Trusty Ox Systems Ltd Privacy Policy


Dated: October 1, 2017

This privacy policy (the “Privacy Policy”) constitutes an agreement between you (“user”, “you” or “your”) and Trusty Ox Systems Ltd. and its affiliates and subsidiaries (collectively, “TOS”, “us”, “our” or “we”). TOS is dedicated to protecting the privacy rights of our users. This Privacy Policy describes how TOS collects, protects, uses and discloses information and data created in the course of your access to and use of the various websites, software, applications, services and other products (including in-app purchases) we provide or make available (including, without limitation, the Services, Websites and Software (each as defined below)) together with any information, customer service, customer support, or other related services provided in connection therewith (collectively, “Products and Services”).

Please note that TOS is not responsible for the actions of any third parties, the content of their websites, the use of information you provide to them or any products or services they may offer.  Any link to third party websites  does not constitute our sponsorship or endorsement of, or affiliation with those third parties.

If you have any questions or concerns after reading this, please email us at

For the purposes of this Privacy Policy:

“Software” means all software distributed, published or otherwise made available by TOS, including, but not limited to mobile applications, web-based software or applications, downloadable/installable software and apps, video, audio, animations, images or digital products for mobile platforms, personal computers or personal electronic devices and web-based or streaming video, audio, animations, images or other digital media content accessed by means of a browser, within website, application or through other online communication method, and also includes all updates, upgrades, patches or other improvements as well as any and all accompanying manuals, packaging and other written documents, files, digital or other online materials and any and all copies of all software programs, applications and digital content and materials.

“Services” means all services made available by TOS, including but not limited to services accessed through the Software or the Websites; and

“Websites” means this website,,, and other websites and web pages owned or operated by TOS.

Acceptance of TERMS and revisions

By accessing, using or installing any of our Products and Services or submitting information to us you accept this Privacy Policy. If you do not accept this Privacy Policy you must not access or use any of the Products and Services.

We reserve the right to revise this Privacy Policy at any time. We will give you notice of such revisions by posting the revised Privacy Policy at It is your responsibility to ensure that you are aware of the current Privacy Policy when you access or use any of the Products and Services. If you continue to access or use any of the Products and Services after any revisions to this Privacy Policy are posted you will be deemed to have accepted those revisions.

Types of Information We Collect

There are two types of information we may collect through your access to and use of the Products and Services:

  • “Personal Information” means information about an identifiable individual (including any “Personal Information” as such term is defined in the Personal Information Protection and Electronic Documents Act, Canada or the Personal Information Protection Act, British Columbia). Personal Information may include, but is not limited to, a person’s name, email address, residential address, precise geolocation information (i.e., your specific location), telephone number, payment card information, transaction history, other billing information and, in some cases, user name.
  • “Non-Personal Information” means information that does not identify you and cannot be used to contact you personally and may include your date of birth, age, gender, postal code and non-precise geolocation information (e.g., your city), as well as information about your computer, mobile device and their hardware/software/firmware and including but not limited to your unique device ID, Internet Protocol (IP) address, or other persistent identifiers. Non-Personal Information also includes “Usage Data” which is anonymous data associated with your computer, mobile device, and/or game system platform, that includes but is not limited to actions you take within and outside of the Products and Services, the browser you use, the identity of other apps included on your device, the date and time of your use of the Products and Services, your game progress, play time, score and achievements, and the URLs you visited and/or apps you used before and after using our Products and Services.

Application of this Privacy Policy

This Privacy Policy only applies to the information that TOS collects and uses, or is supplied, through the use, access or installation of our Products and Services. Any information disclosed to any third party service providers is dealt with in accordance with the privacy policies adopted by each of those service providers. Individuals are encouraged to review the privacy policies maintained by each of those service providers to understand how their information will be used by those entities to process requests.

The Products and Services may contain links to third party websites (the “Linked Sites”) that are not controlled or operated by TOS. The Linked Sites are maintained by third parties who have their own privacy policies and their own terms and conditions of use. This Privacy Policy does not apply to any of the Linked Sites and TOS is not responsible for any information disclosed to or collected by those Linked Sites or for the privacy practices of any operators or sponsors of the Linked Sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. Because we cannot control the activities of third parties, we do not accept responsibility for any use of your information by such third parties, and we do not guarantee that they will adhere to the same privacy and security practices as TOS. To determine how your information will be treated when accessing or using the Linked Sites, you must read the privacy policy, if any, that applies to each of the Linked Sites.

