Privacy Policy

This Policy describes the practices regarding personal information collected by Sans Souci and
Coppperhead (“Sans Souci and Coppperhead Association” “SSCA”, “we” or “us”) through our websites
(currently, (“Websites”) when you sign up for, use, access or otherwise interact with the
We may change this Policy from time to time. If changes are made, notification will happen by posting
the updated Policy to the Websites and revising the “Updated” date. The most current version of this
Policy will be effective at the time it is posted. By continuing to access or use the Websites after those
changes become effective, you agree to be bound by the revised Policy.
By accessing and using any of the Websites, you acknowledge you have read and agree to be bound to
all the terms of this Policy.
The Information We Collect
Personal Information. As used in this Policy, “personal information” is information about an identifiable
individual, as defined in privacy laws applicable to Sans Souci and Copperhead Association, and includes
information such as your name, email address, phone number, fax number, and address.
Third Party Personal Information. From time to time our Websites may also collect personal information
about third parties that you can supply in accordance with applicable laws. For instance, this may be the
email address of someone you wish to inform about a document or promotion on our Websites that we
may contact in accordance with applicable laws.
Additional Information. We may collect additional information than those outlined above, such as for
future upgrades to the Websites, or in connection with the addition of new features and products, for
which we will advise prior to collection.
Non-Personal Information. We also may collect certain non-personal information when you visit the
Websites, such as the type of browser you are using (e.g., Chrome, Firefox, Safari or Internet Explorer),
the type of operating system you are using (e.g., Windows 7, 8, 10, Mac OS X, iOS, Android etc.) and the
domain name of your Internet service provider (e.g., Rogers, Bell, TELUS).
Personal Information of Children Under 13. We do not knowingly solicit or collect personal information
from children under the age of 13. We encourage parents of children under the age of 13 to regularly
check and monitor their children’s use of email and the Websites.

How We Use and Share Your Information
Personal information will only be collected, used and shared for the purposes identified at the time of
collection or as outlined in this Policy. Except as described in this Section, we do not exchange, sell, rent
or distribute your personal information for any purpose.
As Requested by You. We may use the information you provide about yourself to fulfill your requests
for our products, programs, and services, to respond to your inquiries about our offerings, for you to
participate in contests or market research, or to contact you about your account with us.
Marketing. We may use your information to communicate with you, such as to notify you about new
products, programs or services, and to offer you other products, programs or services that we believe
may be of interest to you, provided we have your consent to do so. Your consent to use or share your
personal information for these purposes are optional and is not required as a condition of using the
Websites. If you do not want your personal information to be used or shared for these additional
purposes, please contact the Sans Souci and Copperhead Association Privacy Office at the address set
out below.
Third Party Service Providers. Sans Souci and Copperhead Association may use outside service providers
on Sans Souci and Copperhead Association’s behalf to collect, use and share personal information in
accordance with this Policy. These service providers are bound and subject to Sans Souci and
Copperhead Association’s privacy policies. We require all such service providers to keep your
information confidential and secure and to have privacy policies and security standards with respect to
personal information that are comparable to ours. We also may share other information with third
parties in a manner that does not identify particular users, including, for example, aggregated
Legal Processes. We may disclose personal information under applicable laws, for example, in response
to a court order or a subpoena. We also may disclose such information in response to a law
enforcement agency’s request.
User Generated Content. User generated content posted through the Websites such as product reviews,
commentary on discussion boards or blogs, and certain social networking preferences (e.g. pages you
“Like” or “Recommend”) may be accessible by other consumers and companies and may appear on
other websites or web searches, and therefore this information could be read, collected, and used by
others. Sans Souci and Copperhead Association cannot ensure the privacy of any user information
included in that user generated content.
Social Media. To the extent you associate an account managed by third parties such as social media sites
(e.g., Facebook and Twitter) with a Sans Souci and Copperhead Association account, you authorize Sans
Souci and Copperhead Association to have access to this information and agree that Sans Souci and
Copperhead Association may collect, store and use such information in accordance with this Policy.
Disclaimer of Information Provided to Third Party Websites. In some cases we may allow you access to
certain third party services by links or otherwise. Any information you provide to these third party
services is not user information and will not be subject to this Policy. These links are not intended as an
endorsement of or referral to the linked websites. Once you link to another site, you are subject to the
privacy and security policies of the new site.

