Effective: August 2026
AscendFS Inc. and its related affiliates and subsidiaries (collectively, “AscendFS”, “we”, “us”, or “our”) understand the importance of privacy and the sensitivity of personal information. We are committed to protecting the personal data of all individuals who interact with our digital platforms, prioritizing security, transparency, and trust in how we handle and safeguard that information.
This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, and protect your personal information when you access or use any of our digital properties, including but not limited to our Platforms (such as www.ascendfs.com, www.ascendfs.ca, www.victoryvault.ca, www.victoryvault.com, www.unitysweepstakes.ca), client portals, mobile applications, hosted web pages, and other services operated or controlled by AscendFS (collectively, the “Platforms”). This Policy is intended to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), Quebec’s Act respecting the protection of personal information in the private sector, and other applicable Canadian privacy laws and also addresses relevant privacy obligations in other jurisdictions where AscendFS operates.
This Policy should be read in conjunction with our Terms and Conditions of Use made available from time to time (“Terms & Conditions”), which govern your use of our Platforms and services, and for Client Organizations using Ascend's Clover-integrated hardware, our AscendFS Clover POS Privacy Policy, which governs the collection and use of data through Clover point-of-sale devices. By accessing or using any of our Platforms, you acknowledge that you have read and understood this Policy and agree to its terms, as well as to the Terms & Conditions, and, if applicable, the AscendFS Clover POS Privacy Policy. If you do not agree with our policies or practices, please do not use our Platforms or services.
This Policy applies to all individuals who engage with AscendFS whether through our technology, platforms, or services. These individuals may include, but are not limited to:
When we use “user”, "you", “your”, or “them” in this Policy, it may refer to any of the above user types. Where necessary, we will specify if a provision applies only to a particular category of user.
In order to provide our services, which include software and in-venue hardware solutions used to support charitable gaming, fundraising campaigns, sweepstakes, and related campaign operations, we may collect and process various types of personal information. Where indicated below, or where required by law, we will tell you whether providing a particular category of Personal Information is mandatory or optional and the consequences of declining to provide it.
(collectively, “Personal Information”)
We collect Personal Information through various channels, depending on how you engage with our Services. We may collect Personal Information in the following ways:
AscendFS does not engage in data scraping or the unauthorized collection of Personal Information from public sources. We are committed to collecting only the Personal Information necessary to deliver our Services, enhance user experience, and meet our operational, legal, and regulatory obligations.
We use the Personal Information we collect to operate, improve, and deliver our Services. Depending on your relationship with AscendFS, we may use your information for the following purposes:
Please note that AscendFS does not sell Personal Information in the traditional sense. However, certain disclosures described in this Policy, such as sharing data with advertising platforms for targeted advertising purposes, may be considered a “sale” or “sharing” under applicable U.S. State privacy laws. We will only use your Personal Information as described in this Policy or as required by law.
We may disclose Personal Information that we collect, or you provide as described in this Policy:
We may also disclose your Personal Information:
To deliver our Services effectively, we may transfer your Personal Information to our subsidiaries, affiliates, contractors, service providers, and other third parties that support our business operations. These parties are contractually required to handle Personal Information securely and in compliance with the standards set out in this Policy.
Personal Information may be processed, stored, or transferred outside of Canada, including in jurisdictions with privacy laws that may differ from those in Canada. For example, certain technology services supporting our Platforms including cloud storage providers, analytics services, and payment processors may be hosted in the United States. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Personal Information may also be transferred between AscendFS and its subsidiaries or affiliated entities (including our U.S.-based subsidiary) as necessary to support service delivery and platform operations and maintain operational continuity. These transfers are governed by data protection agreements, including intra-group data sharing terms and, where applicable, standard contractual clauses or equivalent mechanisms.
When we transfer Personal Information internationally, we take appropriate steps to ensure that your data is protected in accordance with this Policy and applicable Canadian privacy legislation. These safeguards may include data protection agreements, contractual clauses, or other legally recognized mechanisms.
For Quebec Residents: Before transferring Personal Information outside Quebec, or entrusting a person or body outside Quebec with processing Personal Information, we may conduct a Privacy Impact Assessment that considers the sensitivity of the information, the purposes for which it will be used, the safeguards that will apply, and the legal framework applicable in the receiving jurisdiction.
You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada. See Section 18 for contact details.
By submitting your Personal Information or engaging with the Platforms, you consent to this transfer, storage, or processing.
