Privacy Policy

/Privacy Policy
Privacy Policy2019-02-07T13:19:26-05:00

Privacy Policy

TOTAL ENTERTAINMENT HOLDINGS PRIVACY POLICY

Privacy Policy

This Privacy Policy is designed to help you to understand how Total Entertainment Holdings (“TEH”, “we”, “us” or “our”) collect, use and disclose the information you provide us when accessing or using the website, https://bmsanpedro.com (the “Site”). This Privacy Policy applies only to the specific webpages of the Site and to nothing else.

Changes to our Privacy Policy

We may change this Privacy Policy in our sole discretion at any time. Any revisions to this Privacy Policy will be posted on the home page of our Site. It is your obligation to periodically visit our Site to review any changes that may be made to this Privacy Policy. Your continued use of our Site constitutes your agreement to be bound by any such changes to this Privacy Policy. If you do not agree with this Privacy Policy, you are not authorized to use our Site and your sole recourse is to not use our Site.

Domicile and Hosting of the Site

The Site is hosted in Canada. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from Canadian law, please note that you are transferring your personal data to Canada and by providing your personal data you consent to that transfer and to our use of that information in accordance with this policy. When you provide personal data to use or our service providers or vendors, you consent to the processing of your data in Canada as the Site is operated in Canada. You acknowledge that the laws of Canada may treat your information in a manner that may be substantially different from, and less protective than, the treatment required under laws of other countries and jurisdictions. If you do not want your information transferred to Canada, you should not share your information with us, or make use of this Site. To the extent allowed by the law of the country in which you are located, you expressly waive any right you may have to require us to treat your identifying information in accordance with the laws of any country or jurisdiction other than Canada. However, the foregoing waiver may not be legally binding in some countries such as member states of the European Union. To the extent it is not legally binding in the country in which you are located, this foregoing waiver does not apply to you and is severed from the remaining policy, leaving the rest intact.

 

Age Restriction

We are committed to protecting children’s privacy in the interactive online world. This Site is not designed for or intentionally targeted at children 13 years of age or younger. We do not intentionally collect or maintain information about anyone under the age of 13.

 

Information We Collect

When you visit our Site, you may provide us with two types of information: personal information that you voluntarily disclose that is collected on an individual basis; and information collected automatically when you use our Site or the services available on our Site (collectively, the “Information”).

What is Personal Information?

Personal information is collected only when voluntarily offered and solely for purposes that are clearly identified on our Site. Personal Information means any information that is unique to you, such as your name, username, password, e-mail address, wallet address, credit card information, medical information, preferences, mailing address and other personal information you choose to provide, other information you voluntarily provide (e.g. comments) and information from third party sources (e.g. partners and public information).

By providing us with your personal information, you also consent for us to collect, hold, use and disclose your personal information in accordance with this Privacy Policy. In addition to providing the foregoing information, if you choose to correspond further with us through e-mail or through the “contact” section of our Site, we may retain, use and disclose the content of your messages together with your e-mail address and our responses.

What Information is Collected Automatically?

When you use our Site or services available on our Site, we automatically collect information from your devices. We collect the following information:

Server Log Information:  We collect server log information when you use our Site, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at our Site and the websites you visit just before and just after our Site.

Device Information: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, the web browser you use, and other device identifiers.

Telemetry Information: If you use any of our open source software, we may collect bandwidth upload and download speeds, the amount of free and used storage space on your device and other statistics about your device.

Usage Information: If you use our Site, we will collect metadata about the files you upload for storage and we will record instances in which you have used your private key to authenticate communications.

Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information when you interact with our Site, including cookies and web beacons. Cookies are small data files that are stored on your device when you visit a website, which enable us to collect information about your device identifiers, IP address, web browsers used to access the Site, engagements with advertisements and similar, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.

Lawful Basis for Processing

We only process personal information where we have a lawful basis for doing so, such as the following:

User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you complete one of our general enquiry forms, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer services.

Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.

Contractual necessity – This is where we have to process personal information to meet our contractual obligations. For example, if you are a print subscriber, we would need to process your delivery address to fulfil your subscription.

Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.

Use of Information

We will only use the Information for purposes of:

Providing, maintaining, delivering or improving our Site or the products or services provided through our Site;

Analyzing and tracking data to determine the usefulness or popularity of certain content and to better understand the online activity of our Site users;

Fulfilling our legal or regulatory requirements;

Providing you with the information or products or services that you have requested;

Answering your inquiry or responding to a communication from you;

Developing new products or services;

Sending you technical notices, support or administrative notifications;

Communicating with you about news, products, services, events and other information we think will be of interest to you;

Matching your Information with job vacancies to assist us in finding a position that is most suitable for you if you have contacted us about recruitment;

Monitoring and analyzing trends, usage and activities in connection with our Site;

Detecting, investigating and preventing fraudulent transactions or unauthorized or illegal activities;

Advertising;

Conducting Research and Analysis;

Protecting the rights and property of the TEH Parties (as defined below) and others;

Linking, connecting or combining Information we collect from or about you with other Information; and carrying out any other purpose or reason for which the Information was collected.

