Privacy Policy

Effective date: April 1, 2025

Last update: April 1, 2025

Introduction

Cult Nation Holding Inc., Cult Nation Productions Inc, Cult Nation Music Agency Inc., Cult Nation Studios Inc., Arketype World Inc., 9457-4977 Québec Inc. (collectively and individually, the “Corporation”, “we”, “us”, “our”) recognize the importance of protecting your personal information. This policy explains how we collect, use, store and disclose your personal information.

Personal information is any information that concerns you and allows you to be identified directly or indirectly (for example, by associating it with other information).

This policy applies to users and customers of our websites, but does not apply to members of our personnel, applicants or our suppliers.

By providing us with your personal information after you have been informed of this policy, as required by applicable law, you consent to the collection, use, storage and disclosure of your personal information in accordance with the terms of this policy. Your consent may also be implied in some cases, depending on your reasonable expectations.

We reserve the right to update this policy at any time and such modifications shall enter into force on the date indicated in the modification. You should check regularly whether this policy has been modified. We consider that you have accepted the modifications to this policy if you continue to provide us with personal information after the effective date of the modifications.

Which business collects personal information?

Your personal information is collected by the Corporation on its own behalf and on behalf of its affiliates.

How is your personal information collected and what information is collected?

Your personal information is collected directly from you when you provide it to us, for example:

  • online on our websites;
  • through emails you send us;

Further to the above, we may also collect personal information, for example, when you decide to subscribe to a newsletter, enter a contest or participate in a survey.

Among other things, we collect the following personal information:

  • last name, first name, postal address, e-mail address, telephone numbers, professional details and details of communications between you and us.

The types of personal information that we collect depend on several factors and the context. We only collect the personal information that we deem necessary for the conduct of our activities and to achieve specific purposes.

We collect personal information automatically on our websites and applications, which is provided through analytical tools or digital markers. These analytical tools only collect a limited set of data, namely the Internet Protocol (IP) address, the date and time of the visit, the pages visited, the actions taken on the website, the domain used to access the website, the type and version of the browser or operating system you are using, and the website you have just accessed and will subsequently access. This information is collected using cookies, as described in more detail below.

For what purposes is personal information collected?

We collect personal information for the following purposes:

  • provide the requested services or information which you request;
  • process your requests;
  • process and resolve complaints and dissatisfaction and improve our services;
  • personalize the user experience and carry out targeted advertising campaigns, if you accepted the installation of cookies;
  • communicate with you within the context of our activities, for internal quality assurance purposes or to manage the quality of the information provided;
  • detect and prevent fraud and ensure the security of our websites;
  • for statistical and accounting purposes (in the latter case, personal information is aggregated and anonymized);
  • to inform you of news, updates, information and special offers concerning the services and products of the Corporation, in accordance with the anti-spam laws and with your express consent where required;
  • if we have reasonable grounds to believe that it may be useful in the context of an investigation into an offense against a federal, provincial or foreign law, or to ensure the protection or defense of a legal interest;
  • as required or permitted under applicable laws.

In addition to the aforementioned purposes, we will inform you of other purposes for which your personal information is collected, no later than at the time it is collected.

If we wish to use your personal information that has been collected for purposes not previously disclosed to you, we will ask for your separate consent before using it, unless applicable laws allow us to do so without your consent.

What technologies are used that include features that allow for identifying, locating or profiling individuals?

We may use cookies. Cookies are pieces of information sent to your computer or mobile device when you visit a website. Cookies are stored, either temporarily or permanently, on the hard drive of your computer or mobile device, thus leaving a trace of your visit. When you consult a website, a cookie may be created and stored, enabling you to be “recognized” every time you consult the website.

Cookies that enable you to be identified, located or profiled are disabled by default. You must first accept them. You may refuse these cookies, but in such a case you will not be able to use some features.

