Your privacy is critically important to us. At SmallCapp Media, we take our obligations in relation to privacy very seriously. We comply with the following privacy principles in relation to your personal data:
Obtain and process information fairly.
Keep it only for one or more specified, explicit and lawful purposes.
Use and disclose it only in ways compatible with these purposes.
Keep it safe and secure.
Keep it accurate, complete and up-to-date.
Ensure that it is adequate, relevant and not excessive.
Retain it for no longer than is necessary for the purpose or purposes.
Give a copy of his/her personal data to that individual, on request.
Below is our privacy statement which incorporates these principles.
This is the privacy and cookies statement (the “Statement”) for including the mobile site, SmallCapp Media platform(s), applications and widgets associated with it, our products and our associated services (respectively, the Site and the Services). The Site is operated by GIMA Inc. (“SmallCApp Media”, “we”, “us” and “our”). For the purposes of the General Data Protection Regulation 2018, we are the data controller.
We are committed to protecting your privacy online. In this Statement we explain how we collect information, what we do with it and what controls you have. By using the Site, or by engaging with us in relation to our Services (including content creators who provide information in relation to content that they publish), you consent to the collection and use of your Personal Data in accordance with this Statement. Your “Personal Data” means any information relating to you in identified or identifiable form.
We reserve the right to change this Statement from time to time by changing it on the Site. This Statement was last updated on the date set out at the beginning of it.
The Statement describes the types of Personal Data we process, namely Personal Data of:
Our suppliers (including content creators and licensors);
Any visitors to our Site or otherwise in connection with our Services; and
Certain data subjects where the personal data we process is data that has been made publicly available by the data subject (e.g. through public posts on social media platforms) at the time of collection.
The Statement also describes how we use that Personal Data, the bases upon which we collect it and with whom we share it. We also describe the measures we take to protect the security of Personal Data and how you can contact us about our privacy practices. The Services we provide are for a general audience, are not targeted to children, and we do not knowingly collect Personal Data from people that are 16 years of age or younger.
2. Information we may collect from you and the basis for collection
We collect Personal Data in order to offer Services that you have requested, where we legitimately believe there is an interest on your part in such Services, and/or where we believe SmallCapp Media has a legitimate interest in doing so, on the following bases:
in order to perform activities based on your consent (to the extent it is required by applicable law);
for the purpose of compliance with a contract to which SmallCapp Media is a party; or
as is necessary to fulfil an identified legitimate interest of SmallCapp Media, having regard to the requirement to balance that interest against the rights and freedoms of any affected data subjects, including, but not limited to:
monitoring and improving our Services to our partners and potential partners; and
managing the relationships we have with our current suppliers, customers and partners.
We may collect and process the following information, including Personal Data, about you:
information (such as your name, email address, social media details, postal address and telephone number) that you provide by completing forms on the Site or otherwise in connection with the Services including if you register as a subscriber or contributor to any service, upload or submit any material via the Site, request any information, or enter into any competition or promotion we may sponsor;
in connection with an account sign-in facility, your log-in and password details;
details of any transactions made by you through the Services;
details of your use of our Site and/or our Services;
communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site, its content or the Services.
information from surveys that we may, from time to time, run on the Site or as part of the Services for research purposes, if you choose to respond to, or participate in, them. You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services;
to the extent that it is publicly available, information from public social media platforms such as your name and/or other online identifier, your email address, gender, location and relevant social media posts; and
in addition to the foregoing relating to publicly available information from social media platforms, we may add such Persona Data to a central relational database which may draw in data relating to individuals from different publicly facing social media platforms. For example, if we use content from a particular YouTube subscriber, that individual may be added to our central relational database and we may augment the relevant profile with information from other publicly available social media accounts that the individual might have (for example, their Twitter or Facebook accounts).
In respect of information gathered as a result of your use of our Site and or Services, your decision to use this Site and/or our Services and to provide that Personal Data, is voluntary. We indicate on our online forms, where applicable, what types of Personal Data are required, before you register to our Services and submit any Personal Data to us.
