Privacy
Policy.

1. Scope and accountability

This Privacy Policy applies to personal information handled by Celmorix Grand Promotions Inc. (“Celmorix,” “we,” “us” or “our”) through celmorix.com, the Monte Carlo Nights Merch Giveaway, related winner communications, security inquiries and privacy requests. It applies whether you use a desktop browser, mobile device or another supported way of accessing the website.

For this Policy, “personal information” means information about an identifiable individual, either by itself or when combined with other reasonably available information. Aggregated or irreversibly de-identified information that cannot reasonably identify an individual is not personal information.

Our Privacy Officer is responsible for our privacy program, including policies, service-provider oversight, access requests, staff awareness and investigation of concerns. Contact details appear in section 14.

2. Information we collect

The information collected depends on how you interact with us. We avoid collecting sensitive information that is not necessary for the stated purpose.

Information we ask you not to send

Do not send passwords, payment-card numbers, bank details, health records, government identification numbers or unrelated identity documents. Celmorix does not require payment information to enter or claim this giveaway. If identity or residency evidence becomes reasonably necessary, instructions will explain what limited information is requested and how to provide it securely.

3. How information is collected

• Directly from you: through the entry form, email correspondence, winner verification and privacy or security requests.
• Automatically: through standard server records and the limited browser-storage functions described in our Cookie Policy.
• From operational partners: for example, a delivery provider may confirm that a parcel was delivered or returned.
• From fraud-prevention and security signals: where reasonably required to protect the integrity of the entry process and website.

We do not purchase entrant lists, scrape email addresses, collect contacts from your address book or require referrals. We do not intentionally combine giveaway information with third-party advertising profiles.

4. Why we use personal information

We identify the purpose for collecting personal information at or before collection. Depending on the interaction, we use information to:

1. receive, timestamp and validate giveaway entries;
2. confirm Canadian residency and age eligibility;
3. enforce the one-entry-per-person and one-entry-per-email limits;
4. detect automated submissions, impersonation, tampering and other misuse;
5. conduct the random draw and contact potential winners;
6. administer the mathematical skill-testing question and required verification;
7. allocate sizes, fulfil prizes and provide shipment updates;
8. answer questions, security reports and privacy requests;
9. maintain records needed to demonstrate fair administration and legal compliance;
10. diagnose technical issues and preserve the security and availability of the website; and
11. establish, exercise or defend legal rights where reasonably necessary.

If we wish to use identifiable information for a new purpose that is not reasonably connected with these purposes, we will explain that purpose and obtain consent where required before proceeding.

5. Consent and communications

By voluntarily submitting the entry form after reviewing the privacy notice and Official Rules, you consent to the collection, use and disclosure necessary to administer your entry. You may withdraw consent, subject to reasonable notice and legal or contractual restrictions. Because certain information is essential to administer the giveaway, withdrawing it before completion may require us to close or invalidate the associated entry.

No automatic marketing enrolment

Submitting a giveaway entry does not provide consent to receive promotional electronic messages. Administrative messages—including entry-service notices, potential-winner contact, verification instructions, delivery updates and responses you request—are sent only as needed to administer the promotion or respond to you. If Celmorix offers optional marketing in the future, it will use a separate, unchecked opt-in and provide the identification and unsubscribe information required by Canada’s Anti-Spam Legislation.

Accuracy

You are responsible for providing accurate information. Please contact us promptly if your email or other necessary information changes. We may ask for reasonable information to authenticate a correction request.

6. Sharing and service providers

We do not sell or rent personal information. Access is limited to people and organizations that need it for an identified purpose. We may disclose limited information to:

• secure website hosting, form-processing, email and infrastructure providers;
• professional advisers, auditors and technical-security specialists under confidentiality obligations;
• Canadian fulfilment, printing, warehousing and delivery providers for verified winners;
• regulators, courts, law enforcement or other parties where disclosure is required or permitted by applicable law; and
• a successor organization in a proposed or completed business transaction, subject to appropriate confidentiality and use restrictions.

Service providers are authorized to process information only for contracted purposes and are expected to apply safeguards appropriate to the sensitivity of the information. We seek to limit the fields shared—for example, a carrier receives delivery details, not the full entry database.

