Privacy Statement
**INVISIBLE**
01 • PERSONAL INFORMATION WE COLLECT
- contact information such as name, address, email address and telephone number;
- information provided when you register or otherwise provide information on our web site;
- information provided when you complete questionnaires or surveys;
- information provided when you participate in a promotion or contest;
- information provided otherwise such as by telephone, by mail or through our web site;
- records of customer calls or product-related comments or inquiries;
- such other information we may collect with your consent or as permitted or required by law.
02 • USE OF PERSONAL INFORMATION
uses personal information for the following purposes:
- receiving and replying to your requests, inquiries and comments;
- with your consent, sending you information about products and promotions offered by The Company and / or contacting you to conduct telephone surveys and market research;
- with your consent, sending coupons from time to time;
- providing customer service;
- administering promotions and contests;
- creating a data base of individuals who have registered to receive information from us;
- understanding your preferences, needs and interests and, with your consent, offering you products and information that are likely to be of interest to you and personalizing your experience when visiting our web site such as by presenting you with information and offerings that we think will be of interest to you;
- improving our products;
- managing our business, including customer relations;
- ensuring the security of our business operations including our web site;
- managing, administering, collecting or otherwise enforcing accounts;
- maintaining business records for reasonable periods and as required by law, and generally managing and administering our business, including defending and prosecuting legal claims;
- meeting legal, regulatory, insurance, security, accounting and processing requirements;
- purposes disclosed at the time of collection of personal information; and
- otherwise with consent or as permitted or required by law.
03 • COLLECTION OF YOUR PERSONAL INFORMATION
- to establish and maintain responsible commercial relations and to provide ongoing service, and communication;
- to understand customer needs, trends and preferences;
- to evaluate, develop, enhance, market or provide The Company’ products and services;
- to manage and develop The Company’ business and operations;
- to meet legal and regulatory requirements;
- to protect The Company against error and fraud; and
- for any other purpose to which an individual consents.
- for any other legitimate grounds for collection or use of Personal Information
04 • DISCLOSURE OF YOUR PERSONAL INFORMATION
- a person who in the reasonable judgement of The Company is seeking the information as an agent;
- a company or individual retained by The Company to perform functions on its behalf, such as research or data processing;
- a company or individual retained by an individual, who represents that it expressly is entitled to receive such individual’s personal information, or in the reasonable opinion of The Company implicitly is entitled to receive such individual’s personal information;
- a company or individual retained by The Company for the evaluation, development, enhancement, marketing or provision of any of The Company’ products or services;
- an agent utilized by The Company to evaluate the customer’s creditworthiness or to collect the customer’s account;
a credit reporting agency; - a public authority or agent of a public authority, if in the reasonable judgement of The Company, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information;
- a third party or parties, where the customer consents to such disclosure or disclosure is required by law;
- a financial institution on a confidential basis and solely in connection with the assignment of its right to receive payment, the provision of security or other financing arrangements; and
- professional advisors, consultants, investigators and adjudicators in defending and prosecuting legal claims.
The Company may disclose personal information to affiliates and business partners in order to permit them to send you occasional information about their products and services in accordance with your consent.
In addition to the above, personal information may be disclosed to our affiliates (including outside of Canada) for internal audit, management, billing, administrative and other general business purposes.
Service Providers. The Company may transfer personal information to outside agents or service providers (including affiliates of The Company acting in this capacity) that perform services on our behalf, for example data processing services such as mailing, call centre, billing, marketing, information technology or data hosting or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes and uses described in this Privacy Statement. Some of these service providers or affiliates may be located outside of Canada, , and your personal information may be collected, used, disclosed, stored and processed in jurisdictions outside of Canada for the purposes and uses described in this Privacy Statement. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada and other foreign countries applicable to our affiliates, agents and service providers. For example, we may be required to disclose personal information due to lawful requirements to disclose personal information to government authorities in those countries.
Business Transactions. Personal information may be used by The Company and disclosed to parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or other disposal of all or part of The Company or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples:
- permitting those parties to determine whether to proceed or continue with the transaction
- fulfilling reporting, inspection or audit requirements or obligations to those parties. Assignees or successors of The Company or our business or assets may use and disclose your personal information for similar purposes and uses as those described in this Privacy Statement.
