Privacy Policy



      Last updated: September 8, 2020

      1. Overview

      1.1  SPV ENTERPRISES LTD. (the “Great White North Vaporizer Company”, “GWNVC” “we”, “us” and “our”) is committed to protecting the Personal Information, defined below, of our members, clients, contractors, employees, customers and other stakeholders (“Users”) during the course of the delivery of our email management services (the “Services”) to our customers. This privacy policy (the “Privacy Policy” or “Policy”) describes the Personal Information we collect from you when you work with us or use our services and website, why we collect it, and how we use it.

      1.2  If you have any questions regarding this Policy, please contact our support team at

      2. Personal Information

      2.1  The term “Personal Information” has the same meaning as set out in the Canadian Personal Information and Electronic Documents Act (PIPEDA), which means any information about an identifiable individual including contact information, name, address, phone number, email address, gender, date of birth, and any other data about yourself that you choose to provide electronically through our website or otherwise.

      2.2  We may use or disclose your Personal Information without your knowledge or further consent in limited circumstances where we are required to do so by law. In certain limited circumstances, we may be required to release your Personal Information in response to a court order, subpoena, search warrant, law or regulation. We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information they may receive.

      3. Consent to Collection of Personal Information

      3.1  By using this website, GWNVC’s services or by otherwise providing Personal Information to GWNVC, you agree to this Privacy Policy and that we may collect, use and disclose your Personal Information in accordance with it. You may withdraw your consent at any time in writing by contacting our support team at We will obtain your consent before collecting, using or disclosing your personal information for new purposes unrelated to the purposes described in this Privacy Policy.

      4. What Personal Information Do We Collect

      4.1  When you register with GWNVC, we will ask you for your name, email address, date of birth and phone number. We may also ask for other information such as your squad, age, gender and other demographic information. We may ask you for your payment information such as payment card details as well as other information that you can voluntarily add to your account profile, such as a photo.

      4.2  If you are an employee with GWNVC or provide consulting services to GWNVC, we will ask you for your contact information, including name, home address, telephone number and email address; criminal background checks; employment information, including a resume that might include educational and work history, referee information and interview notes, financial information, including invoicing details and Social Insurance Number or other required government issued identification.

      5. How Do We Collect Your Personal Information

      5.1  We collect information in the following ways:

      (a) When you register with us as a member or User;

      (b) Cookies and similar technologies, where you consent; and

      (c) Google Analytics.

      6. How Do We Use Your Personal Information

      6.1  We collect your Personal Information to operate, maintain, enhance and provide all features of GWNVC’s services, to authenticate you, to send you marketing communications, to respond to comments and questions, and to provide customer support to you. We use information collected from cookies and other technologies to improve your experience and the overall quality of our services and website.

      7. Who Can Access Your Personal Information

      7.1  Only our personnel, contracted individuals, service providers and trusted third-party applications have access to your Personal Information. These parties include hosting, back-up and other IT services providers, website analytics companies, providers of digital advertising services, providers of CRM, marketing and sales software solutions, billing and processing payments functions. We only provide such parties with the information that they need to perform the services we have hired them to provide.

      8. Disclosure of Your Personal Information Outside of GWNVC

      8.1  GWNVC may disclose your Personal Information to third party companies, organizations and individuals outside of GWNVC in the following circumstances:

      (a) where you have given your consent;

      (b) we may provide Personal Information to certain third party agents or service providers to process for us, in order to carry out the requested services or as necessary for otherwise lawfully processing Personal Information (e.g. processing payments from you);

      (c) where we are required to do so pursuant to any applicable law, regulation, legal process or enforceable governmental request;

      (d) for legal reasons, to exercise our legal rights or defence against legal claims or in connection with an emergency that warrants use or disclosure of the information; and

      (e) we will share Personal Information with companies, organisations or individuals outside of GWNVC if disclosure of the information is reasonably necessary for other reasons authorized by law.

      8.2  GWNVC shall not otherwise disclose Personal Information to third parties for commercial or other reasons, except as may be specifically required to comply with applicable laws or where you have provided your consent.

      9. How Is Your Personal Information Secured

      9.1  GWNVC is committed to protecting the confidentiality and security of all Personal Information against loss and unauthorized access, disclosure, modification or destruction, and therefore has security safeguards appropriate to the sensitivity level of the information in place.

