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Dragonscale and its affiliates (defined below) respect privacy, and the security of your Information (“Information”) and business information (“Business Information”) (collectively, “Information”) is important to us.
We protect your Information by maintaining physical, organizational and technological safeguards appropriate to the sensitivity of your Information. Except as stated herein, Information may only be accessed by persons within our organization and other authorized third parties who require such access to provide you with the services indicated below.
This Privacy Policy describes how Starfoil Inc. o/a Dragonscale, a company federally incorporated in Canada and located at 300 Geary Ave, Suite #308, Toronto ON, M6H2C5, Canada, and our affiliates and subsidiaries (as applicable) (“we,” “us,” or “Dragonscale”), collects, uses, discloses and processes Information when you visit our Site, use our Services, make an Order or otherwise communicate with us in relation to the foregoing processes.
Data Controller (GDPR)
For the purposes of the General Data Protection Regulation (GDPR), Starfoil Inc. o/a Dragonscale, located at 300 Geary Ave, Suite #308, Toronto, ON M6H 2C5, Canada, is the data controller responsible for your personal information.
1. DEFINITIONS
Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).
“Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with Starfoil Inc.
2. INFORMATION WE COLLECT
2.1 Information needed to use the Site.
We collect Information about you when you use the Site or when you provide it to us through other means (such as when you contact us or create a User Account). Without this Information, we would be unable to provide you with all the services provided by the Site.
This information includes:
● Identification Information, Account, Profile Information. Such as your first name, last name, business registration documents, phone number, home address, office address, email address, password and security information, date of birth and some of which will depend on the Services you use.
● Identity Verification and Checks. If required by us or our Payment Processor, such as images of your government issued ID (as permitted by applicable laws), articles of incorporation, business number, occupation, employment information, your ID number or other verification information, previous addresses and licenses.
● Payment Information. Such as bank account or payment account information (such as a credit card number), security codes, void cheques, direct deposit forms from your bank, recordings of your communications with us, and your transaction history—provided that all payment data is stored by our Payment Processor and you should review its terms and privacy policies or contact the Payment Processor directly to respond to your questions.
● Other Information. Such as any other information that is necessary for our identified purposes set out below and that is collected hereunder or as permitted by law.
2.2 Information voluntarily provided to us.
You may choose to provide us with additional Information. This information may include:
● Additional Information. Such as preferred language or any other field that is not a required field when making an Order or during our information collection process or in the process of completing any form or survey on or in relation to the Site.
● Non-personal information. Such as any information that does not directly or indirectly reveal your identity or directly relate to an identified individual, including demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific feature or engaging in a specific activity.
● Other Information. Such as when you fill in a form, checkout an Order, engage with certain Services, add information to your billing profile, respond to surveys, participate in promotions, communicate with us, or share your experience with us.
2.3 Automatically Collected Information
When you use the Site, Payment Services, and the Dragonscale Services, we automatically collect Information that is sent to us by your web browser. We use this information to better understand how users use the Site, and to improve the Site to better meet your needs.
The amount of information sent to us by your web browser depends on the browser and the settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this. This information may include:
● Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings.
● Usage Information. Such as the pages or content you view, frequency of access, time spent using Services, search history, referring website, print orders history, invoicing and billing history, usage history, device type, and other actions on the Site.
● Log Data and Device Information. Such as details about how you’ve used the Site (including if you clicked on links to third party applications or vendors), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Site. We may collect this information even if you haven’t created a User Account or logged in.
● Cookies and Similar Technologies. Such as text files with small pieces of data, such as your username and password or as related to marketing and advertising by Dragonscale or our Third-Party Service Providers, that are used to identify your computer or mobile device as you access and use the Site. The Site uses “cookies” and other technologies to enhance your online experience, including personalizing the content that you see on the Site. Most web browsers can be set to disable the use of cookies. However, if you disable cookies, you may not be able to access certain features on the Site. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners. We do not intentionally store directly identifying personal information in cookies. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies.
● Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address associated with your use of Payment Services, banking email address, your address and other related transaction details.
Please note that while your browser may allow you to transmit a “do not track” signal, like many websites, our Site is not designed to respond to such signals. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/.
2.4 Information Collected From Third Parties.
We may collect Information from other sources, such as:
● Third-Party Services. If you use any Third-Party Services (as defined in the Terms) in connection with the Site, you direct such Third-Party Services to send us information such as your registration and profile information or payment information as controlled by that service or as authorized by you.
● Other Third-Parties. We also work closely with third parties (including, for example, print laboratories, sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, subject to your agreements with them.
● Background Information. To the extent permitted by applicable laws, with your consent where required and if required by our Payment Processor, we or our Payment Processor may obtain identity verification, fraud-prevention verification, or other verification. We or our Payment Processor may use this information, including your full name and date of birth, to obtain such reports.
● Additional Users. If you are referred to Dragonscale on behalf of another User or through a referral link, the User or third-party (as applicable) that referred you may be able to submit Information about you such as your name, age, home address, email address, phone number or other contact information.
● Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or other information to help detect fraud and safety issues from Third-Party Services and/or partners, and combine it with information we have about you. For example, we may receive identity check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Site, or about your experiences and interactions from our partners.
2.5 Minor Personal Information.
The Site and the Dragonscale Services are not intended for or directed to minors under the age of majority (as applicable based on the laws of your jurisdiction). We do not knowingly collect personal information directly from minors under the age of majority without parental consent. If we become aware that a minor under the age of majority has provided us with personal information, we will delete the information from our records. Please contact Dragonscale if you believe we have collected personal information from an individual under the age of majority. As of the effective date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under the applicable age of majority.
3. HOW WE USE YOUR INFORMATION
3.1 Provide, Improve, and Develop the Site. We use Information to:
● enable you to use the Site and Services,
● process Orders,
● make and receive payments,
● supply you with requested Services,
● approve Orders,
● monitor Services and usage of such Services,
● perform analytics, debug and conduct research,
● provide Services and respond to your inquiries,
● send you messages, updates, security alerts, and account notifications,
● verify identity and other information submitted by you or any third parties, for fraud detection and prevention,
● personalize and customize your experience based on your interactions with the Site and use of the Services, your usage history (as applicable), your shopping preferences, and other content you submit,
● improve our business,
● help develop new products and services,
● to carry out any other purposes that are disclosed to you and to which you consent, and
● enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use.
If you are an EEA resident, this is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.
3.2 Maintaining Security and Safety. We use the information to:
● detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
● conduct security investigations and risk assessments,
● verify or authenticate information provided by you,
● conduct checks against databases and other information sources,
● comply with our legal obligations, protect the health and well-being of our employees and members of the public,
● resolve disputes with or from Users,
● enforce our agreements with third parties,
● comply with law, respond to legal requests, prevent harm and protect our rights (see section 4.5),
● perform quality assurance checks,
● enforce our Terms and other policies, and
● in connection with the activities above, we may conduct profiling based on your interactions with us, your information and other content you submit to Dragonscale, and information obtained from third parties.
If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.
If you are located in the EEA, you have the right to object to profiling and processing for direct marketing purposes.
3.3 Advertising and Marketing. We may use Information to:
● with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preference,
● determine appropriate news, alerts and other products and services that may be of interest to you for marketing purposes,
● personalize, measure, and improve our advertising,
● administer promotional programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Dragonscale or its third-party partners,
● analyze characteristics and preferences to send you promotional messages, marketing, advertising and other information that we think might be of interest to you,
● conduct market analysis and generate marketing leads, and
● invite you to events and relevant opportunities.
If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR.
When sending you promotional emails, you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about Order that you have made.
3.4 Provide Payment services. Information is used to enable or authorize third parties to:
● provide Payment Services,
● detect and prevent money laundering, fraud, abuse, identity theft and security incidents.