Legal, Regulatory, etc. The Company may disclose your personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit, and security requirements, and as otherwise with your consent or as permitted or required by law (including as required by applicable Canadian and foreign laws applicable to The Company or our agents and service providers, and including lawful requirements to disclose personal information to government authorities in those countries).
05 • OUR WEBSITE/THE INTERNET
Passive Information Collection: As you navigate through The Company’s web site, certain anonymous information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the Web site some of this anonymous information, such as the URL of the Web site you just came from, the Internet Protocol (IP) address, time of visit, date of visit, the pages visited within the site, and the browser version your computer is currently using.
The Company’s web site may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the Web site might not work without cookies. The Company web site may use and combine such passively collected anonymous information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve the site for your use. Such passively collected anonymous information is not combined with personal information collected elsewhere on the web site, unless you have consented to have your personal information collected in conjunction with this passive information.
Use of Cookies
Set out below are the types of cookies currently used on our website, effective May 23, 2018. The Company reserves the right to amend cookies used in conjunction with its website and you are encouraged to review this Privacy Statement frequently for periodic updates describing from time to time any changes to cookies used.
ARRAffinity (Microsoft) – A cookie used by the Microsoft Azure platform (the underlying platform used to build the website) to help with legacy application compatibility. This cookie does not store any personal information and is an application technique that helps to ensure the stability of the website.
_ga, _gat_gtag_UA, _gid (Google) – Google Analytics is a web analytics service provided by Google Inc. (“Google”) that helps us measure how users interact with our web content. The information about use of the website generated by the cookie (including your IP address), is transmitted to a Google server in the USA and saved there. Google will use this information in order to provide an analysis of all visitors’ use of the website and to help us compile reports on various relevant measures and activities (for example, conversion analysis, referral analysis and evaluation of search/ pay-per-click activities). We will not upload any data that allows Google to personally identify an individual, such as names, email addresses, or any similar data. Google will not associate your IP address with any other data held by Google; however, we may connect the data we provide to, or receive from, Google with other data we have about you. BY ALLOWING THE USE OF COOKIES YOU ARE DEEMED TO CONSENT TO THIS CONNECTION. Google has advised us it is compliant with GDPR requirements.
cookieAgreed (Maple Leaf) – This cookie is set on our website once the user has agreed to the notification that is displayed when the website is visited. The notification will display until the user clicks the “I Agree” call to action button at which time a cookie will be set in order to prevent this notification from appearing again. No personal information is stored with the setting of this cookie and this cookie can be reset by accessing and clearing the browser cookie preferences.
06 • YOUR CONSENT
You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our products or services. Note also that where we have provided or are providing products or services to you, your consent will be valid for so long as necessary to fulfil the purposes and uses described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records, disclosures to Canadian and foreign government entities as required to comply with laws, and reporting on credit information after credit has been granted, if applicable).
The Company collects, uses and discloses your personal information with your consent, except as permitted or required by law. Accordingly, notwithstanding the foregoing we may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.
Unsubscribing (Opting-out) of Email Campaigns
If you have consented to receive promotional materials from The Company we may periodically use your email address to send you information related to The Company products and services. If you would like to stop receiving promotional materials from The Company or the affiliated brands you can opt-out of emailing lists by clicking the unsubscribe link at the bottom of a promotional email.
About Teenagers and Children
Children under the age of 13: Generally, we do not intend to collect personal information from individuals under the age of 13 without parental consent. We may, from time to time, offer a contest where the child under the age of 13 can enter in which case the personal information is used for purposes of administering the contest and determine a winner. If a child under 13 has provided us with personal information, without parental consent we ask that a parent or guardian of the child contact us to request that this personal information be deleted from our records. We will use reasonable efforts to delete the child’s personal information from our existing files. We encourage parents to talk to their children about their use of the Internet and the personal information they disclose to Web sites or otherwise.
We will use reasonable efforts to delete all contact and other personal information obtained from a teenager if a parent or guardian notifies us that they wish to withdraw consent for the collection of a teenager’s personal information.
07 • SECURITY
08 • ACCESS, CORRECTION & CONTACTING US
09 • LINKS TO OTHER WEB SITES
10 • PRIVACY STATEMENT CHANGES
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