Retention. Sans Souci and Copperhead Association will retain user information for so long as it continues
to be useful in connection with providing or improving the Websites and product offerings and subject
to law and this Policy. We may further retain and use data as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
Aggregate and De-Identified Information. We may use and share user information in aggregated or de-
identified formats by removing direct personal identifiers, for internal purposes or to third parties for
any purpose to the extent not prohibited by law. This Policy does not limit our use or disclosure of any
aggregate or de-identified information created from user information in any way, and we reserve the
right to use, disclose, and sell de-identified information (including de-identified information combined
with non-scrubbed information that is not your personal information) to our partners, advertisers, and
other third parties at our discretion to the extent permitted by law. “De-identified” means Sans Souci
and Copperhead Association has taken reasonable precautions to protect data de-identified from you
from being re-identified to you.
Export of Personal Information. Your personal information may be processed and stored in the United
States or other countries and may be accessible to the United States or other country’s government,
courts or law enforcement or regulatory agencies through their laws.
How Sans Souci and Copperhead Association Safeguards Your Information
Protection of Your Information. Sans Souci and Copperhead Association takes precautions to secure
your personal information and protect it from loss, theft, unauthorized access, destruction, use,
modification, and disclosure. Such measures include technological, physical and organizational
safeguards that are appropriate given the sensitivity of the personal information, including maintaining
controlled access to electronic and paper documents and files, using appropriate technology safeguards
such as passwords, firewalls and encryption, and restricting access to those of our employees,
representatives and subcontractors who need to know such information to provide you with the
services for which the information was collected. However, please note that Sans Souci and Copperhead
Association’s security measures may change or be unavailable from time to time and no data
transmission over the Internet or any wireless network is 100% secure, so we cannot guarantee the
security of your personal information.
Retention. Sans Souci and Copperhead Association keeps your personal information only for as long as
necessary to accomplish the identified purposes, and then securely destroys such information.
Cookies and Web Beacons
Cookies. To enhance your experience, many pages on the Websites use “cookies”. Cookies are text files
we place in your computer’s browser to store your preferences or other information. Cookies, by
themselves, do not tell us your e-mail address or other personal information unless you choose to
provide this information to us by, for example, registering at a Website or subscribing to our newsletter.
However, once you choose to furnish the Website with personal information, this information may be
linked to the data stored in the cookie.
Beacons. We may also use web beacons. Beacons are small pieces of code placed on Web pages, videos,
and in emails that can communicate information about your browser and device to a server. Beacons
can be used, among other things, to count the users who visit a Web page or read an email, or to deliver
a cookie to the browser of a user viewing a Web page or email.

Use of Cookies and Beacons. We use cookies and beacons to understand site usage and to improve the
content and offerings on our sites. For example, we may use cookies and beacons to personalize your
experience at the Websites (e.g., to recognize you by name when you return to a Website). We also may
use cookies and beacons to offer you products, programs, or services in accordance with this Policy. We
may use third party cookies on our Websites as well. For instance, we use Google Analytics to collect
and process certain analytics data. Google provides some additional privacy options described at regarding Google Analytics cookies. Cookies and beacons
can be removed or blocked in accordance with your browser’s specifications, but in doing so the
Websites may have more limited services.
Feedback, Inquiries and Complaints – Privacy Officer
If there is a concern or complaint about this Policy or your personal information, or if you wish to update
or correct your information, you may contact Sans Souci and Coppperhead Association’s Privacy Officer
at the following address:
Privacy Officer
c/o Sans Souci and Coppperhead Association
561 Avenue Road
Suite 206
Toronto, ON M4V 2J8
Sans Souci and Coppperhead Association will respond to all inquiries, complaints or requests to access
or revise personal information within a reasonable time. Sans Souci and Coppperhead Association will
investigate all complaints received in a reasonable time frame and the Company will take all reasonable
and appropriate measures as it determines is required to respond to any and all well founded
complaints. The Company reserves the right to charge a reasonable fee in connection with complying
with all lawful and permitted access requests.