Effective date: September 2nd, 2022
www.brokenpencilstudios.ca (the "Site") is owned and operated by Broken Pencil Studios Inc. Broken
Pencil Studios Inc is the data controller and can be contacted at:
1025 10 St SE, Calgary, AB T2G 3E1
1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected;
4. The rights of Site users; and
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European
Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the
"GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers
and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
By using our Site users agree that they consent to:
When the legal basis for us processing your personal data is that you have provided your consent to that
processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make
processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Email request at firstname.lastname@example.org.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so
under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
1. Users have provided their consent to the processing of their data for one or more specific
2. Processing of user personal data is necessary for us or a third pary to pursue a legitimate interest.
Our legitimate interest is not overriden by the interests or fundamenal rights and freedoms of
users. Our legitimate interest(s) are: Communication purposes for providing services.
Personal Data We Collect
any additional data beyond the data listed below without notifying you first.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
1. First and last name;
2. Email address; and
3. Company name, business or project information..
This data may be collected using the following methods:
1. Filling our Form.
How We Use Personal Data
on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy
The data we collect when the user performs certain functions may be used for the following purposes:
1. Communication for possible services offering.
Who We Share Personal Data With
We may disclose user data to any member of our organization who reasonably needs access to user data
We will not sell or share your data with other third parties, except in the following cases:
1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protect our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and
have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.
You will be notified if your data is kept for longer than this period.
How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our
data on servers in secure facilities. All data is only accessible to our employees. Our employees are
bound by strict confidentiality agreements and a breach of this agreement would result in the employee's
While we take all reasonable precautions to ensure that user data is secure and that users are protected,
there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we
are unable to guarantee the security of user data beyond what is reasonably practical.
Your Rights as a User
Under the GDPR, you have the following rights:
1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object.
The minimum age to use our website is 18 years of age. We do not knowingly collect or use personal
data from children under 16 years of age. If we learn that we have collected personal data from a child
under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of
age has provided us with personal data their parent or guardian may contact our privacy officer.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data,
if we have disclosed your personal data and to who we disclosed your personal data, if you would like
your data to be deleted or modified in any way, or if you would like to exercise any of your other rights
under the GDPR, please contact our privacy officer here:
Sharon R Chan
1025 10 St SE, Calgary, AB T2G 3E1
Do Not Track Notice
Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not track
the users of our Site over time and across third party websites and therefore do not respond to browser initiated
How to Opt-Out of Data Collection, Use or Disclosure
In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data
Collected section, we provide the following specific opt-out methods for the forms of collection, use, or
disclosure of your personal data specified below:
1. You can opt-out of the use of your personal data for any business purpose. You can opt-out by
A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating
to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can
also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your
If you have any complaints about how we process your personal data, please contact us through the
contact methods listed in the Contact Information section so that we can, where possible, resolve the
issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a
supervisory authority. You also have the right to directly make a complaint to a supervisory authority.
You can lodge a complaint with a supervisory authority by contacting the Office of the Privacy
Commissioner of Canada at 30 Victoria Street Gatineau, Québec K1A 1H3.
If you have any questions, concerns or complaints, you can contact our privacy officer, Sharon R Chan,
1025 10 St SE, Calgary, AB T2G 3E1
Website: www.brokenpencilstudios.ca (the "Site")
to the personal information of children in the United States who are under the age of thirteen (13)
Children's Online Privacy Protection Act ("COPPA"). Any terms defined in COPPA have the same
Children's Data We Collect
We do not knowingly collect the personal information of children under the age of thirteen (13).
Children are not able to make their personal information publicly available on our Site.
Third Party Operators
Third parties do not use our Site to collect personal information about children who use our Site.
A child's parent or guardian can review their child's personal information, direct us to delete their child's
personal information, and refuse any further collection or use of their child's personal information. A
parent or guardian can also agree to the collection and use of their child's personal information but not
allow us to disclose that personal information to third parties, unless disclosure is part of the service
provided by our Site. A parent or guardian can exercise these rights via the following method(s):
1. Email to email@example.com.
We will not require a child to disclose more information than is reasonably necessary to participate in an
activity on our Site.
personal information, can be sent to:
Name: Sharon R Chan
Address: 1025 10 St SE, Calgary, AB T2G 3E1
Phone number: (403) 918-8840