regarding medical conditions or other health information.

Information Automatically Collected

We also may receive and store certain information about you and your device(s) automatically when you access or use our Website. This information may include:

      • Technical Information – We may collect technical information associated with your activity on the Website including information related to your browser and operating system, IP address (the Internet address of your computer) unique device identifiers, and other information such as your device type. We use such information for diagnostic and statistical purposes and to administer the Website and Services provided through the Website.
      • Usage Information – We may collect information to better understand customer traffic patterns usage of the Website. This may include the webpage that you were visiting before accessing the Website, the pages or features of the Website that you browsed, to inform us which part of the Website you visit and how much time you spend there. This information is used to analyze and improve the Website and to provide our customers with a better user experience.
      • User Preferences – We collect information about your preferences to make your use of the Website more productive through the use of cookies.

For more information regarding our use of cookies, please see the Cookies section below.

3. Use and disclosure of personal information

We will never sell your information to anyone. We may use or disclose your personal information to:

  • operate and administer the Website and Webstores,
  • deliver the Services,
  • process payments for purchases,
  • create and maintain your Website account,
  • contact you to respond to an inquiry,
  • send promotional communications,
  • contact you regarding policy changes,
  • enforce this Privacy Policy and our Terms and Conditions,
  • maintain security and regulatory requirements, and
  • for any other purpose for which you provide it to us.

We may send your personal information to our affiliates and service providers, to help us provide the Services to you and to help us complete the above-noted purposes/tasks. All such third parties are made aware of the confidential nature of your personal information. Your personal information will be shared with service providers on a “need to know” basis only and we limit the information shared to what is needed for the specific task being performed or fulfilled. Your personal information may also be disclosed to government agencies as required by applicable law.

We may also share your information with third parties where required to protect and defend our legal rights, protect the safety and security of other users of the Website or Webstores, prevent fraud, and to comply with applicable laws.

In the event of sale, transfer, merger, reorganization, dissolution, or similar event, we may transfer your information to one or more third parties as part of that transaction, including during the negotiation of an actual or contemplated transaction, but we only provide as much information as is needed for the purposes of the transaction. If we sell our organization or merge with another party, you hereby consent to the transfer of your personal information and all information you provide to us, to our successor for the same purposes as set out in this Privacy Policy.

Where applicable, you may opt out of having your personal information used or disclosed for a specific purpose at any time by emailing our Privacy Officer, at the contact details provided at the end of this Privacy Policy.

4. Cookies, Beacons, and Other Technologies

We may use cookies, web beacons and other similar technologies to collect information and personalize your experience with the Website.

Cookies are small web files that a website transfers to your device’s hard drive through your web browser that enables the Website’s system to recognize your browser and remember certain information. You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of the Website. For more information on cookies and how to disable cookies visit https://youradchoices.ca/en/tools.

We may also use cookies or third-party analytics providers to compile aggregate data about site traffic and site interaction and to collect information about your computer and internet connection, including your IP address, operating system, and browser type. The information collected through these cookies is used to better understand your interactions with the Website and to improve our services and content. Third party vendors may also use cookies to serve you ads based on your visit to the Website or other websites.

Our Website may also use a technology called “tracer tags” or “web beacons”. This technology allows us to understand which pages you visit on our Website. These are small graphics with a unique identifier that may be included on the webpages to deliver or communicate with cookies, in order to track and measure the performance of the Website and related services, monitor how many web visitors use the Website, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or in an email). These tracer tags are used to help us optimize and tailor our Website for you and other future visitors to our Website.

5. SAFEGUARDS and RETENTION

We take reasonable physical, technological and organizational precautions to prevent the loss, misuse, or modification of personal information under our control. The nature of these security measures varies by the sensitivity, quantity, distribution and format of the personal information collected, as well as by the storage methods used.

The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Passwords registered with our Website are encrypted to ensure protection against unauthorized access to your personal information.

Unfortunately, the transmission of personal information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, the Webstores or over any public network. Any transmission of personal information is at your own risk. Without prejudice to any mandatory legal obligations to which we may be subject, we are not responsible for circumvention of any privacy settings or security measures on our Website or Webstores.

6. RETENTION AND STORAGE

Please note that your personal information may be accessed, transferred, disclosed, stored and processed in Canada and any other country where Balsam Promotions, its affiliates, its service providers, and its agents are located or where their cloud computing infrastructures may be hosted. While your information is located outside Canada, it will be subject to local law, which may be less protective of your data than Canadian laws, and under the jurisdiction of local law enforcement.

Balsam Promotions retains your personal information for only as long as needed to fulfill the purposes for which it was collected, or for as long as necessary to comply with applicable laws, whichever is longer. Personal information that is no longer required is destroyed, erased or anonymized. Your consent to Balsam Promotions’ collection, use and disclosure of your personal information for such purposes remains valid after the termination of Balsam Promotions’ relationship with you.

7. THIRD PARTY LINKS

The Website or Webstores may contain links to other websites operated by third parties. Please note that this Privacy Policy applies only to the personal information that we collect or receive from third parties with your consent and we cannot be responsible for personal information that third parties may collect, disclose, store and use, including through their websites. You should always read the privacy policy of each website you visit carefully.

In addition, when you provide information to us through a third-party website or platform, the information may also be collected by the third-party website and may be subject to their privacy policy.

8. CHILDREN’S PRIVACY

Our Services are not intended for children under 13 years old. We do not knowingly collect personal information from children under 13 without parental consent.

If you are under 13, do not use or provide any personal information on our Services.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that personal data. If you believe we might have any personal information from or about a child under 13, please contact us at hr@balsampromotions.com

9. ACCESS, DELETION AND CORRECTION

You may send us an email at accounting@balsampromotions.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may also need to retain certain information for billing or other purposes identified at the time of collection of the information, or as otherwise required by law.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed or made your personal information anonymous in accordance with our record retention obligations and practices.

10. ANTI-SPAM

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages, which may include email or SMS text messages. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message or by contacting us at info@balsampromotions.com

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

11. WITHDRAWING CONSENT

We will collect, use and disclose your information only when we have your consent, which may be express or implied in certain circumstances, or as otherwise permitted or required under applicable law. You may withdraw your consent at any time, subject to applicable legal or contractual restrictions and reasonable notice to us. Please note that withdrawing your consent may limit our ability to provide our Services to you if such Services require processing your personal information. To withdraw your consent, if applicable, please contact our Privacy Officer using the information below.

12. POLICY CHANGES

We may update this Privacy Policy from time to time for any reason whatsoever. We encourage you to periodically review this Privacy Policy in order to stay informed of how Balsam Promotions is protecting your personal information. Each time this Privacy Policy is amended, the “Last Updated” date at the beginning of the Privacy Policy will be revised. If we make any material or substantive changes in this Privacy Policy, we will notify you by posting a clear and conspicuous notice of these changes on the Website and, where applicable, the Webstores. You may be required to read and accept it to continue your use of the Website or Webstore or you may be deemed to accept the changes based on your continued use of the Services.

13. Contact – Privacy officer

Should you have any questions or comments regarding your personal information or this Privacy Policy, please contact our Privacy Officer:

Attention: Privacy Officer 

Email: hr@balsampromotions.com 

Mail: 1135 Ringwell Drive Newmarket, ON L3Y 8T8 

If you are not satisfied with our response to your query, you may also contact or make a complaint to the Office of the Privacy Commissioner of Canada at 1-800-282-1376, or the applicable provincial privacy commissioner, as appropriate.