Products Offered in Partnership with Third Party(s)

In some instances, users may register for other services from our Websites or Software. Certain Products and Services, or other products and/or services made available through our Websites or Software, are provided to you in partnership with third party(s) and may require you to disclose Personal Information in order to register for and access such products and/or services. We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you are responsible for reviewing the privacy practices and policies of such third party(s) prior to providing your Personal Information in connection with such products and/or services.

Collection of Information

We may collect information (including Personal Information) as follows:

  • Information you Provide to Us. If you choose to open an account with us, register for our Products and Services, sign up for our newsletter, request support, or in any other way take steps that require the submission of information; we may collect information such as your name, email address, physical address, date of birth, location, gender and/or phone number.
  • Social Media Sites. If you choose to connect to one of our Products and Services through a third-party social network such as Facebook, we may collect information from your profile on such third-party social networks, such as your name, username, photograph, gender and date of birth.
  • If you choose to make a purchase of or through our Products and Services, we will collect your credit card information and other billing information.
  • Public Forums. If you choose to make use of any public forum, comment section, or chat function, we may collect any information you may disclose through such means.
  • In-Media Communications. If you choose to send a message to another user or defined group of users through our message, chat, post or other in-app function, we may collect any information you may disclose through such means, as well as the necessary Personal Information of the user(s) you are contacting, in order to facilitate the communication.
  • Push Notifications. If you choose to enable push notifications, we may use your information such as a device ID, in order to send push notifications to your device.
  • Your Location. We may collect precise geolocation information provided that, prior to doing so initially, you will either be informed of such practice or be prompted to allow or disallow such feature. In the event you proceed with using any of the Products or Services or choose to allow such feature, you will have the ability to disallow it at any time thereafter by taking the appropriate steps in the applicable settings tab.
  • Other App’s on your Device. Certain of our Products and Services may read your device to determine what other apps and software have been installed and information, such as your city and gender, may be inferred based on the identity of those apps.
  • Information You Submit to Us. If you choose to submit your information to us for any other reason in any other form, we will collect such information and use it for the purposes for which you submitted it.
  • Visiting our Websites. We will not collect any Personal Information from you simply by virtue of your visiting any of our websites; we only collect Personal Information if you choose to submit it to us. We do, however, collect Non-Personal Information such as device IDs, IP addresses and other persistent identifiers, as well as Usage Data, whenever you use our Products and Services. Such Non-Personal Information is not combined with Personal Information unless you choose to submit Personal Information to us.
  • Speaking with the Call Centre. If you speak to our customer service centre, our third party service provider may collect certain information including Personal Information from you and provide this information to TOS so that we can provide necessary support and address your concerns.
  • Where Permitted by Law. We may also collect information, including Personal Information as otherwise permitted by law.
  • Do Not Track (DNT). Do Not Track (DNT) is a privacy preference that users can set in their web browsers allowing users to opt out of tracking by websites and online services.  At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals, and, therefore, TOS does not recognize DNT.
  • Our Third Party Contractors. From time to time, TOS may employ third party contractors to collect Personal Information on our behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing, shipping or other services on our sites. When requesting these services, you may be asked to supply your name, mailing address, telephone number, email address and other information to our third party contractors. We may ask some third party contractors, such as credit agencies, data analytics or market research firms, to supplement Personal Information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors’ needs and preferences. To enrich our understanding of individual customers, we may tie this information to the Personal Information you provide to us.
  • “Cookies”. In connection with the foregoing collection of information, we may also use “cookies” or similar technologies (small amounts of data that are stored on your computer’s hard drive, mobile device or personal electronic devices when you use or access our Products and Services that identify your computer, mobile device or personal electronic devices and may store information about you such as behavioural data). Should you choose to submit Personal Information to us, we may link cookie information to such Personal Information. If you do not wish to accept cookies, you have the option of blocking or disabling cookies. However, please be aware that some of our Products and Services will not function properly if you do so and you may lose access to Products and Services you purchased. TOS uses cookies to improve your experience on an TOS website.  For example, if you have completed one of our surveys, the cookie ensures you are not asked to complete the same survey again and again.  TOS has also implemented several Google features that use Cookies such as Google Analytics, Google Display Network Impression Reporting, DoubleClick platform integrations and Google Analytics Demographic and Interest Reporting.  Disabling your cookies means your experience will be affected.
  • Third Party Advertisers. In addition, certain third-party advertisers may also make use of cookies in their ads served within our Products and Services. Such cookies may collect Non-Personal Information which those advertisers may use to serve you targeted ads both within and outside of our Products and Services.

