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Privacy Policy

Privacy Policy

Last updated June 2018

This Privacy Policy discloses the privacy practices in effect for the Royal Draw ( website (referred to as the "Site"). Consumer Smart Media Inc. (referred to as the "Site"). Consumer Smart Media Inc. (referred to as "us", "we", or "CSM") is the provider and operator of the Site and all its contents. Please read the following to learn what information we collect from you (referred to as "you" or "User") and how we use that information. We are committed to protecting your privacy online. If you have any questions concerning this privacy policy, please email us.

Please read this Privacy Policy carefully and in its entirety. By using the Site, you certify that you have read this Privacy Policy, understand it, and agree to its terms regarding the collection, storage and use of your information. If you do not agree to this Privacy Policy, please discontinue use of this Site.

  • Privacy Policy modifications

    Royal Draw reserves the right to modify this privacy statement at any time. It is recommended that you re-read this page every so often to ensure you are up-to-date with our existing policies regarding the collection and use of your information.

  • Types of Information collected

    Depending on the activity you wish to engage in, some of the information we ask you to provide will be required, and some will be voluntary. If you do not provide required information for a particular activity that requires it, you will not be allowed to engage in that activity. If you use our Site to send information or offers, we may store any Personal Information attached to what you send.

    To provide the Site and all of its features, Royal Draw collects the following types of information about our Users:

    Personal Information
    Personal Information is information that is used to identify a specific User. Personal Information is collected when you engage in activities on the Site that require you to voluntarily enter in information, such as creating or updating an account with your real name, uploading an avatar image, redeeming points at the Points Store, publishing/posting content in discussion forums or comment areas, filling out a survey or form, entering a draw or sweepstakes, sending feedback to us or our Partners, requesting information about us or our partners, or signing up for special offers from third parties through the Site (collectively referred to as "Identifying Activities"). In such cases, you may be asked to supply certain Personal Information, which may include your first and last name, email address, telephone number, mailing address (including postal code), city of residence, date of birth, etc. When creating an account and posting to the Site, all posts will be related to your account and attributable to the name you supply during account creation.

    Some Personal Information, such as your computer's Internet Protocol ("IP") address and account information, will be collected automatically through your engagement with the site and will be used for account administration, such as to facilitate your subscription preferences, process your Points Store orders, and award you with points for completing Offers. Your Personal Information will be stored on our system for the purposes of our operations, and for User convenience.

    Your Personal Information is used to provide you with offers based on your subscription settings, improve Site operation, analyze Site use, conduct contests, improve marketing promotions, improve our goods and services offers, and to customize your experience with third parties as laid out in this Privacy Policy. If you send Royal Draw an email commenting on the draws, deals, goods, or services subject to our Site, we may use your comments and feedback either internally or externally. We may publish your comments and feedback as a testimonial, and/or to inform others about our services, or promote our Site or our offers. We may also post your comment in our internal marketing documents, and/or on our Site. Prior to posting your comments publicly on our Site, we will secure consent from you to use your full name along with your comment. In submitting a comment or reply to our social media, such as the Royal Draw Facebook page or Twitter feed, you are agreeing to have that comment shown publicly.

    We may also use Personal Information to resolve disputes, troubleshoot our Site, provide customer service, send promotional emails, accomplish administrative tasks, contact you, assert enforcement of the terms of our agreements with you (including our Terms of Use and this Privacy Policy) according to any and all applicable laws, and/or in cooperation with law enforcement actions.

    Non-Personal Information
    Non-Personal Information is information that does not represent or identify a specific User, and includes things like the Internet Protocol ("IP") address of the computer you use to access our Site, the Uniform Resource Locator ("URL") of the website you visited before coming to our Site, the URL of the website you visit after leaving our Site, the type of device you used to access the site, and the type of browser you use when accessing our Site. We and/or our authorized third-party service providers and advertisers may collect this information automatically through the use of electronic information collection tools like cookies, web beacons or pixel tags. In using the Site, you consent to the use of such electronic devices.