● conduct security investigations, credit assessments and risk assessments,
● comply with legal obligations,
● enforce our Terms, and other payment policies, and
● improve the Payment Services.
4. SHARING, DISCLOSURE & RETENTION
4.1 Sharing With Third Parties.
We may share your information with third parties, such as when authorizing a third-party application or website to access your Information or participating in promotional activities by Dragonscale partners or third parties. Such third parties may include:
● Business partners, vendors, suppliers, and sub-contractors who perform services on our behalf (these companies are authorized to use your personal information only as necessary to provide these services to us);
● Analytics and search engine providers that assist us in the improvement and optimization of our Website;
● Marketing agencies that assist us with improving and optimizing our digital campaigns, email marketing, affiliate marketing and other promotional activities;
● Logistics partners that maintain our inventory and facilitate shipping, delivery and returns to Users in relation to Orders on the Site;
● Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you or providing Payment Services;
● Payment processors for the purpose of fulfilling relevant payment transactions; and
● When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
Where permissible with applicable law, we may use certain information about you, such as your email address, transaction data and credit data, de-identify it (where required by applicable law), and share it with social media platforms, to generate leads, drive traffic to Dragonscale or otherwise promote our products and services, and third-party resellers, to deliver data and products or access personal data and Collective Content.
4.2 Information You Publish in Profiles and other Public Information.
Certain information that you choose to make public on the Site, such as product reviews, comments, or other content you voluntarily submit for public display, may be visible to other users. We do not make your account contact details publicly visible.
4.3 Third-Party Services.
User personal information shared with us (such as names, addresses and contact details) may be shared with such third-party service providers as well, at Dragonscale’s sole discretion. These service providers may change over time.
We may share Information with affiliated and unaffiliated service providers to help us run our business, including service providers that help us: (i) verify your identity or authenticate your identification, (ii) check information against public databases, (iii) conduct identity checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Dragonscale Services through third-party platforms and software tools (such as data analytics, data security, communications and customer support), (vi) provide customer service, advertising, or payments services, or (vii) process, handle or assess potential, threatened or actual legal claims, insurance claims or similar claims. These providers have access to your personal information to perform these tasks.
Our use of third-party service providers or third-party links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as explicitly set out otherwise in the Terms.
4.4 Complying with Law.
We may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with a valid legal request or to respond to claims asserted against Dragonscale, (iii) to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) to enforce and administer our agreements with Users, or (v) to protect the rights, property or personal safety of Dragonscale, its employees, its Users, or members of the public. For example, if permitted due to the forgoing circumstances, User tax information may be shared with tax authorities or other governmental agencies.
Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Dragonscale, our Users, or expose Dragonscale to a claim of obstruction of justice.
For jurisdictions where Dragonscale facilitates the collection and remittance of Taxes where legally permissible according to applicable law, we may disclose information about transactions and Taxes to the applicable tax authority, such as names, addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) from Users, and contact information.
Some or all of the Information we collect may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from courts, law enforcement, governmental or public authorities, tax authorities or authorized third parties in those jurisdictions according to laws in those jurisdictions.
4.5 Retention of Information.
We retain Information that we collect only as long as necessary for the purposes for which it was collected or to meet legal requirements (see Section 6.3). We destroy Information when it is no longer needed.
4.6 Business Transfers.
If Dragonscale undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (i.e., due diligence). In this event, we will notify you before your Information is transferred and becomes subject to a different privacy policy.
4.7 Affiliates and Subsidiaries.
Certain personal data may be disclosed among various affiliated and subsidiary companies of Dragonscale for the purposes set out in this Privacy Policy and our Terms.
4.8 Testimonials.
With consent, we may display personal testimonials of satisfied customers on our site, along with other endorsements. If you wish to update or delete your testimonial, you can contact us at support@dragonscalesupplies.com.