For more information about how and on what basis SmallCapp Media processes your personal data, please contact setting out your query in reasonable detail.
3. Information you provide about third parties
Where information you provide, including content you submit to us, contains Personal Data of others, we may ask you to provide us with the details of your relationship with those individuals. We will only use those details to provide a description of your content, for verification purposes, or otherwise pursuant to terms agreed with you. By providing this information to us, you agree to our use of such information for these purposes. When you upload content to our Site, you warrant that you have permission from those individuals to appear in that content and for us to use their Personal Data in accordance with our agreement with you. You must not provide us with the details of anyone from whom you do not have such permission. We reserve the right to identify you as the person who has guaranteed that such individuals have given this permission.
4. Information obtained by automated means through our Services
When you visit the Site or as part of our Services we may automatically collect additional information about you, such as the type of Internet browser you use, any website from which you have come to the Site and your IP address (the unique address which identifies your computer on the Internet) which is automatically recognised by our web server. This information is only used to assist us in providing an effective service on the Site and to collect broad demographic information for aggregate use.
SmallCapp Media makes use of a number of cookies in the provision of Our Services. For more information, please refer to our Cookie Notice.
6. Uses made of your information
We will use the information you provide to:
deliver you the Services and information offered through the Site or via the Services and which you request, including monitoring your use of the Site to assess your use preferences and/or to otherwise improve your user experience;
monitor your use of our Site, our products and our other Services in order to improve them;
administer your account with us;
audit the downloading of data from the Site;
improve the layout and/or content of the pages of the Site and customise them for users;
identify visitors to our Site;
carry out research on our users’ demographics and tracking of sales data;
fulfil contractual obligations to our clients, including where we are confident that the requesting client has itself established a legitimate interest in SmallCapp Media processing the relevant Personal Data on behalf of the client (and always subject to the terms and conditions of the relevant contract between SmallCapp Media and the requesting client);
process content, including Personal Data, that at the time of initial processing may or may not lead to an outreach to the data subject with a view to establishing legal relations and/or further processing said Personal Data on the basis of there being a legitimate interest or another other lawful bases to do so;
to provide our clients with aggregated data reports showing de-identified information regarding social media users’ expressed preferences and behaviours;
supplement your Personal Data and other information collected from you with additional information from publicly and commercially available sources, and/or information from Company affiliates and our business partners;
perform data analytics;
allow us and our partners to contact you directly to carry out verification or other checks (for example, regarding future uses) with respect to the content you provide to us; and
comply with and enforce applicable legal requirements, including without limitation court orders and regulations, relevant industry standards, contractual obligations and our policies.
Where required by applicable law, we obtain your consent to use your Personal Data. You have the right to withdraw your consent at any time. We may also use your Personal Data in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.
You can tell us not to contact you with information regarding our products and Services, either at the point such information is collected on the Site (by checking or un-checking (as directed) the relevant box), by discontinuing a particular Service or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by contacting us using the Contacting us details at the end of this Statement.
7. Information sharing
We may disclose aggregate statistics about visitors to the Site, those who engage with our Services, customers and sales in order to describe our Services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no Personal Data.
If you upload, grant clearance in respect of, sell, licence or otherwise provide content, including video content to SmallCapp Media or any other platform (in the case of the latter, such distribution shall always be limited to where there is a legal bases), when we distribute that content to our partners, or where you otherwise engage with our Services, we may disclose your Personal Data to our partners in order for them to independently verify the content you have published. This disclosure may include your name, Facebook, Twitter or other social media profile information and location and may also include other information you have provided to us, such as your email address and phone number and location of where the content was created. At the point at which you submit your content to us, you are required to acknowledge that this disclosure will be made and by continuing to upload your details you continue to agree to such disclosure.
We may also disclose your Personal Data to any of our affiliates, or to our agents or contractors who assist us in providing the Services we offer including those provided through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform services on our behalf or to comply with legal requirements.
