last updated on June 12, 2018

Your privacy is critically important to us. At Carmanah Digital Creative Inc., we have a few fundamental principles. (i) We don't ask you for personal information unless we truly need it. (ii) We don't share your personal information with anyone except to comply with the law, develop our products, or protect our rights. (iii) We don't store personal information on our servers unless required for the ongoing operation of one of our services.

Below is our Privacy Policy, which incorporates these goals. If you have questions about deleting or correcting your personal data please contact us.

Carmanah Digital Creative Inc. ("Carmanah") operates several websites and applications, including carmanahdigital.com & Big 2 Poker!. It is Carmanah's policy to respect your privacy regarding any information we may collect while operating our products.

Website Visitors and Product Usage
Like most product businesses, Carmanah collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Carmanah's purpose in collecting non-personally identifying information is to better understand how Carmanah's customers use its websites and products. From time to time, Carmanah may release non-personally-identifying information in the aggregate, for example, by publishing a report on trends in the usage of its websites and products.

Gathering of Personally-Identifying Information
Certain users of Carmanah's products choose to interact in ways that require Carmanah to gather personally-identifying information. The amount and type of information that Carmanah gathers depends on the nature of the interaction. For example, within Big 2 Poker!, we allow for simple account creation using your Facebook account and permit the creation of custom avatars.

In each case, Carmanah collects such information only as is necessary or appropriate to fulfill the purpose of the user's interaction. Carmanah does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain activities.

All of the information that is collected by Carmanah will be handled in accordance with GDPR legislation.

Protection of Certain Personally-Identifying Information
Carmanah discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Carmanah's behalf or to provide Carmanah's services or products, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Carmanah's websites and products, you consent to the transfer of such information to them. Carmanah will not rent or sell potentially personally-identifying and non-personally-identifying information to anyone.

Other than to its employees, contractors and affiliated organizations, as described above, Carmanah discloses potentially personally-identifying and non-personally-identifying information only in response to a subpoena, court order or other governmental request, or when Carmanah believes in good faith that disclosure is reasonably necessary to protect the property or rights of Carmanah, third parties or the public at large.

If you are a registered user of a Carmanah website or product and have supplied your email address, Carmanah may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with Carmanah and our products. We primarily use our product blogs to communicate this type of information, so we expect to keep this type of email to a minimum.

If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Carmanah takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and non-personally-identifying information.

Use of Personal Information
We will not sell or lease your personal information to third parties unless we have your permission or are required by law to do so.

We would like to send you email marketing communication which may be of interest to you from time to time. If you have consented to marketing, you may opt out later.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on the unsubscribe link at the bottom of every email we send you.

Legal Grounds for Processing Personal Information
We rely on one or more of the following processing conditions: (i) our legitimate interests in the effective delivery of information and services to you; (ii) explicit consent that you have given; (iii) legal obligations.

Cookies
A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Carmanah uses cookies to help Carmanah identify and track visitors, their usage of the Carmanah websites, and their website access preferences. Carmanah visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Carmanah's websites, with the drawback that certain features of Carmanah's websites may not function properly without the aid of cookies.

Access to Data
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all your personal information, please follow the instructions at the end of this policy.

Retention of Personal Information
We will retain your personal information on our systems only for as long as we need to, for the success of Carmanah's products. We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information from our live systems. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request.

Carmanah will not delete personal data from logs or records necessary to the operation, development, or archives of Carmanah's products.

Rights in Relation to Your Information
You may have certain rights under data protection law in relation to the personal information we hold about you. In particular, you may have a right to: (i) request a copy of personal information we hold about you; (ii) ask that we update the personal information we hold about you, or independently correct such personal information that you think is incorrect or incomplete; (iii) ask that we delete personal information that we hold about you from live systems, or restrict the way in which we use such personal information (for information on deletion from archives, see the 'Retention of Personal Information' section); (iv) object to our processing of your personal information; and/or (v) withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights or understand if these rights apply to you, please follow the instructions at the end of this Privacy Policy.

Third Party Services
Carmanah's products relies on a number of third party services to function. Each of these companies fully complies with GDPR. This is a listing of these third parties. (i) We use Gamesparks to store player data from Big 2 Poker!. (ii) Cloudinary is used for handling Big 2 Poker! avatars.

Third Party Links
Our website or applications may contain links to other websites provided by third parties not under our control. When following a link and providing information to a third party website, please be aware that we are not responsible for the data provided to that third party. This Privacy Policy only applies to carmanahdigital.com & Carmanah's applications, so when you visit other websites, even when you click on a link made available from one of the aforementioned sources, you should read their own privacy policies.

Aggregated Statistics
Carmanah may collect statistics about the behavior of visitors to its websites or within applications. However, Carmanah does not disclose personally-identifying information other than as described in this Privacy Policy.

Business Transfers
If Carmanah, or substantially all of its assets, were acquired, or in the unlikely event that Carmanah goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Carmanah may continue to use your personal information as set forth in this policy.

Payment Information
Payment information, such as credit card and debit card details, are never handled directly by Carmanah. Our products are distributed exclusively through Apple's App Store. Carmanah never stores your payment details on its servers.

Privacy Policy Changes
Although most changes are likely to be minor, Carmanah may change its Privacy Policy from time to time, and in Carmanah's sole discretion. Carmanah encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this website and our products after any change in this Privacy Policy will constitute your acceptance of such change.

The Privacy Policy was last updated on June 12, 2018. The Privacy Policy is inspired by Automattic’s Privacy Policy, which is made available under a Creative Commons ShareAlike license.

Contact Us
Please contact us if you have any questions about our Privacy Policy or information we hold about you by emailing support@carmanahdigital.com.