Privacy Policy

1. What is this Privacy Policy for?


We are RareCircles Inc ("MagicPace", “we”, “us”, “our”), a Canadian registered company. This privacy policy is for the personal information collected through MagicPace websites (“Websites”), or other MagicPace accounts, and the services offered through them (“Services”). This privacy policy sets out how MagicPace uses the personal information users who choose to access and use the Websites, or other accounts and Services (“Users”). “Personal Information” or “personal data” includes any personal information that identifies or could identify, or is associated with information that identifies or could identify, an individual. It does not include data which cannot be related to an identifiable person (anonymous data).

2. Choice


It is always a User’s choice whether or not to provide Personal Information. However, if a User chooses not to provide requested Personal Information, that User will not be able to use certain features of the Services. We set out in detail below the information that we collect about Users and Users’ use of our Services. MagicPace does not collect on its own behalf things like protected health information, financial information, date of birth, social security or other government-issued identification number, and other sensitive personal information.

3. The Information We Collect About Users


We may collect, use, store and transfer different kinds of personal data about Users which we have grouped together follows:

  • Identity Data includes first name, last name, or similar identifier.

  • Contact Data includes email address and telephone numbers.

  • Profile Data includes Users’ profile data saved through the Service.

  • Location data includes data about your geographic location while you use the Website or Services.

  • Technical Data includes internet protocol (IP) address, browser type and version, operating system and platform, device identifiers and pseudonymous unique identifiers.

  • Usage Data includes data about how Users use our Services, such as browsing actions within the portal, the buttons, controls, Users click on, pages of our portal that Users visit, the time spent on those pages, User’s search queries, the dates and times of User’s visits, and workplace usage.


We also collect, use and share Non-personalized data called “Service Data” such as statistical or demographic data for any purpose. Service Data may be derived from User’s Personal Information but is not considered personal information in law as this information does not directly or indirectly reveal User’s identity. For example, we may aggregate User’s Usage Data to calculate the percentage of users accessing a specific Website feature.


We do not collect any Special Categories of Personal Data about Users (this includes details about User’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about User’s health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

4. How Is User’s Personal Information Collected


We use different methods to collect data from and about Users including through:

  • Direct interactions. Users may give us User’s Identity, Contact and Profile Data by registering for or using the Services and completing fields within the Services 

  • Automated technologies or interactions. As Users interact with our Services, we may automatically collect Technical and Usage Data about User’s equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

  • Third parties or publicly available sources. We may receive Personal Information about Users from various third parties and public sources as set out below:

  • Technical Data from the third parties such as the following:

  1. analytics providers such as Google Analytics;

  2. search information providers such as Google.

5. Purposes for Which We Will Use User’s Personal Information


We have set out below, in a table format, a description of all the ways we plan to use Users’ Personal Information.

Purpose/Activity

Type of Data

To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

To register Users accounts on the Services

  1. Identity

  2. Contact

To manage our relationship with Users which will include Notifying Users about changes to our terms or Privacy Policy

  1. Identity

  2. Contact

To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity

  2. Contact

  3. Technical

  4. Location

To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services

  1. Technical

  2. Usage

To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

To improve our Services including:

  1. tracking email open rates, web page visits and form submissions)

  2. To inform MagicPace as to what content is effective

  3. To provide follower updates

  4. To personalize MagicPace’s Services

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

Purpose/Activity

Type of Data

To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

To register Users accounts on the Services

  1. Identity

  2. Contact

To manage our relationship with Users which will include Notifying Users about changes to our terms or Privacy Policy

  1. Identity

  2. Contact

To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity

  2. Contact

  3. Technical

  4. Location

To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services

  1. Technical

  2. Usage

To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

To improve our Services including:

  1. tracking email open rates, web page visits and form submissions)

  2. To inform MagicPace as to what content is effective

  3. To provide follower updates

  4. To personalize MagicPace’s Services

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

Purpose/Activity

Type of Data

To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

To register Users accounts on the Services

  1. Identity

  2. Contact

To manage our relationship with Users which will include Notifying Users about changes to our terms or Privacy Policy

  1. Identity

  2. Contact

To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity

  2. Contact

  3. Technical

  4. Location

To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services

  1. Technical

  2. Usage

To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

To improve our Services including:

  1. tracking email open rates, web page visits and form submissions)

  2. To inform MagicPace as to what content is effective

  3. To provide follower updates

  4. To personalize MagicPace’s Services

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

Purpose/Activity

Type of Data

To deliver the Services to Users (including by recognizing users across the devices they use, and providing, maintaining, tailoring and improving website and services)

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

To register Users accounts on the Services

  1. Identity

  2. Contact

To manage our relationship with Users which will include Notifying Users about changes to our terms or Privacy Policy

  1. Identity

  2. Contact

To administer and protect our business and this the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  1. Identity

  2. Contact

  3. Technical

  4. Location

To use data analytics to improve our Services, customer relationships and experiences and to personalize our Services

  1. Technical

  2. Usage

To make suggestions and recommendations to Users about Services that may be of interest to Users and to provide Users with information, products or services they request

  1. Identity

  2. Contact

  3. Technical

  4. Usage

  5. Profile

To improve our Services including:

  1. tracking email open rates, web page visits and form submissions)

  2. To inform MagicPace as to what content is effective

  3. To provide follower updates

  4. To personalize MagicPace’s Services

  1. Identity

  2. Contact

  3. Profile

  4. Usage

  5. Technical

  6. Location

6. Disclosures


We may disclose Personal Information that we collect, or Users provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates where they are providing Services.

  • To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MagicPace’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by MagicPace about our Website, and/or Users are among the assets transferred.

  • To fulfill the purpose for which Users provide it.

