Effective date: September 5, 2023
Just For Laughs Group Inc. and its affiliates and related entities, including the not-for-profit organizations Festival Zoofest, Just For Laughs Festival and Just For Laughs Toronto, (collectively, "JFL", "we", "us" or "our") are committed to respecting the privacy of the individuals with whom we interact and to protecting their personal information. It is important to us to be transparent and to provide you with information about how we collect, use, communicate and protect your personal information. We also want you to be aware of your options and how you can exercise your rights with respect to the protection of your personal information.
1. Scope and Application
2. What is “personal information”?
In this Policy, "personal information" means any information about an individual that can be used to identify that individual, either alone or in combination with other information, such as name, contact information, date of birth, credit card number, etc. It may also include more technical information, such as IP address, Web browser settings and unique device identifier, but only when such information can be used to identify you as an individual. Information that is rendered anonymous and cannot be associated with an individual is not considered personal information if it is reasonable to foresee in the circumstances that this information no longer makes it possible, in an irreversible manner, to identify an individual whether directly or indirectly.
3. What categories of personal information do we collect and how do we collect it?
JFL only collects personal information that is necessary to provide you with our services, to respond to any other requests you may make and for the other purposes set out in the section How do we use your personal information? below. In particular, we may collect the following categories of personal information:
- Your identifiers, which may include your first and last name, date of birth, e-mail address, home address and telephone number. We may collect this information in a variety of situations, for example if you contact us about a service or product, create an account on our Site, make a purchase through the Site's ticketing service, apply for employment with JFL, including as a volunteer, or if you offer your professional services to us, or otherwise interact with us, including in connection with your role or duties as an artist representative or otherwise. We generally collect this information directly from you, but in some cases, we may receive it from third parties, such as through a representative or agent. When you provide us with someone else's personal information, you represent that you have obtained their consent and are authorized to provide that information to us.
- Billing and payment information, such as your credit or debit card information (credit card number, name on card, expiration date and card security code), your billing and shipping address, and your purchase history, when you make a purchase on our Site. We generally collect this information directly from you.
- Professional information, such as information about your work experience and education. We collect this information if you apply for a position with JFL or if you offer us your professional services, including through third-party recruitment platforms. We will collect the personal information contained in your application, such as your resume, cover letter, salary or fee preferences, and information generated in connection with your application, to evaluate your application and determine whether we will offer you a position or retain you for a contract. If your professional services are retained, as a contractor, we will collect and retain your contact information, as well as bank account information, tax identification numbers (including Social Insurance Number, CAVCO and ACTRA numbers), passport, visa or work permit information, and any additional information provided by you in an application. We may also collect personal information from third parties as part of a pre-employment background or reference check. We generally collect this information directly from you, but in some cases, we may receive it from third parties.
- Information related to online activity, including IP addresses, the sections consulted on our Site or language preferences. We generally collect this information when you visit our Site using cookies or similar technologies as described in the section Cookies and similar technologies below. We treat this information as personal information when it can be used to identify you.
- Social networking and social media information, when you interact with our content or through social media or other third-party platforms, these platforms may share certain information with us, such as name, gender, profile picture, "likes," interests, demographics, etc. This information is shared with us subject to the respective privacy policies of the social media platforms and is not governed by this Policy. You can control the information we receive by modifying your privacy options on each social media platform.
- Video images, such as images recorded by our surveillance cameras on our premises or at JFL Group shows and events.
- Any other information that you provide directly to us when you communicate with us, for example by clicking on "Contact Us" on the Site.
4. How do we use your personal information?
We may use your personal information for any of the purposes identified in this section. We may also use your personal information for other purposes, in which case we will seek your prior consent where required by law.
- To ensure the delivery of and payment for our services. For example, we may use personal information to process purchases you make using the Site's ticketing service.
- To manage your account. For example, we may use personal information to enable you to create an account so that you can purchase tickets on the Site and to provide you with information and documents relating to your account.