    We use Non-Personal Information to help us manage and troubleshoot the Site, analyze usage trends, gather User demographic information, comply with applicable laws, and cooperate with law enforcement activities. We may share Non-Personal Information with authorized third-party service providers and advertisers to measure the overall effectiveness of our online advertising, content, and programming.

  • Release of Personal Information

    Royal Draw shall not sell, rent, trade, or otherwise share your Personal Information with other parties except as described below:

    Sharing information with authorized Third-Party Service Providers
    Royal Draw provides services and products through Third-Party Service Providers (referred to as "Third-Party Service Providers") who perform functions on our behalf, such as sending and distributing Royal Draw's administrative and promotional emails. Royal Draw may share your Personal Information with Third-Party Service Providers in order to operate or troubleshoot the Site, fulfill customer orders, send mail or email, remove repetitive information on customer lists, provide search results and links, administer draws or sweepstakes, analyze data, provide marketing assistance, and/or provide customer service. Royal Draw may also collect Personal Information from individuals and companies with whom we have business relationships (referred to as "Partners") and may share your information with third parties to perform administrative functions. For example, when you complete an Offer, we release your user information to the company that provides the Offer on the Site in order to award you with points.

    We encourage Third-Party Service Providers to adopt and post their own privacy policies. The use of your Personal Information by Third-Party Service Providers is governed by their respective privacy policies, and is not under our control.

    Sharing information collected through surveys
    The surveys made available for Users on our Site are supplied by a third party (the "Survey Provider"). Any Personal and Non-Personal Information submitted through a survey our Site will be shared with the Survey Provider. If you participate in surveys through the Site, you may be asked to provide certain information including, but not limited to, your address, consumer and shopping habits, demographic information, and other information that could be used to qualify you for surveys (collectively "User Data"). User-submitted data collected through the surveys ("Survey Data") is anonymous, Non-Personal, and is owned by the Survey Provider and the company that sponsored the survey ("Survey Sponsor"). Survey Data collected through a Survey may be delivered to the Survey Sponsor, free of any restrictions or claims by any party. Neither Royal Draw, nor the Survey Provider, nor the Survey Sponsor shall send emails to any Users who have not opted in to receive those emails. Each party must also comply with all applicable laws, rules and regulations, including but not limited to CAN-SPAM and consumer privacy protection laws, subject to the collections, handling, storage and transmission of User Data and Survey Data.

    Neither Royal Draw nor the Survey Provider shall use User Data in any way other than to provide applicable surveys, and shall not disclose, disseminate or in any way publish or communicate User Data to any person, firm, corporation or other third party without the prior written consent of the User, except to employees, contractors, financial and legal advisors, subsidiaries who have a need to know, have been informed of the confidentiality terms of this Privacy Policy, and who agree in writing or are required by law to maintain the confidentiality of the User Data. Both parties are contractually obligated to use the same degree of care used in protecting its own confidential information from unauthorized disclosure to protect all User Data in its possession.

    One or both parties may disclose User Data, including Personal Information such as a User’s email address, to the other only to the extent necessary to troubleshoot a User's survey experience, or to comply with its legal obligations if so required by law or a court order, wherein the recipient shall, if possible, give the User prompt written notice, and cooperate with the User at the User’s expense in any effort the User wants to undertake to obtain a protective order.

    Neither party shall allow any other party to copy or modify any User Data, nor shall either party export or re-export (within the meaning of export control laws or regulations) any User Data in any form.

    Re-marketing your information
    Royal Draw may re-market your information, which enables us to connect with Users based on their past interactions with the Site. We may hire third-party marketing vendors to perform re-marketing services on our behalf. As a result, third-party vendors, including search engines like Google, may show Royal Draw advertisements. Third-party vendors use cookies to collect User information in order to serve ads based on a User’s prior visits to the Royal Draw Site. This information shall be used only for re-marketing purposes and will not be used by third-party vendors for any other purpose. If you would like to opt out of the use of cookies by third-party vendors, please contact them directly.