Cookies can enable us to analyze your personal preferences, your interests or your behaviour when you browse the Internet. They thus make it possible to improve your online experience by recording your browsing preferences, to analyze the functioning of our websites and the pages viewed, to carry out statistical analyses and to recommend content to you.

We use the following cookies:

  • Google Tag Manager (id: GTM-WCJ57Z6)
  • Meta Pixels (id: 735147084943810)

We will ask you beforehand whether you accept or refuse the installation of cookies, if these cookies make it possible to identify you, to locate you or to carry out profiling.

Many major websites use cookies. Most browsers are initially set up to accept them. If you wish, you can change your browser settings so that it notifies you when it receives a cookie or refuses to accept it.

Although you are not required to accept cookies, some website features may not function properly if you refuse their installation. You may consult the following link for an overview of how to block or delete cookies on the most common browsers: https://allaboutcookies.org.

Is it possible to refuse the collection of personal data?

You may refuse to allow the collection of your personal information. However, refusal to give such consent may limit our ability to offer you services or sell you products. We will not refuse to fulfill a product or service request from you if you refuse to give such consent, unless the collection is necessary in such context. Your consent for us to use your personal information for secondary purposes (e.g. for marketing) is therefore not mandatory.

Do we collect personal information about minors?

We intend to comply with applicable laws regarding the privacy of minors and advertisements aimed at them. We do not seek to collect personal information about minors under the age of 14 without the verified consent of a person having parental authority or a tutor. However, if you believe that we do so, please let us know. If we ever wish to collect personal information about minors under the age of 14, we will obtain consent directly from a person having parental authority or a tutor, in accordance with applicable laws.

Will we make decisions based solely on automated processing of your personal information?

We do not intend to make decisions based solely on automated processing of your personal information.

Who has access to personal information within and outside the Corporation?

Only authorized members of our personnel who need access to your personal information in order to perform their duties are granted access, for example: those responsible for providing products and services to customers, as well as those in charge of sales, communications and marketing. These individuals only have access to the personal information they require in order to perform their duties.

We will only disclose your personal information to third parties (the type of information disclosed will depend on the situation) in the following circumstances:

  • We will only disclose your personal information to third parties (the type of information disclosed will depend on the situation) in the following circumstances:
  • third parties acting on behalf of the Corporation as agents or service providers (for example, IT service providers, hosting providers, marketing solution providers, as well as our affiliated corporations with which we share services, infrastructure, systems and technologies, and the information is communicated to them solely within this context, it being understood that these third parties must comply with strict contractual terms that require them to maintain the confidentiality of all information, to use it only within this context and not to retain the information upon expiry of the contract;
  • if a person is acting as your representative or if we reasonably believe that the person is acting with appropriate authorization (e.g. tutor, person having parental authority, etc.);
  • to satisfy legal requirements;
  • if we are required to provide personal information in response to a properly issued court order, summons to produce documents, an investigation by the authorities, or as otherwise required under applicable laws;
  • if the Corporation ever sells its business or its assets, in whole or in part, or merges, as required as part of such a transaction, as well as in the context of due diligence;
  • as required or permitted under applicable laws.

What are the roles and responsibilities of members of our personnel who have access to personal information?

We inform members of our personnel of their obligation to preserve the confidentiality of personal information and make them aware of the importance of protecting the confidentiality of personal information. Members of our personnel may only use personal information in accordance with the terms of this policy and our other policies.

What are the measures taken to ensure the confidentiality and security of personal information?

We implement reasonable physical, technological and administrative security measures to protect personal information against loss or theft, as well as unauthorized consultation, disclosure, copying, use or modification. The nature of the security measures varies depending on the sensitivity of the personal information collected, the quantity, segmentation and format of the personal information, as well as the storage methods. These measures include the following:

  • physical measures, such as locked premises;
  • technological measures, such as firewalls;

Where is personal information kept and can it be communicated outside Quebec?

Depending on the nature of the personal information, it may be stored at the Corporation’s offices, in various computer systems of the Corporation or our service providers, or in the storage facilities of the Corporation or our service providers.