5. OTHER IMPORTANT INFORMATION
5.1 Automated Data Processing.
Dragonscale may perform automated data processing of your personal information in the context of delivering certain Dragonscale services (such as Dragonscale’s reporting functionality). Where Dragonscale performs such processing, it does so on the basis of informed consent, performance of a contract, compliance with legal obligations, or legitimate interests, as applicable. All such data processing is subject to this Privacy Policy and, if you are entitled by applicable law to do so based on your jurisdiction, you may contact Dragonscale to obtain human intervention and/or contest any decision generated by any of Dragonscale’s automated processing.
5.2 Artificial Intelligence.
In delivering the Site and Dragonscale Services, Dragonscale may use personal information to develop, train, build and use statistical models, including artificial intelligence, to improve the Site, the Dragonscale Services and user experiences.
5.3 Analyzing your Communications.
We may review, scan, or analyze your communications with us for reasons outlined in Article 3 of this policy, including fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, enforcing our Terms of Service, and customer support purposes.
In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools.
5.4 Third-Party Partners & Integrations.
Parts of the Site may integrate with or link to third-party services, not owned or controlled by Dragonscale, such as Shopify, Google Pay, Apple Pay, PayPal and Shop. Use of these services is subject to the terms of service and privacy policies of those providers. Dragonscale does not own or control these third parties and when you interact with them you are providing your information to them, and thereby agree to the terms of service and privacy guidelines of such third parties.
6. YOUR RIGHTS
You can exercise any of the rights described in this section consistent with applicable law. Please note that we may ask you to verify your identity and request before taking further action on your request.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your full name, email address and phone number, before providing a substantive response to the request.
In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
6.1 Data Access and Corrections.
You can access and update some of your Information by contacting Dragonscale and submitting a request. You are responsible for keeping your Information up to date. You can request a correction to your Information if you believe it is inaccurate. If you have submitted Information and would like to have access to it, or if you would like to have it corrected, please contact us using the contact information provided below.
6.2 Data Erasure.
In certain jurisdictions, you can request that your Information be deleted, or you may withdraw consent at any time. Please note that if you withdraw consent or request the erasure of your Information:
● We may retain your Information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend you from using Site for fraud or safety reasons, we may retain information gathered from you to prevent you from using Site in the future.
● We may retain and use your Information to the extent necessary to comply with our legal obligations. For example, Dragonscale may keep information for tax, legal reporting and auditing obligations.
● Information you have shared with others (such as reviews, comments, and forum postings) may continue to be publicly visible on Dragonscale, even after your Dragonscale Account is cancelled, suspended or voluntarily deleted. Some copies of your Information (such as log records) may remain in our database.
● Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your Information may not be removed from our backup systems for a limited period of time.
To request deletion of your personal information, please contact us at support@dragonscalesupplies.com with the subject line “Data Deletion Request.”
6.3 Right of Portability.
You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
6.4 Processing and Withdrawal.
You may have the right to ask us to stop or restrict our processing of personal information. Where we rely on consent to process your personal information, you may have the right to withdraw this consent. Any such requests shall be made in writing using our contact information provided below.
6.5 Appeal.
You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
6.6 Right to Lodge a Complaint (EEA Users)
If you are located in the EEA, you have the right to lodge a complaint with your local data protection authority if you believe that your personal information has been processed unlawfully.
7. SECURITY
While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your Information against unauthorized access, loss, destruction, or alteration.
8. INTERNATIONAL USERS
Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
9. CHANGES TO THIS PRIVACY POLICY
Dragonscale reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Site. Changes to this Privacy Policy shall be effective upon posting, and you understand and agree that if you use the Site after the date on which the Privacy Policy has changed, Dragonscale will treat your access to or use of the Site as acceptance of the revised Privacy Policy. If you disagree with the revised Privacy Policy, you may terminate this Agreement in accordance with the Terms of Use. If you do not terminate this Agreement, your continued access to or use of the Site or Services will constitute acceptance of and be subject to the revised Privacy Policy.
10. CONTACT INFORMATION AND RESPONSIBLE ENTITIES
If you have any questions regarding this Privacy Policy or our handling of your Information, please contact us at support@dragonscalesupplies.com.