    Sharing information in a business transfer
    Like all businesses, Consumer Smart Media Inc. could merge with, or be annexed by another company. Should this occur, that company would inherit and be able to access the information we store, including Personal Information. In such case, the Personal Information would remain subject to this Privacy Policy.

    Sharing Personal Information for our protection and the protection of
    Royal Draw reserves the right to disclose your Personal Information as required by law when we have reason to believe that such disclosure is necessary to protect our rights; to comply with a judicial proceeding, court order, or legal process served on our Site; to enforce or apply this Privacy Policy, our Terms of Use, or other Agreements; or to protect the rights, property, or safety of the Site, its Users, or others.

  • Release of Non-Personal Information

    Royal Draw may release or share Non-Personal Information, such as composite demographic information, with partners and advertisers, which includes Third-Party Advertisers or Third-Party Advertising Companies.

    Third-Party Advertising Companies may be employed by Royal Draw to provision ads when you visit our Site. These companies may use Non-Personal Information collected during and with regards to your visits to the Site in order to provide advertisements about goods and services that may be of interest to you through the use of network tags. Some of these companies may be members of the Network Advertising Initiative ("NAI"). If you wish to learn more about the NAI or any NAI member company, or if you wish to opt out of the targeted advertising initiative of any NAI member company, visit the NAI website.

    We may also use Third-Party Service Providers to track and analyze non-personal usage and volume statistical information from our Users to administer our Site, and to continuously improve its quality. We may publish this statistical information for promotional purposes, or to represent audience for advertisers. None of this statistical information constitutes Personal Information, and it is used and published only as general representative summaries of the activities of our Users. This statistical information and data is owned and used by Consumer Smart Media Inc. and is collected on our behalf.

  • Updating information

    Royal Draw believes that you should have the ability to access and edit your provided and stored Personal Information. We encourage you to promptly update your Personal Information if it changes by logging into your account, or you can send Royal Draw an email request to, or a written request to:

    Consumer Smart Media Inc.
    300 Supertest Rd., Unit 4,
    Toronto, ON, M3J 2M2.

    Please include your current account name, address, email address, and the new information you would like us to update for you.

    As demonstrated above, you always have a choice in whether or not to provide Personal Information, and whether or not to provide Non-Personal Information by choosing whether or not to access our Site.

  • Administrative and Promotional emails

    Royal Draw may send you emails that relate to your activity on our Site and/or contain account and transaction information (referred to as "Administrative Emails"), as well as emails with information and updates on our products and promotional offers (referred to as "Promotional Emails"). Promotional Emails advertise our products and services, including exclusive offers, and/or the products and services of our Advertisers and Partners. If you wish to opt out of receiving our Promotional Emails, please unsubscribe by emailing us at, or by clicking the "Unsubscribe" link found at the bottom of all our Promotional Emails. When contacting us by email or in writing, please include your name and the email address you use to subscribe to our mailing list.

  • Information security

    We at Royal Draw take the security of our User information very seriously, and numerous safeguards are in place to protect Personal Information. Access to your Personal Information on our Site requires a User to provide an encrypted password. We suggest you do not share your password with anyone. In addition to provide password protection, your Personal Information survives on a secure server that only select personnel and contractors can access. We also encrypt certain sensitive information using Secure Socket Layer ("SSL") technology in order to ensure your Personal Information is safe when being transmitted to us.

    No data transmission over the Internet or any wireless network can be 100% guaranteed secure. While we employ industry-quality security measures to protect all data, and try to partner ourselves only with companies that employ the same quality of security, we cannot guarantee the security of any information transmitted to or from our Site, and are not responsible for the actions of any third parties that might receive such information.