- To manage commercial activities. For example, we may use your personal information to improve our business strategies, book the professional services of artists, acquire rights, and fulfill our tax obligations.
- To manage our marketing activities. For example, we may use personal information to provide you with customized content and marketing based on your preferences.
- To communicate with you. For example, we may use personal information to communicate with you, to answer a question about our services, to provide customer support or to send you our newsletter, if applicable.
- To process job applications. For example, if you apply for a position with JFL, we may use your personal information to process and evaluate your application.
- To analyze customer data. For example, we may use personal information to analyze Site visitor behavior in order to improve the customer experience. This information is not provided to us in a format that personally identifies you and is collected through settings on visitors' devices or browsers.
- To manage our business and the Site. Generally, we may use your personal information in connection with any other purpose with respect to the management of the Site and JFL, which may be described to you at the time of collection of the information, or to detect fraud and other illegal activity.
- For other purposes permitted or required by law. For example, we may use the information we collect to protect the security of that information and our Site or to comply with a legal obligation, if necessary.
5. When do we share your personal information with other organizations?
We may share your personal information with the following categories of persons or with other persons where permitted or required by law. We may also disclose your personal information to other third parties, in which case we will ask for your prior consent.
- Our affiliated companies and organizations, when necessary and for the purposes detailed in this Policy or your separate agreement with JFL, as applicable.
- Our employees, when access to information is necessary to perform their duties.
- Our service providers, when such communication is necessary to carry out a mandate or contract entrusted to them. We hire service providers to, among other things, plan our business operations and run our company; participate in the development, production and operation of our shows and audiovisual productions; provide, operate and maintain our information technology systems and services, including the Site; to provide our services to you; to process ticket purchases and payment thereof; to manage applications for positions at JFL; to check a job applicant's criminal history; for data hosting; for archiving; and to detect and deter fraud or other illegal activities. We ensure that we obtain a written commitment from our service providers that they will only use your personal information to carry out their mandate and that they will take reasonable security measures to protect your personal information.
- Our business partners, we may share, with your prior consent, your personal information with third party business partners in connection with the production of our festivals and audiovisual productions or for marketing purposes, including targeted advertising. JFL has no control over, and is not responsible for, the information handling practices of these parties.
- With other persons, including: when we are required or permitted by law to disclose personal information; in the event of a sale or transfer of all or part of our business assets (for example, as a result of a merger, reorganization, liquidation or other business transaction), including negotiations relating to such transactions, and in accordance with applicable laws; when we determine that disclosure of specific information is necessary to respond to a request from a law enforcement or regulatory agency or other legal process, or a trade union; to enforce our policies, or to investigate, prevent and take action regarding illegal activities, including suspected fraud; to protect JFL's rights, property or safety; or when necessary to protect our affiliated entities or organizations, employees, customers or others.
6. Protection of the personal information of children
Our Site is intended for the general public and not for children under the age of 14. We do not knowingly collect personal information from children under the age of 14. If you are under 14 and do not have permission from a parent or legal guardian to visit the Site, you may not access the Site or use our services. If we discover that a child under the age of 14 has provided us with personal information, we will delete that information from our systems.
7. Third party websites
Links to other third-party websites are available while browsing the Site. However, we are not responsible for the content or practices employed by the organizations sponsoring these other websites. JFL is not responsible for the practices, policies, or actions of these third parties with respect to the protection of your personal information. We therefore recommend that you carefully read the privacy statement appearing on these websites so that you can make an informed decision as to whether you wish to use these third-party websites in light of their privacy practices.
8. What are your options around privacy?
When you provide us with personal information, we assume that you consent to the collection, use and disclosure of your information for the purposes identified at the time of collection, including those described in this Policy. In certain circumstances, we may seek your consent after collecting your personal information, particularly if JFL wishes to use or disclose your information for purposes not previously identified.
You may withdraw your consent at any time, except in limited circumstances, such as where certain legal or regulatory requirements apply or because of your contractual obligations to us. If you withdraw your consent, JFL may no longer be able to provide you with certain services, in which case you will be notified of the consequences of withdrawing your consent. To withdraw your consent, please contact our Privacy Officer using the contact information provided in the Contact Us section below.