TOS does not collect Personal Information through the use of our Products and Services unless users choose to provide it. If you do not wish to have TOS collect your Personal Information through the use of our Products and Services, you can choose not to provide it.

Public Information Including User Generated Content

You may choose to disclose information about yourself in the course of contributing user generated content to us or through your use of our Products and Services including but not limited to our online chat rooms, blogs, message boards, user “profiles” for public view or in similar forums on our Websites and/or on third party websites. Information that you disclose in any of these forums is unencrypted, public information, may be accessed or recorded by TOS, and there is no expectation of privacy or confidentiality therein.

You should be aware that any Personal Information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Information you choose to make public in any of these forums.

Note also that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies.  TOS has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

Use of your Information

We may use your information (including Personal Information) for administrative, analytical, research, optimisation, security and other purposes, including, without limitation, the following purposes:

  • to provide you with any goods, services, or functionality you have requested, including the Products and Services;
  • to improve our Products and Services, and to inform the creation of future Products and Services;
  • to send you information related to our Products and Services, including confirmations, technical notices, updates, security alerts, and support and administrative messages;
  • to process transactions for the Products and Services;
  • to manage your account with TOS;
  • to track your use of our Products and Services to help us learn more about your usage of the Products and Services and content consumption and understand your preferences and tendencies so that we can personalise your experience, provide you with in-media offers and notifications that are tailored to you, and otherwise enhance your experience when using the Products and Services;
  • to personalise your content and offers;
  • to respond to customer service inquiries;
  • to troubleshoot problems with the Products and Services;
  • to enforce our Terms of Use
  • to protect against unlawful activities or other misuse of the Products and Services or for other security reasons;
  • to conduct marketing, including promotional activities such as sending newsletters;
  • to provide you advertising that better suits your interests and profile and is age/gender-appropriate and targeted to your interests or general location or both;
  • to compile statistics;
  • to send you push notifications (if you choose to allow that function); and
  • to take any other action permitted by law.

By providing Personal Information through the access to, or use of, any of our Products and Services, you acknowledge and agree that we may use the Personal Information for the purposes set out in this Privacy Policy and by accessing, using, or installing any of our Products and Services or submitting information to us you also agree that we may use the Non-Personal Information for the purposes set out in this Privacy Policy.

Updates and Push Notifications

We may occasionally send you updates, patches and related push notifications that may be of importance to you. If you do not wish to receive updates, patches and notifications you should discontinue use of our Products and Services or disconnect your computer or device from the Internet.

If you wish to opt out of push notifications, select the applicable settings tab for the applicable Product or Service, and follow the necessary prompts to opt out of further push notifications.

Disclosure of Information

We will not transfer your Personal Information to third parties, except for our business partners who have agreed to comply with legally required privacy standards and who will use the information only for the purposes disclosed at the time of collection or for a use consistent with that purpose.

Notwithstanding the foregoing, we reserve the right to disclose information, including Personal Information, if we reasonably believe that we are required to do so by law or legal process or if we are otherwise requested by any law enforcement officer or agency acting under colour of law. In addition, we reserve the right to disclose Personal Information and Non-Personal Information in order to (a) enforce the Terms of; (b) investigate and/or take action against unlawful activity, suspected abuse or unauthorised use of the Products and Services; (c) protect and defend the rights or property of TOS; or (d) act in urgent circumstances to protect the safety or security of the public or users of the Products and Services. We may also disclose your information (including Personal Information) in connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

We may also share aggregate or anonymous information, including Personal Information, about you with hardware manufacturers, platform hosts, content providers, publishers, business partners, and other third parties, to the extent permitted by applicable law.