Your personal information may be sent outside Quebec or Canada for the aforementioned purposes, which may include the collection, use, communication or retention of such information.

For how long do we retain your personal information?

We retain the personal information we collect for as long as it is necessary to fulfill the specified purposes, as long as it is reasonable to do so for customer service, legal or commercial purposes. The retention period depends on the specific purposes and the nature of this information. At the end of this period, the information is permanently and securely destroyed or anonymized, in accordance with applicable laws.

What are the applicable rules for websites, applications and social media sites operated by third parties?

Our websites or applications may contain links to third-party websites or applications (collectively and individually the“Third-Party Sites”) that may cause you to leave our website or application. We provide these links for your convenience. Third-party sites are not under our control, and we therefore have no control over the privacy and confidentiality practices of third-party sites. Accordingly, any personal information that is transmitted via third-party sites is subject to the privacy policy of those third-party sites. It is your responsibility to read it in order to ensure the protection of your personal information.

We may use third-party social media sites such as Facebook and Instagram. The social media accounts are public and are not operated by us. If you decide to interact with us through these third-party social media sites, you should first read their privacy policies.

The personal information that is provided to us through social media accounts is collected in order to capture conversations, that is, questions and answers, comments, “likes”, shared tweets between you and us. It may be used to respond to inquiries, perform statistical analysis, and for reporting and other purposes outlined in this policy.

What are your rights and how can you exercise them?

You have the following rights, all within the limits and according to the provisions of applicable laws:

  • consult your personal information;
  • rectify or update your personal information;
  • withdraw your consent at any time (the withdrawal of consent binds us as to the use of personal information based on the consent in question, but will not affect the use based on your consent prior to its withdrawal);
  • request the removal of your personal information if it is outdated or not justified for the purposes of collection.

If you request to withdraw your consent to the use, communication and storage of your personal information, the processing of this request will depend on the situation and the intended purpose. According to the case:

  • you may withdraw your consent, but we will no longer be able to offer you a service or product that depends on it;
  • you cannot withdraw your consent, because the processing of your personal information is necessary or mandatory.

In any case, we may need to retain certain personal information to comply with our legal obligations.

You may exercise the above rights at any time by contacting the person responsible for the protection of personal information at the Corporation (see below).

The request must contain enough information for us to be able to process it. We undertake to respond to requests within reasonable time and, wherever possible, within thirty (30) days, as provided for in applicable laws. However, we will first need to verify the identity of the person making the request.

We will ensure that your personal information is as accurate, complete and current as possible for the purposes for which it is used. However, it is your responsibility to ensure that you update your personal information, such as your contact details, with us.

What is the process for handling complaints pertaining to the protection of personal information?

You can lodge a complaint with the person responsible for the protection of personal information at the Corporation (see below) if you feel that we are not complying with our obligations as to the protection of confidential information. We will acknowledge receipt of your complaint, may contact you for clarification, investigate the complaint confidentially, and report the findings of the investigation to you. If your complaint is justified, we will take the appropriate measures to correct the situation. If you are not satisfied with the internal review of your complaint, you can contact the organizations that have jurisdiction over the protection of personal information: the Office of the Office of the Privacy Commissioner of Canada (at the federal level), the Commission d’accès à l’information du Québec, the Office of the Information and Privacy Commissioner for British Columbia or the Office of the Information and Privacy Commissioner of Alberta.

Who can you contact if you have any questions respecting your personal information and who is responsible for the protection of the Corporation’s personal information?

The person with the highest authority within the Corporation has delegated the role of person responsible for the protection of personal information to Audrey Sylvestre, Director, Music Operations, Cult Nation Holding Inc., whose contact details are as follows:

legal@thecultnation.com

You may contact the Corporation’s Privacy Officer to exercise your rights, to ask questions about our personal information practices, or to lodge a complaint regarding the protection of personal information.