Winner publicity

Where permitted by law, we may ask a verified winner for separate permission to publish their first name, last initial, province or territory and prize. Refusing optional publicity will not affect prize entitlement. We do not publish a winner’s email, street address or identity documents.

7. Processing outside Canada

Some technology providers may store or process information in Canada, the United States or another jurisdiction. Information processed outside your province or outside Canada may be accessible to courts, law-enforcement agencies or national-security authorities under the laws of that jurisdiction.

Before using a provider, we consider the nature of the service, the information involved, contractual protections, access controls and available security information. You may contact the Privacy Officer for further information about relevant service-provider processing.

8. Retention, de-identification and deletion

We retain identifiable information only as long as reasonably necessary for its purpose and applicable legal, security and dispute-resolution requirements. Current operational targets are:

When retention is no longer justified, information is securely deleted, destroyed or irreversibly de-identified using methods appropriate to the format. Backup copies may persist for a limited rotation period and remain protected until overwritten.

9. Security safeguards

We use administrative, technical and physical safeguards proportionate to the sensitivity, amount, format and storage of information. Measures may include encrypted transport, access restrictions, separation of duties, secure configuration, logging, input validation, service-provider review, staff confidentiality expectations, backup controls and incident-response procedures.

No internet transmission, email message or storage system can be guaranteed completely secure. You can help by using an email account you control, avoiding shared-device autofill, keeping your browser updated and treating unexpected winner messages cautiously.

10. Your privacy rights and choices

Subject to applicable law and limited exceptions, you may ask us to:

• explain whether we hold personal information about you and how it has been used or disclosed;
• provide access to personal information we hold about you;
• correct information that is inaccurate or incomplete;
• withdraw consent for future processing where processing relies on consent;
• delete information that is no longer necessary, subject to legal or legitimate retention requirements; or
• answer a question or investigate a concern about our privacy practices.

How to make a request

Email privacy@celmorix.com with “Privacy Request” in the subject line. Describe the request and the email address used to enter. To protect you, we may ask for limited information to verify identity and authority. Please do not email copies of government identification unless specifically requested through a secure process.

We will respond within the period required by applicable law or explain any permitted extension. Access may be limited where disclosure would reveal another person’s information, confidential commercial information, legally privileged material, security-sensitive information or information that cannot be disclosed by law. If access is refused, we will explain the reason where permitted.

Browser controls

You may clear or block functional browser storage using your browser settings. Doing so can reset age acknowledgement and locally stored confirmation information. Details appear in the Cookie & Local Storage Policy.

11. Age restrictions

The website and giveaway are intended only for Canadian residents who are at least 18 and have reached the age of majority in their province or territory. We do not knowingly solicit giveaway entries from minors. If we learn that an ineligible minor submitted personal information, we will take reasonable steps to remove it, subject to records needed to document the issue and comply with law.

A parent or guardian who believes a minor provided information may contact the Privacy Officer. The request should identify the relevant email address without including unnecessary information about the child.

12. Privacy and security incidents

We maintain procedures to identify, contain, investigate and remediate suspected unauthorized access, use, disclosure, loss or alteration. Where applicable law requires notification or reporting, we will notify affected individuals and relevant privacy authorities within the required framework and retain the records required by law.

If you believe information submitted through Celmorix has been compromised, contact security@celmorix.com promptly. Include a concise description, relevant dates and the affected Celmorix service, but do not send passwords or financial information.

13. Changes to this Policy

We may update this Policy to reflect changes in the website, service providers, law or privacy practices. The “Last updated” date identifies the current version. Material changes will be presented prominently on the website or communicated directly where appropriate and legally required.

Changes do not retroactively authorize a materially different use of personal information without any consent required by law. Archived versions may be requested from the Privacy Officer where reasonably available.

14. Contact, questions and complaints

Privacy Officer
Celmorix Grand Promotions Inc.
Toronto, Ontario, Canada

Email: privacy@celmorix.com
Security reports: security@celmorix.com
Giveaway support: contest@celmorix.com

We encourage you to contact us first so we can investigate and respond. You may also contact the Office of the Privacy Commissioner of Canada or the privacy authority responsible in your province, where applicable.