The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. While no system is completely secure, we are committed to continuously improving our practices to align with evolving industry standards. Our safeguards include:
While we implement strong security measures to protect your Personal Information, no system is completely secure. The protection of your information also depends on your actions. If you have been provided with, or have chosen, a password to access certain areas of our Platforms, you are responsible for keeping it confidential and should not share it with others. Please exercise caution when disclosing information in public areas of the Platforms, such as message boards, as this information may be accessible to other users.
Although we strive to protect your data, transmission over the Internet is not entirely secure, and any transmission of Personal Information is done at your own risk. We are not liable. To the extent permitted by applicable law, for any circumvention of privacy settings or security measures on the Platforms. However, if a data breach occurs that presents a significant risk of harm, AscendFS will notify affected users in accordance with applicable laws.
For Quebec Residents: We also maintain a register of every confidentiality incident and, where an incident presents a risk of serious injury, we notify the Commission d’accès à l’information du Québec, in addition to notifying affected individuals, as required by applicable law.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to provide our Services and fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We establish retention periods based on the type and sensitivity of the information, the purposes for which it was collected, applicable legal and regulatory requirements, and our legitimate business needs. Please note that we may be required in certain circumstances to retain your Personal Information as long as required by law (for example, in order to comply with our policies and procedures in connection with self-exclusion or to comply with jurisdictional regulatory requirements for charitable gaming).
Under some circumstances, we may anonymize or de-identify your Personal Information in accordance with generally accepted best practices and applicable legal requirements, so that it can no longer be associated with or identify you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose, including without limitation, business intelligence and research, without further notice to you or your consent. We do not attempt to re-identify anonymized or de-identified information and do not sell such data to third parties.
The Platforms may include links to third-party platforms, plug-ins, services, social networks, or applications. Engaging with these third-party services may allow them to collect, process, or share your Personal Information in ways that are beyond our control.
If you follow a link to a third-party platform or engage a third-party plugin, please note that these third-parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party platforms, and as such, we strongly recommend reviewing the privacy policies of any external sites you visit to understand how they handle your Personal Information.
We use cookies and similar technologies to support the operation, security, and functionality of our Platforms and to enhance your user experience. Cookies are small files that are stored on your device when you visit our Platforms. For more information about the categories of information we collect through cookies and the purposes for which we use that information, please see Sections 3, 4, and 5.
The technologies we use for this automatic data collection may include:
Where available, you may manage your cookie preferences through a cookie consent banner or similar preference management tool. You may also manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality or performance of our Platforms.
For Quebec Residents: Where our Platforms use cookies or similar technology capable of identifying, locating, or profiling you, we can configure non-essential technologies to be off by default until you provide your consent through our cookie preference tool.
Some content or applications on the Platforms are served by third-party providers, including advertisers, ad networks and servers, content providers, and application providers. These third-parties may use cookies to collect information about you when you use our Platforms. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different Platforms and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. We do not control these third-parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
You can opt-out of several third-party ad servers and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and/or an opt-out tool created by the Network Advertising Initiative. You can also access these Platforms to learn more about online behavioural advertising and how to stop Platforms from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Our Platforms is not available for users under the age of 18 (or the age of majority for the jurisdiction the user is located in) (a “Minor”). Minors may not provide any information to or on the Platforms. We do not knowingly collect Personal Information from Minors.
If you are a Minor, do not use or provide any information on this Platforms or on or through any of its features/register on the Platforms, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.
If we learn we have collected or received Personal Information from a Minor without verification of parental consent, we will delete that information.
If you believe we might have any information from or about a Minor, please contact our privacy officer in accordance with Section 18 of this Policy.
Subject to applicable law, you may have certain rights regarding your Personal Information. The availability of these rights may depend on your jurisdiction of residence and the circumstances in which your Personal Information is processed. These rights may include the following:
We strive to ensure that the Personal Information we hold is accurate and up to date. If your information changes, please notify us so we can maintain accurate records.
You have the right to request confirmation of whether we hold Personal Information about you and, where applicable, you have the right to review, verify, update, or correct, your Personal Information by contacting our Privacy Officer, whose details are provided in Section 18 of this Policy.
Where you have provided your consent to the collection, use, and disclosure of your Personal Information, you have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, please contact our Privacy Officer, whose contact details are outlined in Section 18 of this Policy. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. Withdrawing your consent will not affect the lawfulness of any processing carried out before you withdrew your consent.