Aggregated and De-identified Information Held About You

Aggregated Information or De-Identified Information does not identify you individually; it helps us to analyze patterns among groups of people. We share Aggregated Information or De-Identified Information in several ways, for example:

For the same reasons as we share Personal Information;

With Business Partners to help develop and market programs, products or services and present targeted content (including Targeted Advertising);

With Business Partners to conduct analysis and research about customers, website and app users; or

With Third-Party Ad-Servers to place ads (including ads of our Business Partners) on various websites and apps, and to analyze the effectiveness of those ads.

Sharing of Information

We will only share Information about you in the following ways: (1) with your consent or at your instruction; (2) with our current or future parent companies, affiliates, subsidiaries and with other companies under common control or ownership with us or our offices internationally; (3) with third parties or service providers that perform work for us; (4) certain information you may choose to share may be displayed publicly, such as your username and any content you post when you use interactive areas of our Site like our online forums; (5) in connection with a merger or sale of our company assets, or if we do a financing or are involved in an acquisition or any other situation where information may be disclosed or transferred as one of our business assets; (6) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process; (7) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of any TEH Party or others; (8) Social media providers (where you have a login in via social media account) and (9) with third parties where aggregate Information is disclosed which cannot be reasonably be used to identify you.

How Long Do We Keep Your Information

We will keep your Personal Information only for as long as we need to deliver our products and services, unless we are required to keep it for longer periods because of law, regulation, litigation or regulatory investigations. When your Personal Information is no longer necessary for our business, legal or regulatory needs, we will take reasonable steps to securely destroy such information or permanently de-identify it. For more information about our retention periods for Personal Information, please contact us.

Social Sharing Features

Our Site may offer social sharing features, links to social media and other integrated tools. Your use of such features enables the sharing of information with your contacts or the public, depending on the settings you use with the entity that provides the social sharing feature or social media. Please visit the privacy policies of the entities that provide these features to obtain more information about the purpose and scope of data collection and the processing of such data by such entities.

Protection of Personal Information

We take reasonable steps to protect the security of the information communicated through our Site. However, no computer security system is entirely foolproof and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the data you submit to or receive from us through the Internet or for any unauthorized access or use of that information and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received or that it will not be altered before or after its transmission to us. You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns (collectively, the “TEH Parties”) liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided through our Site.

Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies (please refer to the help menu on your browser); however, switching off cookies may restrict your use of our Site.

You may also opt out of receiving promotional communications from us at any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information about your account (if any).

How Do We Keep Your Information Secure

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

When we receive certain types of sensitive information such as the financial information provided when placing an order using our automated shopping cart, visitors are automatically redirected to a secure server. Strict security measures are in place, on our website, with our credit card processing company, and in our physical facilities, to ensure that information we collect from you is not accessible to third parties, and that it is protected from loss, misuse, or alteration.

All payment information provided to the Site via the Internet is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. We also encrypt our entire Website and protect information by placing it on a secure portions of our Website that is only accessible by certain qualified employees. Unfortunately, however, no data transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee or warrant the security of such information.

Your Rights

Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. These rights include:

The right to object to direct marketing – your preferences, including in relation to direct marketing, can be found in your account;

The right to access the personal data that we process about you;

The right to request the deletion of your personal data;

The right to request a manual review of automated data handling about you;

The right to request the rectification of your personal data – you can manage some of this information in your account;

The Right to raise a complaint or objection with a regulatory authority;

You can exercise these rights through your account or by contacting customer services.

Hyperlinks and Third-Party Sites

This Site may contain links to other third party websites that may collect personal information about you, including through cookies or other technologies. If you link to another website, you will leave this Site and this Privacy Policy will not apply to your use of and activity on those other websites. You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.

Contact Us

The designated data protection officer is Peter Cleland who can be contacted at totalentertainmentholdings@gmail.com

 

If you have any questions about this Privacy Policy, please contact us at:

 

Total Entertainment Holdings

Cricket Square, Hutchins Drive, PO Box 2681, Grand Cayman, KY1-1111, Cayman Islands

Phone: +51 (11) 65 26 3454

Last Updated:  February 7, 2019

© 2019 Total Entertainment Holdings

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