You may also choose to unsubscribe from our e-mail lists or any subscriptions, by clicking on the "unsubscribe" link in any e-mail from us or by contacting us at the coordinates provided in the Contact Us section below. Please note that even if you have indicated your choice not to receive commercial e-mails from us, we may still communicate with you in connection with services you have ordered, in accordance with applicable laws. In addition, it may take up to ten (10) working days to register a change of preference across our systems.
9. How do we protect your personal information?
We implement appropriate measures and controls to protect your personal information. These measures include restricting physical access to our offices and files, restricting access to your personal information to only those employees or agents who need it to perform their duties, restricting unauthorized access, disclosure, use and mishandling of your personal information in our custody and control, storing archival documents with reliable third parties, off-site, in secure facilities, and using firewalls, passwords and file encryption for online activities.
We implement internal policies and practices to ensure the protection of your personal information, including:
- Designating a privacy officer responsible for ensuring compliance with applicable privacy laws;
- Implementing policies and procedures that define the roles and responsibilities of our employees throughout the personal information life cycle, limit access to personal information on a "need-to-know" basis, and govern the retention and destruction of personal information;
- Implementing a procedure for handling privacy complaints and inquiries, including any privacy incident involving personal information;
- If the information is collected or stored in electronic form, implementing technical security measures such as encryption, firewalls, anti-virus software and other similar measures;
- Implementing contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate safeguards and security standards. For example, we generally require our service providers to limit their use and retention of personal information to that which is necessary to provide their services, and to notify us in the event of any actual or suspected breach of confidentiality.
Our goal is to prevent unauthorized access, loss, misuse, sharing or modification of personal information in our possession. We also use these safeguards when we delete or destroy your personal information.
10. How long do we keep your personal information?
We retain your personal information only as long as is reasonably necessary for the fulfillment of the purposes for which it was collected, or as permitted or required by law. Once it is no longer needed or required, your personal information will be securely destroyed or anonymized in accordance with applicable laws.
11. Where is your personal information stored?
We try to ensure that your personal information is kept in Quebec or, when this is not possible, in Canada. However, information stored on our service providers' servers may be located outside Canada (notably in the United States) and may therefore be subject to the laws of those countries, including any laws permitting access by government authorities. Where applicable, subject to such foreign laws, we will use contractual measures to the best of our ability to maintain protections for your personal information that are at least equivalent to those that apply in Quebec.
12.Cookies and similar technologies
You can refuse certain cookies and manage your cookie preferences by activating the relevant settings in your browser software. Most browsers allow you to delete or stop accepting cookies from the website you are visiting. To do this, follow the instructions in your browser settings. However, if you do not accept cookies, you may not be able to use all the features of the Site or the Site may not function properly.
We use Google Analytics, which enables us to see information about user activity, including the pages they have visited, the source and the time they have spent on our Site. This information is de-identified and displayed as numbers, which means it cannot be used to identify the user. You can disable the use of Google Analytics by visiting the Google Analytics deactivation page.
13. Access, correction, withdrawal of consent and other personal information requests
Subject to any applicable legal restrictions, you have the right to access your personal information and request that it be corrected if it is inaccurate, incomplete or obsolete.
You may also withdraw your consent to the collection, use or disclosure of your personal information at any time, subject to legal or contractual restrictions. Withdrawal of your consent will not have retroactive effect and may affect your ability to access our services, offers and content.
You also have the right to obtain more information about JFL's handling of your personal information, including the categories of persons who have access to your personal information within our company and the retention period applicable to your information.
If you have any questions or concerns regarding your personal information, please contact us in writing using the contact details set out in the Contact Us section below.
14. Changes to this Policy
15. Contact Us
If you have any questions or complaints about how we handle your personal information, or wish to exercise your privacy rights, please contact JFL's Privacy Officer at [email protected].