Where required by applicable law, you may request that we delete your Personal Information. For Quebec residents, this may also include a right to request that we cease disseminating your Personal Information or de-index any hyperlink associated with your name where dissemination contravenes the law or a court order.
Please note that we may be unable to comply with your request where we are required or permitted to retain your Personal Information to comply with legal, regulatory, contractual, or other legitimate business obligations. This right is also available where the dissemination of your Personal Information causes you serious injury in relation to your right to reputation or privacy that clearly outweighs the public’s interest in knowing the information, and that injury cannot be limited by less drastic means.
Where required by applicable law, you may request a copy of certain Personal Information you have provided to us in a structured, commonly used, and machine-readable format, or request that such information be transferred to another organization where technically feasible.
To protect your privacy and security, we may require you to verify your identity before processing any requests. In some cases, we may be unable to accommodate a request if it would conflict with legal requirements, regulatory obligations, or data integrity policies.
Additionally, certain requests may be denied if the information has been anonymized, erased, or is no longer retained in accordance with our data retention practices. If we cannot grant your request, we will inform you of the reason, subject to applicable legal and regulatory limitations.
This Policy may change from time to time. It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated.
If we make material changes to this Privacy Policy, we will notify you through a notice on the Website home page. We may also notify you in advance of any material changes to this Policy including any new ways that we collect, use, disclose, and store your Personal Information. Please check the Policy periodically for updates, as your continued use of these Platforms after we make changes indicates that you accept and consent to those changes.
If you reside in certain U.S. states, including but not limited to California, Colorado, Connecticut, Utah, and Virginia, you may have specific privacy rights under applicable state privacy laws (collectively, the “State Privacy Laws”). This section supplements the rights and disclosures contained elsewhere in our Privacy Policy, including Section 14. We will not discriminate against you for exercising any of your privacy rights under applicable State Privacy Laws.
In the past 12 months, we may have collected and used the following categories of personal information, as defined under applicable State Privacy Laws:
We collect this information to operate and improve our Services, support charitable campaigns, provide customer support, comply with legal obligations, and for limited marketing or analytics purposes.
We may disclose personal information to third-party platforms (such as Facebook, Google, and advertising networks) to support audience targeting, retargeting, or campaign measurement. These activities may be considered "sharing" or "selling" under some State Privacy Laws.
You have the right to opt out of the "sale" or "sharing" of your personal information, including for purposes of targeted advertising. You can exercise this right by contacting our Privacy Officer in accordance with Section 18.
We do not knowingly sell or share Personal Information of individuals under the age of 18.
If you are a California resident or resident of any other state where applicable, you may designate an authorized agent to make a request on your behalf. We may require the agent to submit proof of authorization and may also ask you to verify your identity directly.
Where required under applicable State Privacy Laws, if we deny your request to exercise a privacy right, you may have the right to appeal that decision. To submit an appeal, please contact our Privacy Officer in accordance with Section 18. We will provide information about the applicable appeal process in our response.
We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact our Privacy Officer at:
If you are located in Canada:
Privacy Officer
AscendFS Inc.
1 Adelaide Street E, Suite 2410
Toronto, ON
M5E 1E5
Email: privacy@ascendfs.com
If you are located in the United States:
Privacy Officer
AscendFS Delaware, Inc.
4235 Hillsboro Pike, Suite 247,
Nashville, TN 37215
Email: privacy@ascendfs.com
We are committed to addressing any concerns you may have and will respond to your inquiry within a 30 days, or such other period as required by applicable law.
If you are not satisfied with our response to your privacy-related inquiry and you are located in Canada, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada, the Information and Privacy Commissioner of Ontario, or if you are a Quebec resident, the Commission d'accès à l'information du Québec, as applicable (addresses are subject to change so please verify prior to sending any communication).
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Toll-free: 1-800-387-0073
Website: www.ipc.on.ca
If you are a Quebec resident, you may also file a complaint with the Commission d'accès à l'information du Québec:
Commission d'accès à l'information du Québec
525 Boulevard René-Lévesque E,
Québec Québec
G1R 5S9
Toll-free: 1-888-528-7741
Website: www.cai.quebec.gc.ca
U.S. residents may also have the right to lodge a complaint with their applicable state Attorney General or state privacy regulator. Contact details vary by state and are subject to change; please consult your state's official government resources for current information.
By using our Services, you acknowledge and agree to the terms of this Policy.
We appreciate your trust in us and will continue to work diligently to protect your Personal Information and provide you with the best possible service.