We may sell, rent or share your Usage Data and other Non-Personal Information including, without limitation, device IDs, advertising IDs or other persistent identifiers and non-precise geolocation information or precise geolocation information (if you choose to allow us to collect it), with third parties who assist us with our operations such as administration, analytics, research, optimisation, and with our advertising partners in order to, among other things, allow them to serve more relevant advertisements tailored to you.

Our Products and Services offer social sharing features such as “Share” or “Like” on Facebook or other third-party social networking websites and applications. If you decide to use such features, it may allow the sharing and collection of information (including Personal Information) both to and from such third-party social networks. You are responsible for visiting and reviewing the policies of such third parties to obtain information about and understand their information collection practices.

Protection of YOUR Information

TOS has implemented reasonable physical and technical measures to protect the information we collect or are provided with from unauthorized access and against loss, misuse or alteration by third parties. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure.  While we take reasonable effors to safeguard Personal Information, we are not liable for any breach resulting from the limitations of the security of our systems.


For further information on how we safeguard information we collect or are provided with, contact us via email at

Retention of YOUR Information

The data and information that we collect will be stored and maintained by TOS or our third party service providers until you instruct us otherwise, or, acting in our sole discretion, for the longer of: (a) for so long as is necessary or appropriate to carry out the purpose(s) for which such information was collected or (b) for so long as we are required to maintain such information by law or other applicable rules or regulations and your consent to such purposes remains valid after termination of our relationship with you.

Currently, TOS or our third party service providers retain and store information collected by, or provided to, us on secure servers in Canada, the United States and the United Kingdom. As TOS and some of our third party service providers may retain and store information received from users (including Personal Information) outside of Canada, and under the laws of those other jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or foreign jurisdictions may be entitled to access users’ information.

Account Security

If you use any of our Products and Services, you are responsible for protecting the confidentiality of your account password and elected codes, and for restricting access to your computer, device or game system platform, and you agree to accept responsibility for all activities that occur under your account.  Please notify us immediately if you detect suspected misuse of your account.

Access and Accuracy

TOS will use commercially reasonable efforts to provide you access to your Personal Information (to the extent we are in possession of any) if you submit your request for access via Subject to applicable law, TOS reserves the right to deny access to your Personal Information on any of the following grounds:

  • when denial of access is required by law;
  • when granting you access is reasonably likely to negatively impact other people’s privacy;
  • when granting access is, in our judgement and acting reasonably, cost prohibitive; or
  • when we have reason to believe that such requests are frivolous or made in bad faith.

You are responsible for ensuring that all information created through your use of any of our Products and Services is accurate, reliable and complete and you acknowledge and accept that the use of such information is at your own risk. We ask that you keep the Personal Information that you provide to us current and correct. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person. If you believe that the Personal Information maintained by TOS about you is inaccurate or incomplete, you may notify us by describing in detail any inaccuracies or omissions via email at Following receipt of a properly submitted notice, we will, within a reasonable time period and acting in our sole discretion, use commercially reasonable efforts to either: (a) amend or correct your Personal Information to reflect corrected or additional information provided by you, or (b) in connection with your Personal Information, make note of any claimed inaccuracies or omissions reported in the notice submitted by you.

Governing Law
Those who choose to use or access any of the Products and Services from outside Canada do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Notwithstanding the foregoing, and recognizing the global nature of the Internet, each viewer and user shall comply with all local rules regarding online conduct and submission of acceptable materials. This Privacy Policy is governed and interpreted pursuant to the laws of the Province of British Columbia, Canada and the federal laws of Canada applicable therein, without regard to principles of conflicts of law that would impose the law of another jurisdiction, and you accept and submit to the exclusive jurisdiction of the courts located within the Province of British Columbia, Canada.
International Transfer

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same personal information protection laws as your own jurisdiction, and you consent to the transfer of information over international borders and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy.
Questions or Comments
We welcome questions or comments about this Privacy Policy. Please direct any questions or comments to the individual below who oversees TOS’s compliance with privacy requirements:

Trusty Ox Systems Ltd.
Attention:Privacy Officer
Address:Box 21, Lantzville, BC V0R 2H0