SMB Communications Small Business Giveaway — Contest Privacy Notice (English)
This notice is specific to the contest and does not replace SMB Communications' general privacy policy or the privacy terms governing an activated VoIP service.
Who is responsible and how to reach us
The organization responsible for contest personal information is 1001115443 ONTARIO INC., operating as SMB Communications, 184 Fieldside Road, Allenford, Ontario N0H 1A0, Canada.
Privacy contact: the person responsible for the protection of personal information, privacy@tryvoip.ca. Questions, complaints and requests for access, correction, withdrawal or deletion where available may be directed there or mailed to the address above. Receipt of a privacy request does not imply immediate deletion if lawful retention is required.
Information we collect
For an entry, we collect the business's name, province/territory and size (1–10 employees), the authorized representative's name, business email and telephone number, and the time of entry. We record the version of accepted contest rules, optional email/telephone marketing choices, email verification status and dates, relevant contest events, eligibility/draw status, and withdrawal/disqualification decisions. We use necessary technical and anti-abuse data such as a pseudonymized rate-limit identifier, security timestamps and limited audit/transaction identifiers. A pseudonymous identifier can still be personal information depending on context.
If an entrant is selected, we may collect information reasonably needed to verify the business's operation, its representative's authority, a qualifying Canadian service address and availability, the mathematical skill-testing question outcome, service acceptance, and claim/notification dates. We do not need a full service address from every entrant merely to enter. A confirmed winner's service provisioning and billing records are governed by additional customer notices and agreements provided before activation.
Why we need it; how decisions are made
We use this information to (1) accept and authenticate entries; (2) apply the one-business-entry and 24-month previous-winner policies; (3) prevent fraudulent or abusive entries; (4) construct a verified eligible pool and administer auditable random monthly draws and carryovers up to 12 draws; (5) notify and verify potential winners and alternates; (6) check service availability, arrange the prize only with informed acceptance, and address complaints; (7) meet recordkeeping and legal obligations; and (8) secure and troubleshoot the contest.
Eligible drawings use an automated random selection, with a staff-reviewed verification process before a prize is awarded. An automated selection is not a final determination that a person or business has won. Quebec participants may inquire about automated processing and request appropriate human review or correction of erroneous data, as applicable by law.
Contest administration messages (including email verification, winner selection and required instructions) are used only to operate the contest. Participation is not an automatic subscription to newsletters, cold calls or marketing lists.
Optional consents are separate
The entry form offers two separate, unchecked opt-ins: promotional email and promotional telephone contact. Either may be refused or withdrawn without affecting entry eligibility, selection or receipt of the prize. If promotional emails are sent, they must comply with applicable Canadian anti-spam rules, including sender identification and an effective unsubscribe mechanism. We retain consent wording/version, choice, time and any withdrawal to document the preference.
After a winner has been verified and accepts the prize, we may request a third, distinct affirmative opt-in to publish only the winning business name. Refusal does not affect the award. We do not publish an individual's name, private contact details, service address or email on this basis. Withdrawal prevents future publication and triggers a review of material already published; we cannot promise to reverse independent third-party copies.
Who may receive information
Access is limited to authorized SMB staff and service providers who need specific information for hosting, security, contest administration, transactional email/queue delivery, lawful eligibility review and prize fulfillment. This may include the approved hosting platform, FusionPBX email infrastructure, an authorized outbound email relay, and a telecom carrier when necessary to provide an accepted prize. We do not sell contest participant lists or share entry contact details with advertisers merely because someone has entered.
Information may be stored or processed by service providers in Canada or other jurisdictions, depending on actual deployment, contractual arrangements and mail transport. Before launch, SMB must confirm each processor, storage/processing jurisdiction, required data-processing contracts and any cross-border privacy impact assessment and safeguards, especially for Quebec personal information. A precise list of vendors and locations must be added to the published notice once deployment is verified.
Security
We apply reasonable administrative, technical and organizational safeguards proportionate to the sensitivity of the data, such as restricted staff access, transport encryption, protected secrets, rate limiting, audit trails and documented incident response. No online system can guarantee absolute security. Suspected confidentiality incidents are assessed and notified to individuals and regulators when required by applicable law.
Retention and deletion
The Sponsor-approved retention plan (subject to counsel review and implementation verification) is:
| Category | Intended retention |
|---|---|
| Unverified entries | Delete or anonymize 30 days after the verification window expires |
| Verified nonwinning entries | Through a maximum of 12 eligible draws, then 90 days after final eligibility, withdrawal or disqualification |
| Winner and alternate claims, eligibility and award evidence | 3 years after the relevant draw closes |
| Prior-winner exclusion identifiers | 24 months after the winning draw, plus 90 days to close related reviews |
| Draw/audit/integrity evidence | 3 years after the draw |
| Optional marketing consent/withdrawal evidence | 3 years after last relevant marketing activity or withdrawal, subject to applicable law |
| Optional winner publicity consent/withdrawal evidence | 3 years after last publication or withdrawal, subject to applicable law |
| Ordinary technical and security logs | 90 days unless needed for a documented investigation |
| Encrypted backups | Up to 90-day rolling expiration, with restricted access |
| Service, financial and tax records | Governed separately by statutory accounting/service requirements, generally including longer retention where legally required |
After expiry, data is securely destroyed or irreversibly anonymized in line with applicable law and verified deletion procedures. Backups expire on their own protected cycle; a withdrawal cannot guarantee instantaneous removal from historic backups. A legally required retention duty, unresolved complaint, security investigation or litigation hold may extend retention. These are approved policy targets, not evidence that an automated production deletion job is already operating; implementation must be tested before collecting real entries.
Your choices and rights
You can request access to and correction of personal information, ask how it has been used and shared, request withdrawal of an entry or optional consent, and request deletion or portability where rights apply. Withdrawal from the contest ends eligibility for future draws; withdrawal of optional marketing/publicity consent does not invalidate an otherwise eligible entry or awarded prize. We may require reasonable identity/authority verification before disclosing protected information. We respond according to the applicable federal or provincial privacy law, including Quebec-specific rights, deadlines and lawful exceptions. Contact privacy@tryvoip.ca.
Quebec and French-language service
This notice and the contest interface must be available in French under conditions at least as favourable as English. For Quebec residents, the Act respecting the protection of personal information in the private sector and related obligations may require documented governance practices, privacy impact assessments for new technology/certain transfers outside Quebec, and transparent explanations of information collection and automated decision-making. SMB must confirm these assessments, processing locations, provider contracts and complaint processes before opening the contest.
Updates
We will identify the effective date and version of the approved and published notice and make material changes available in both languages with any required notices or additional consent. This notice becomes effective when published for the November 1, 2026 campaign opening.