  • Data tracking

    To assist and customize your interplay with the Site, Royal Draw uses cookies. A cookie is a small text file containing information about a User that is stored on that User's computer as a record-keeper. We use cookies to save you time when using the Site, and to remind us of who you are. Cookies also facilitate our collection of your Non-Personal Information, such as which pages on our Site you visited and what links contained therein you clicked on, and whether or not you accessed our Site through a referral link. This information helps us create and maintain a user-friendly experience for all visitors. Cookies may be placed on your computer separately and in addition to ours by any Third-Party Advertising Companies we may use to present advertisements on our Site. Royal Draw has no access to or control over cookies used by any of its Third-Party Advertising Companies. This Privacy Policy is relevant to the use of cookies by our Site only, and does not account for the use of cookies by any Advertiser. Most browsers automatically accept cookies, however, you may be able to modify your browser settings to refuse cookies. If you refuse or delete our cookies, please be aware that some parts of the Site may not work properly for you.

    Other data tracking devices
    In addition to cookies, we may use other standard automations like pixel tags and web beacons to track your use of our Site’s pages and promotions, or we may allow our Third-Party Service Providers to use these automations on our behalf. Pixel tags and web beacons are tiny graphic images that may be placed on pages within our Site, or in our emails, that allow us to determine whether you have performed a specific action. When you access a page or open an email that contains pixel tags and web beacons, they create a Non-Personal record of that action. Pixel tags allow us to measure and understand visitor traffic and behaviour on our Site, measure responses to our promotions, and measure our Site's overall performance. Our Marketing Partners may supply us with pixel tags and web beacons for the same purposes.

  • Third-party website Privacy Policies

    This Privacy Policy only addresses the collection, use, and disclosure of information acquired on Other websites accessible through this Site may have their own privacy policies. If you visit any such website through this Site, we highly recommend you review their privacy policy. Royal Draw is not liable or responsible for the privacy policies or practices of any third party linked on our Site.

    Children under the age of 13 are not permitted to use this Site, and children between the ages of 13 and 18 may only use this Site if supervised by a parent or guardian. We do not knowingly collect personal information from anyone under the age of 13, and we do not aspire to attract Users under the age of 13. Royal Draw will not post any pictures of any User under the age of 18 on the Site or the Site's social media pages, even if the picture was submitted by the User (e.g. a Winners Wall submission).

    Publicly accessible areas
    Areas may exist on our Site where Users can publicly post information about themselves, post text, images, links, or other media, and communicate with each other, such as on discussion boards or the home page news feed. On the home page news feed you can choose whether to post to friends, or to the public. The information made public in these areas may be accessible by other consumers and companies, and could appear on other websites or web searches. As such, this information could be read, collected, and used by others. For example, if you post your email address publicly, your email address could be accessible by spammers and other unsolicited message senders. Royal Draw has no control over who reads your information made public on our Site, or over what others may do with that information. Please use caution when posting any Personal Information, or when using your real name on the Site. If you use your real name in your account, your name will be associated with any public or friends-only posts. If you post such information in a publicly accessible, Royal Draw is not responsible for any resulting solicitations or contact. If Royal Draw plans or wishes to publicly post your information, we will first obtain consent from you to do so. Submitting a comment or reply to any public forum constitutes an agreement to have any Personal Information contained within to appear publicly on that forum.

  • Privacy rights of California residents

    The California Online Privacy Protection Act (referred to as the "Act") requires us to provide any California residents who subscribe to Royal Draw with a summary of their privacy rights under the Act and the California Business and Professions Code. Upon request, we will inform California residents of (1) the categories of Personal Information we collect and the third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the goods or services marketed by those third parties. Furthermore, the Act requires us to allow California residents to control who they do and do not want us to share their personal information with. If you are a California resident and you would like us to send you any of the above-mentioned information entitled to you under the Act, please send an email request to our contact address found below. When contacting us, please provide your name, address, email address, and a description of the Personal Information you do not want us to share with our Business or Marketing Partners. There is no charge for requesting this information, or for controlling the sharing of your Personal Information. Please allow up to 30 days for a response.

  • Contacting Royal Draw

    Whether you are a new User, existing User, potential User, Merchant, marketer, publisher, media member, or job seeker, we want to hear from you. Please contact us at the following address:

Consumer Smart Media Inc. Headquarters Address
Consumer Smart Media Inc.
300 Supertest Rd., Unit 4,
Toronto, ON, M3J 2M2
Fax: 416-667-0044