Privacy Policy
The Regroupement des festivals régionaux artistiques indépendants ("REFRAIN", "we", "us", or "our") is committed to protecting the personal information we collect, use, and share (collectively, "Processing") in relation to the REFRAIN application and website (www.lerefrain.com or other websites we own that reference this privacy notice, the "Website"), the services described in our Terms of Service (the "Service"), or other instances where you interact with us, such as sales, marketing, or events.
This privacy policy explains when, why, and how we process your personal information, as well as your rights regarding these activities. If you disagree with our policies and practices, please refrain from using the Website or the Service.
For any questions, you may contact us at accesrefrain@lerefrain.com with "ACCES REFRAIN" in the subject line.
1. WHEN DOES THIS PRIVACY POLICY APPLY?
This Privacy Policy applies when you interact with us through the services described in this policy or in our Terms of Service, specifically:
When you visit our website and/or our application;
When you fill out a form on our website and/or our application;
When you communicate with us via email, phone, chat or social media;
When you use our Service;
When you participate in our events.
This privacy policy does not apply to third-party websites, tools, or applications, even if we link to them from our website. It is your responsibility to review and agree to the policies and procedures of those third parties. We encourage you to read the privacy policies of every website you visit. Any links to third-party sites are provided for convenience only and do not constitute our endorsement.
2. WHAT IS PERSONAL INFORMATION
"Personal information" refers to any information that allows someone to identify an individual, directly or indirectly, including but not limited to name, identification number, address, phone numbers, or financial information. Some jurisdictions refer to this concept as "personal data." Anonymous or de-identified aggregated data that cannot identify an individual is not considered personal information.
3. WHAT PERSONAL INFORMATION DO WE COLLECT, AND WHY?
We collect personal and other information from individuals who interact with us. Some information is collected automatically through your use of our website and services; other information is voluntarily provided or obtained from third parties.
3.1 Personal information you provide to us to create a user account
When you register to use our Service, we may collect your:
Name
Address
Location
Email address
Password
Profile photo
Phone number
Items you own
Photos of your items
Your item related needs
Interactions with other members
3.2 Personal information you provide for inquiries
When you contact us with inquiries or to provide feedback, we collect your:
First and last name
Contact details
Job title (for business inquiries)
Place of Work (for business inquiries)
Notes related to your inquiry
When you subscribe to our newsletter, we collect your email address.
3.3 Use of the Website, Application and Service
When you interact with our website or service, we use automatic tracking technologies to gather certain technical and behavioral information.
To provide our Service and make it more useful to you, we (or a third-party service provider) collect information about you, including but not limited to your browser type, operating system, IP address, mobile device identifier, and timestamps.
Log files. As is the case for most websites and applications, our website and service automatically collect certain information and store it in log files. This information includes IP addresses, browser type, Internet service provider, referring/exit pages, operating system, timestamps, and clickstream data. We use this information to analyze trends, administer the service, and better tailor the service to our users' needs. For example, some of this information may be collected so that when you use the service, it recognizes you and the information can be used to personalize your experience.
Do Not Track Signals. Although we do not currently use third-party cookies, our systems recognize your browser’s “Do Not Track” signals, which allow you to opt out of tracking.
3.4 Information collected from third-party companies
We may receive personal information about you from companies that offer their products or services for use in conjunction with our Service, or whose products or services may be linked to our Service.
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information to provide the Service, personalize your experience on the Website and the Service, improve the Service, and operate our business in a compliant manner. We may also use your personal information in any other way that we describe when you provide the personal information.
4.1 Providing the Service
Facilitate the creation of your account and further secure your account
Send you a welcome email to verify ownership of the email address you provided
Identify you as a user in our system
Display your username on our platform
Improve the administration of our Service and the quality of the experience when you interact with our Service, including by analyzing how you and other users discover and interact with the Service
4.2 Contacting you
Provide customer support and respond to your requests and inquiries
Send you notifications, such as security, support, and maintenance alerts
Send you notifications regarding actions on the Service
Send you newsletters, promotional materials, and other notices related to our services or to third-party goods and services
4.3 Combating fraud and complying with legal requirements
Investigate and address conduct that may violate our Terms of Use
Detect, prevent, and address fraud, violations of our terms or policies, or any other harmful or illegal activity
Comply with applicable laws, cooperate with investigations conducted by law enforcement or other authorities in cases of suspected legal violations, or in connection with threats or legal claims
Prevent imminent threats or acts of violence that endanger the life or safety of individuals
Save or protect an individual’s vital interests
5. WHAT ABOUT COOKIES?
In this privacy policy, when we refer to "cookies," we also include other similar technologies such as pixels, tags, and web beacons. Cookies are small files used by web servers that are placed on your device when you visit a website to enhance your online experience.
For example, they can remember your language preferences so that websites are displayed in your preferred language by default, keep you logged in so you don’t have to re-enter your login information each time you visit a website, and optimize the display of a website based on your specific device or browser type..
These include first-party cookies and third-party cookies. Some cookies are stored only temporarily and are deleted each time you close your web browser. Others may remain in your browser and may collect and store data for some time after you have left the website or stopped using our Service..
5.1 Our cookies
We use the following types of cookies:
Functionality: Our Service uses cookies to ensure it functions properly, including loading pages, remembering your user account, and providing tutorials to assist with navigation.