      9.2  GWNVC will ensure that all employees and third party service providers with access to information of individuals shall be required, contractually, as a condition of employment or provision of services to respect the confidentiality of such information and that all employees and third party service providers are aware of the importance of maintaining the confidentiality of such information as part of training requirements.

      9.3  GWNVC takes precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the Web page. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment.

      10. Your Rights Respecting Your Personal Information

      10.1  Users may exercise certain rights regarding their Personal Information processed by GWNVC. In particular:

      (a) Users have the right to withdraw consent where they have previously given their consent to the collection, use, disclosure or other processing of their Personal Information. Users may withdraw their consent by contacting GWNVC support team at

      (b) Users are entitled, subject to certain legal restrictions, to access and review their Personal Information held by GWNVC. GWNVC will make the following information available upon request: the name or title, and the address of the person accountable for GWNVC’s policies and practices and to whom complaints or inquiries can be forwarded; the means of gaining access to Personal Information held by GWNVC; a general description of the type of Personal Information held by GWNVC, including a general account of its use; a copy of any information available explaining GWNVC’s policies, standards or codes; and what Personal Information is made available to related organisations.

      Please note, GWNVC reserves the right to refuse to provide access to Personal Information in circumstances during which GWNVC is permitted by law to refuse access, including where providing access would reveal Personal Information about a third party, if the release of the Personal Information could affect the security of an individual, or if the Personal Information is subject to privilege.

      Requests for access to Personal Information should be made to our support team at

      (c) Users have the right to request corrections to Personal Information. Accurate Personal Information is required for efficient and effective delivery of product and services. Individuals may contact our support team at to modify or correct any Personal Information. Corrections will be made within a reasonable timeframe.

      (d) Users have the right to object to the processing of their Personal Information in certain circumstances where Personal Information is being processed on a basis other than consent. In particular, Users can object to processing of their Personal Information for purposes of direct marketing at any time.

      (e) Users have the right, under certain circumstances, to restrict the collection, use, disclosure or other processing of their Personal Information, meaning Users can limit how GWNVC uses their Personal Information.

      (f) Users have the right, under certain circumstances, to obtain the erasure of their Personal Information from GWNVC.

      (g) Users have the right to receive their Personal Information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another Controller (as defined in GDPR) without any hindrance, under certain circumstances.

      (h) Users have the right to bring a claim before a competent data protection authority.

      10.2  Any requests to exercise User rights can be directed to GWNVC through the contact details provided in this Privacy Policy. These requests can be exercised free of charge and will be addressed by GWNVC as early as possible.

      11. Do We Transfer Personal Information Internationally

      11.1 If you are utilizing services or visiting GWNVC’s website(s) from outside of Canada please be aware that you may be sending information (including Personal Information) to Canada where our servers are located. That information may then be transferred within Canada or back out of Canada to other countries outside your country of residence, depending on the type of information and how it is stored by us. These countries may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, use and disclosure of your Personal Information will at all times continue to be governed by this Privacy Policy.

      12. How Long Do We Retain Your Personal Information

      12.1  We shall store your Personal Information for as long as required by the purpose for which it has been collected, used or disclosed.

      12.2  Personal Information which we no longer need to retain shall be destroyed, erased or made anonymous in a secure manner in accordance with GWNVC’s policies respecting the destruction of records. GWNVC shall use care in the disposal or destruction of information so as to prevent unauthorized parties from gaining access to the information. The right to access, the right to erasure, the right to rectification and the right to portability cannot be enforced after the information has been destroyed.

      13. Changes to This Privacy Policy

      13.1  We reserve the right, at our sole discretion, to modify this Privacy Policy or any portion thereof. Any changes will be effective from the time of publication of the new privacy policy. If we believe the changes are material, we will let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes. Your continued use of the Services after the changes have been implemented shall indicate your agreement with the terms of such revised privacy policy. Otherwise, and if the new privacy policy does not suit you, you must no longer use the Services.

      14. Contact Us

      14.1  If you have questions about our Privacy Policy or have a concern or complaint about privacy, confidentiality, or our information handling practices, please contact our support team at for more information.