  • For any other purpose expressly disclosed by us when Users provide the information.

  • With User’s express consent to other uses not indicated in this Privacy Policy.


We may also disclose User’s Personal Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.

  • To enforce or ly our Terms of Service and other agreements, including for billing and collection purposes.

  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MagicPace, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Access


Upon request, MagicPace will provide Users with information about whether we hold any of User’s Personal Information. MagicPace enables Users with the ability to access and correct Personal Information we have collected. If Users have any concerns or suspect unauthorized activities associated with User’s account, please contact us at support@magicpace.com. We will respond to User’s request within a reasonable timeframe, and in any event within 30 days of receipt of request.


MagicPace acknowledges that Users have the right to access, update, revoke permission to process, or request the deletion of User’s Personal Information. Any such query can be directed to MagicPace’s Data Protection Officer at data@magicpace.com. If requested to remove data under either scenario, we will respond within a reasonable timeframe.

8. Security and Enforcement


The security of User’s Personal Information is important to us. We use security safeguards appropriate to the sensitivity of the information to ensure that User’s Personal Information is stored and maintained in a secure environment. MagicPace exercises managerial and technical safeguards designed to protect against the loss or unauthorized use or disclosure of Personal Information belonging to our Users. These safeguards include encryption, malware protection, logical and physical access controls, and detection of social engineering attacks.


MagicPace monitors and reviews security safeguards and takes corrective action whenever we discover deviations from our Privacy Policy.

9. Retention of Data


MagicPace will keep User’s Personal Information for as long as it remains necessary for the identified purposes set out below or as required by law, which may extend beyond the termination of our relationship with User. Users acknowledge and agree that if User request that User’s name be removed from our databases, it may not be possible to completely delete all User’s Personal Information due to legal constraints.

Data Type

Data Type

Data Type

Retention period

Retention period

Retention period

Reason

Reason

Reason

Identity, Contact and Profile data

Identity, Contact and Profile data

Identity, Contact and Profile data

Subscription term and 3 months after account termination

Subscription term and 3 months after account termination

Subscription term and 3 months after account termination

To provide the Services to you during the subscription term.

To provide the Services to you during the subscription term.

To provide the Services to you during the subscription term.

Technical and Usage data

Technical and Usage data

Technical and Usage data

3 years after account termination

3 years after account termination

3 years after account termination

To provide the Services to you during the subscription term and to protect against fraud.

To provide the Services to you during the subscription term and to protect against fraud.

To provide the Services to you during the subscription term and to protect against fraud.


10. Managing the Online Collection of Additional Data


As Users navigate through and interact with our Website, and Services, we may use automatic data collection technologies to collect certain information about User’s equipment, browsing actions and patterns, location, and workplace usage patterns, including:

  • Details of User’s visits to our Website or and other communication data and the resources that Users access and use on the Website, or account.

  • Information about User’s computer and Internet connection, including User’s IP address, operating system, and browser type.

  • We also may use these technologies to collect information about User’s online activities over time and across third-party websites or other online services (behavioral tracking).

  • When Users access and use the Website, or Services, we may automatically collect certain details of User’s access to and use of the Website, or Services, including traffic data, location data, and other communication data and the resources that Users access and use on or through the Website, or Services.

  • We may collect information about User’s mobile device and Internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.

  • Our Website and collects real-time information about the location of User’s device.


We and our third-party service providers may collect information about Users in a variety of ways. We and/or our third-party partners may employ various tracking technologies, such as cookies, web beacons and analytics software, that help us better manage content on our Services by informing us what content is effective.

11. Use of Cookies


The Website uses cookies to better the users experience while visiting the Website. Where licable the Website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer / device.


Cookies are small files saved to the User's computer’s hard drive that track, save and store information about the User's interactions and usage of the Website. This allows the Website, through its server, to provide the Users with a tailored experience within the Website.


Users are advised that if they wish to deny the use and saving of cookies from the Website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from the Website and its external serving vendors.


The Website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to Users computer’s hard drive in order to track and monitor engagement and usage of the Website, but will not store, save or collect Personal Information. 


Other cookies may be stored to your computer’s hard drive by external vendors when the Website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No Personal Information is stored, saved or collected.

12. Transfers and disclosures of Data


MagicPace’s headquarters in Canada is our primary location for business operations, but may process or transfer data in or to other jurisdictions in the course of providing the Services.


For example, regarding normal business operations, MagicPace may engage a third-party to support our data storage, data processing, billing, support services, information technology, or mailings on our behalf, which third party’s facilities may be located in another jurisdiction.


We may also disclose User’s Personal Information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect User’s safety, or the safety of others, investigate fraud, or respond to a government request.

13. Additional Privacy Protections for Minors


We join the industry in recognizing that children, including young teens, may not be able to make informed choices about Personal Information requested online. MagicPace does not solicit or knowingly collect Personal Information of those under the age of sixteen.

14. Changes to this Privacy Policy


MagicPace may make changes to this Privacy Policy from time to time for any reason. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes or changes in the way we use information, we will notify customers via e-mail or by posting an announcement on the Website and prior to the change becoming effective. Website and users are bound by any changes to the Privacy Policy after such changes have been posted.


In the event that MagicPace is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any Personal Information and give affected Users notice before Personal Information is transferred or becomes subject to a different privacy policy. Users will be notified via email and/or a prominent notice on our Website or of any change in ownership or uses of User’s information, as well as any choices Users may have regarding User’s information.

15. Personal information we collect automatically when you use our services


When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

16. Contact information


MagicPace Privacy Officer

MagicPace

ATTN: Nick D’Urbano (MagicPace)

RareCircles Inc

PO Box 39029, Montreal CP Saint-Alexandre, Quebec, Canada, H3B 0B2

Updated: May 14, 2024