Performance and Analytics: These cookies collect data on usage and performance. This allows us to monitor and improve the performance of the Website, our Service, and your overall experience.
Marketing: We use cookies to deliver more relevant offers and advertisements to our users. We also track user data to refine our marketing strategies and tactics. Most marketing data is automated and anonymized.
5.2 Cookie controls
If you wish to prevent cookies from tracking your activity on our Website or Service, or across multiple websites, you can configure your browser to block certain cookies or to alert you when a cookie is being set.
We only track your activity on our Website for our own analytical purposes. We do not track visits across multiple websites and do not engage in targeted advertising. You can always choose to block cookies using your browser settings. However, if you block all cookies, some features that allow our Service to function properly may not work, and your experience may be affected.
6. WHERE DO WE STORE YOUR PERSONAL INFORMATION?
Your personal information is stored on our servers located primarily in Canada. You consent to the transfer of information to countries other than your country of residence, which may have different data protection rules than those of your country. Our practices regarding your personal information will always be governed by our privacy policy, and where applicable, we will comply with relevant laws to ensure adequate protection for international transfers.
7. IN WHAT CONTEXTS MAY WE SHARE YOUR PERSONAL INFORMATION?
Affiliates, service providers, and partners.
We may share your personal information with our affiliates, service providers, and partners in connection with the provision of our Service or our marketing activities. This is done in accordance with the purposes set out in this Privacy Policy or as permitted by applicable laws, as the case may be. We require our affiliates, service providers, and partners to honor this privacy notice.
Business transfers.
Because it is important for us to have the flexibility and ability to operate our business, we may share and transfer your personal information without your permission when a business event requires such a transfer, such as a merger, acquisition, bankruptcy, asset sale, or a reorganization of assets or operations. In such events, we may share your personal information with the relevant third party (or its advisors) as part of a due diligence process or transfer to the reorganized entity or third party..
Advisors, auditors, law enforcement agencies and other competent authorities.
To comply with our legal obligations or to protect our interests, we may share your personal information with third parties if we believe the disclosure is useful to enforce our Privacy Policy, detect or prevent fraud, security issues, or technical problems, or to comply with an applicable law, regulation, legal process, government request, certification program, or any similar situation.
Other disclosures.
When you have expressly consented to your personal information being shared with other third parties, we will process it in accordance with that consent. For example, there may be specific cases where additional terms apply, and through those terms, we clearly indicate that specific third parties will process your personal information.
8. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We may retain your personal information for as long as you continue to use the Service, have an account with us, or as long as necessary to fulfill the purposes described in this Privacy Policy. We may continue to retain your personal information even after you deactivate your account or stop using the Service if such retention is necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, or protect our legitimate interests. When your personal information is no longer needed for these purposes or you request its deletion, we will destroy it within a reasonable period following your request.
9. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We understand the importance of information security. We use physical, administrative, and technological safeguards to help protect the personal information under our control from accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. Examples of such measures include restricted access to offices, the use of strong passwords, and two-factor authentication.
However, we cannot guarantee that such incidents will never occur, as no method of transmission over the Internet or electronic storage is 100% secure. As such, and to the fullest extent permitted by applicable law, we disclaim any liability that does not result from our gross negligence or willful misconduct.
In the event that information under our control is compromised as a result of a security breach, we will take steps to investigate and address the situation and, in accordance with applicable laws and regulations, notify the individuals whose information may have been compromised.
10. DO WE COLLECT PERSONAL INFORMATION FROM MINORS?
We do not knowingly collect personal information from website visitors who are under the age of 13. Minors under the age of 18 are not permitted to use a parent’s or guardian’s “ACCES REFRAIN” account. If someone under the age of 18 submits personal information to “ACCES REFRAIN” and we become aware that the information belongs to a minor, we will attempt to delete that information as soon as possible.
11. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
You can view, modify, or delete your personal information for certain aspects of the Service through your Settings page. You may also have additional rights depending on the privacy laws applicable to your situation.
Below, we highlight the key rights available to individuals under privacy laws; however, these rights may or may not be accessible to you depending on your place of residence and origin. Some of these rights are also subject to exceptions.
You may request access to and obtain a copy of the personal information we hold about you by submitting a written request along with proof of identity.
You may challenge the accuracy and completeness of your personal information. If your personal information is incomplete or inaccurate, you may request that we correct it.
You may withdraw your consent to the processing of your personal information or restrict it, in which case we will stop processing it.
Without prejudice to any other administrative or judicial remedy, you may file a complaint with a regulatory authority if you believe that our processing of your personal information violates local laws and regulations.
If you wish to exercise any of the above-mentioned rights or if you have any questions or concerns, please contact us in writing and we will respond to your request within 30 days.
12. CAN WE UPDATE THIS PRIVACY NOTICE?
We reserve the right to update our privacy policy from time to time to reflect changes in applicable laws or in our operations. The date of the latest version of our privacy policy is indicated at the top of this page. We will inform you of any changes to our Privacy Policy by posting the updated version. Any changes will take effect upon the publication of the revised privacy policy. Your continued use of the Website or submission of new personal information will be subject to the then-current privacy policy.
13. CONTACT SOMEONE AT REFRAIN ?
If you have any questions, concerns, or complaints regarding our privacy notice or our data collection or processing practices, or if you wish to report a security breach, please contact us at the following address: accesrefrain@lerefrain.com.
Last updated: August 13, 2025