We require our service providers to protect the confidentiality and security of Personal Data, and to ensure that Personal Data is processed only for the provision of services on our behalf and in compliance with applicable law. Service providers are not authorized to use or disclose Personal Data, except as necessary to perform services on our behalf or to comply with legal requirements.
We may further disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, and (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer Personal Data we have about you in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
We will provide links to third-party websites as part of the Services we provide on this Site. SmallCapp Media is not responsible for the content of external websites, or for their privacy policies.
8. Child safety
Protecting the safety of children when they use the Internet is very important to us. We do not knowingly collect information from minors without seeking parental or guardian consent. We recommend that children receive permission from their parent or guardian before gaining access to our Services or sending Personal Data to us or anyone else online. Where we become aware that content may have been uploaded by a minor, we will contact the uploader to seek further permissions before using the content further. If content provided by you contains children, you must seek parental or guardian consent to share the content with us. When you submit the content, you declare that you have such permissions.
9. External links
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
We place great importance on the security of the Personal Data associated with our users. We maintain administrative, technical and physical safeguards designed to protect the Personal Data we have about you against accidental, unlawful or unauthorized destruction, loss,alteration, access, disclosure or use. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data.
You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Site or Services whilst it is in transit over the Internet and any such submission is at your own risk. It is advisable to close your browser when you have finished your user session to help ensure others do not access your Personal Data if you use a shared computer or a computer in a public place.
11. Transfer and storage of your information
Information that you submit via the Site and/or the Services is sent to and stored on secure servers located in the United States and in the EEA.
12. Retention of personal data
We maintain administrative, technical and physical safeguards designed to protect the Personal Data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data.
We retain Personal Data for the period needed to fulfil the purposes for which Personal Data was collected and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.
13. Your rights and choices
You are entitled to require SmallCapp Media to uphold certain rights and choices that you have in connection with the Personal Data we obtain about you. You may contact SmallCapp Media to exercise these rights and choices, and to update your preferences as to how we communicate with you by contacting us as outlined below in the “Contacting Us” section, below.
Access: You may request to access your Personal Data that is processed or retained by SmallCapp Media. As provided under the General Data Protection Regulation 2018, on request, we will provide you with a copy of this information free of charge, subject to a fee not exceeding the permitted statutory maximum for repetitive or manifestly unfounded or excessive requests.
Rectification: You have the right to correct any errors in your Personal Data that is processed by SmallCapp Media .
Erasure: You are entitled to require SmallCapp Media to delete your personal data if our continued processing of that data is no longer justified. In particular, processing of your Personal Data may no longer be justified where:
The data are no longer needed for the original purpose for which we collected them
The lawful basis for processing is your consent and you wish to withdraw that consent;
You exercise your right to object, and SmallCapp Media has no overriding grounds for continuing the processing;
Erasure is necessary to comply with EU, Canadian or other law; or
The original processing of your Personal Data was unlawful.
Restriction: You have the right to restrict the processing of your Personal Data to a particular purpose, including where the accuracy of the Personal Data we hold is contested; where you request restriction instead of erasure and you are entitled to require erasure; or where SmallCAp Media no longer needs the Personal Data for its original purpose but it is still required to establish, exercise, or defend legal rights.
As mentioned above, you have a right to prevent the use of your Personal Data for direct marketing purposes. We will respond to your questions or complaints relating to the processing of your Personal Data. If you are not satisfied with our responses, you have the right to lodge a complaint with a supervisory authority.
14. Contacting us
The entity responsible for the collection and processing of Personal Data in connection with the Site and Services is GIMA inc., 386 Blvd Petit-Cap,Gaspe,Canada,G4X 4l2
Please submit any questions, concerns or comments you have about this privacy Statement or any requests concerning your personal data by email to info or write to us at:
FAO: General Counsel,
386 blvd petit-cap,Gaspé,Canada ,G4X 4l2
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective as of now.
What we collect
We may collect the following information:
name and job title.
contact information including email address.
demographic information such as postcode, preferences and interests.
other information relevant to customer surveys and/or offers.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
Internal record keeping.
We may use the information to improve our products and services.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
Whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes.
If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to us.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.