We have developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.
Information We Collect
a. Personal Information
Personal Information is any information in any form that identifies or can identify an individual and includes any information provided to Us by You in using Our Site or services. Personal Information that We collect includes, but is not limited to:
- Account and profile information, including name, e-mail address, address, and phone number;
- usernames and passwords, if any;
- Billing and payment information, including credit card details;
- Any other Personal Information that You may provide when You set-up an account with Us, when You contact Us with questions and/or inquiries, or that You may enter when You use the Site; and
- Any information that We collect from You that is intended to improve and personalize Our Site or services.
b. Non-Personally Identifiable Information
Personal information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any Users. Such information by itself or together cannot be tracked to a specific individual’s personally identifiable information.
How do We use Personal Information?
We collect Personal Information for the following purposes:
- to provide Our Site or services to You and Users;
- to create and administer Your user account;
- to establish and maintain responsible commercial relations and to communicate with You in order to provide Service. This includes, but is not limited to, communications relating to billing, advertising, promotion and account verification;
- to respond to any correspondence You may direct to Us;
- to understand Our customers needs and preferences;
- to enforce Our Terms of Online Sales and Service;
- to provide You with Service or administrative messages;
- to meet legal and regulatory requirements; and
- for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
How do We use Non-Personally Identifiable Information?
Each time You or a User accesses Our Site, We automatically receive and store certain types of non-personally identifiable information about users including IP address, web pages viewed, and date and time. The non-personally identifiable information collected through Your use of the Site is used to monitor website traffic and conduct internal research on Our Users’ demographics, interests and behavior to better understand and serve Our customers. For example, We may collect information such as the length of time a user visited the Website, the pages he or she visited, the type of browser used to access Our Website as well as to track the number of visitors to the Website.
We respect Your privacy and, unless otherwise required by law, We will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing Us Personal Information to register for Our Site is implied consent to use such information to provide You the associated services.
Where appropriate, We will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when We want to use information for a purpose other than those identified above). In obtaining consent, We will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by Us may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, We shall take into account the sensitivity of the Personal Information and the reasonable expectations of Our Users. We will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to Us in writing. You may also change Your communication preferences with respect to email newsletters and notifications of special offers and products, by clicking on the unsubscribe link.
Limiting Use, Disclosure and Retention
Unless required by law, or in connection with a business transaction, We shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining Your consent, where such consent may not reasonably be implied.
As noted above, We do not disclose Your Personal Information to third parties. Notwithstanding, Your Personal Information may be transferred to third party suppliers, contractors and agents (“Affiliates”) who are contracted by Us to assist it in providing and developing products and services.
For example, We use third party payment processors to process Your payments.
Subject to the foregoing, only Our employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about Our Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of Users’ Personal Information.
We will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Us.
Law Enforcement Requests
We will disclose Personal Information without Your knowledge or consent if We receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If We receive a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, Our policy is to provide the requested information.
Children and Minors
Neither Our Site or services are directed to children under the age of 13 years. We will not knowingly collect Personal Information about a child under the age of 13. We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions.
Links to Other Websites and Social Network Plug-Ins
You may be able to access third-party websites through links available on the Website. You may also connect to social media online services such as Facebook, Google, Twitter and Instagram.
You may create links between Our website and social media online service. If You do so, We may be able to publish updates about Our Services to Your social media service accounts through the links that You establish. You may terminate those links at any time by modifying Your social network account.
How can I Access my Personal Information?
Upon request, We will provide information to You or a User regarding the existence, use and disclosure of his or her Personal Information. We will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. A User may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, We may not be able to provide access to all the Personal Information it holds about a User. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. We will provide the reasons for denying access upon request.
We protect Your Personal Information by security safeguards appropriate to the sensitivity of the information. We will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
Our methods of protection include:
- Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to Our place of business in general and to internal offices as well;
- Organization measures, such as security clearances and limited access on a need to know basis; and
- Technological measures, such as the use of passwords, firewalls and encryption.
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If We find a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact Our Privacy Office via e-mail at firstname.lastname@example.org
Last Revised: February 7, 2017