Privacy Notice

Last Update: January 3, 2019

Sunrise Records Ltd. (“Sunrise”, “we”, or “us”) values and respects your privacy. This Privacy Notice describes our privacy practices associated with our loyalty program, Club Sunrise, and the  Club Sunrise Loyalty App (the “App”).

For more information on the manner in which we treat personal information, please refer to the Sunrise Records Privacy Policy.

TABLE OF CONTENTS



COLLECTION AND USE OF INFORMATION

In the course of providing the Club Sunrise loyalty program, we collect and use information for the purposes identified below.

  • Registration: In order to participate in the Club Sunrise loyalty program, you are required to create an account on our Website or App. To fully participate in Club Sunrise and earn and redeem stamps, you are also required to download, install and log-in to the Club Sunrise App. When you create an account, we collect your first and last name, email address, mobile phone number, and a password that you create. You can optionally provide your postal code. We use this information to create and administer your account and participation in the Club Sunrise loyalty program. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

  • Collecting Stamps: To earn stamps on your purchase, you are required to scan your receipt through the App and upload it to us. We collect information from the receipts, such as the store location, the date and time of the transaction, the ten-digit transaction number, the nine-digit operator ID, basic details of the product(s) purchased, and the total amount spent, in order to calculate the number of stamps you have earned, which you may then redeem in-store when your stamp card is full.

  • Location Information: If you consent, we collect your location information by accessing your device’s GPS coordinates so that we can provide you with location-based services, such as sending you location-based push notification when you are within a close radius of a Store (if you have consented as set out below) or showing you Stores nearby. You can opt-out of location tracking at any time by turning off your location services for the App in the settings of your mobile device.

  • Push Notifications: If you provide your consent to receive push notifications, we may display push notifications on your mobile device such as welcome messages, product features and promotional offers. If you also have enabled location services for the App, we will send you real-time push notifications when you are within a tight radius of a Store. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.

  • Subscribe to our Mailing List or Newsletter: When you create an account on the App, you may be provided with the option to sign-up to receive our email mailing list or newsletter (including Club Sunrise offers and promotions). If you sign-up, we collect your name and email address. If you no longer wish to receive these communications, you can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our newsletter by contacting us at the contact information under “Contact Us” below. Please note that you may continue to receive certain transactional or account-related communications from us.

    We may also use services provided by third-party platforms (such as social networking and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please contact us at privacy@sunriserecords.com.

  • App Usage Information & Analytics: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on our App, to monitor and improve our App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-app experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.


SHARING OF PERSONAL INFORMATION

We do not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.

  • Service Providers: Your personal information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as administering our surveys, hosting the Website, providing advertising services, and sending our marketing communications. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located in the US, Canada or other foreign jurisdictions.

  • Legal and Compliance: We and our Canadian, US and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

  • Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Sunrise Records or as part of a corporate reorganization or other change in corporate control.


SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

YOUR CHOICES

As indicated above, if you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.

If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.

You can opt-out of location tracking at any time by turning off your location services for the App in the settings of your mobile device.

ACCESS TO INFORMATION

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

UPDATES TO THE PRIVACY POLICY

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

CONTACT US

If you have any questions or comments about this privacy policy or the manner in which we or our service providers treat your personal information, or to request access to your personal information in our records, please contact us at privacy@sunriserecords.com.