(Last Updated: June 20, 2015)
Please note that [CLIENT] complies with the federal and provincial laws relating to the protection of personal information. You can find out more about these laws by visiting: (i) the website of the Privacy Commissioner of Canada located at www.priv.gc.ca; and (ii) the web site for the site for the privacy commissioner for your province or territory. The responsible handling of your personal information is our utmost concern.
In this policy, [CLIENT] describes the type of personal information that [CLIENT] collects through our Sites, what we use it for, the circumstances in which we disclose and transfer it and the rights that you have in relation to your personal information collected through our Sites.
1. Collection and storage of personal information
a) When you visit any Site
When any Site is visited, our servers temporarily store information about each access in a protocol file. The following data is recorded without you needing to do anything and stored by us until it is automatically deleted after no more than twelve months:
- the Internet Protocol address (IP) used to connect your computer to this Site,
- date and time of access,
- the name and Uniform Resource Locators (URL) of the retrieved data,
- the website from which this Site was accessed,
- your computer's operating system and the browser used by you,
- the country from which you accessed this Site, and
- the name of your Internet access provider.
By using any Site, you consent to the collection and use of this information by [CLIENT] and its use in aggregated form by [CLIENT] to: (i) operate and improve upon our Sites; (ii) enable connection to our Sites; (iii) to maintain system security and stability for our Sites; and (iv) for internal statistical purposes relating to the use of the Sites.
b) When you register a user account
You enter the following personal information to create your user account for our Sites:
- first name and surname,
- e-mail address, and
- user account password.
Further personal information (for example your gender) may be given voluntarily.
By using any Site, you consent to the collection and use of this information by [CLIENT] and its use in aggregated form by [CLIENT] to: (i) administer our Sites; (ii) operate our Sites (including user accounts); (iii) optimise our Internet offering in general; (iv) better tailor your experience with our Sites to you; (v) check the personal information provided for plausibility; and (vi) manage the contractual relationship we enter into with you, in relation to your user account and your use of the Site(s).
c) When you subscribe to our newsletter
If you expressly consented, [CLIENT] uses your e-mail address to regularly send you our newsletter. In the end of each newsletter a link is provided which you can use to unsubscribe from the newsletter at any given time. You can also unsubscribe from the newsletter by following the instructions set out in section 8.
d) When you use our contact form
You may use our contact form (accessible via each Site) to contact us. When completing the contact form, it is mandatory to provide the following personal data:
- first name and surname,
- address (street, number, postcode, town, country), and
- e-mail address.
If you use our contact form to complain, your phone number, the product description, the bar code number of the product(s) complained about need to be submitted.
By using our contact form, you consent to the collection and use of this information and any further information that you provide voluntarily (like organisation, country, when indicated phone number, order number or location of purchase) by [CLIENT] to respond to your contact request, and its use in aggregated form by [CLIENT] to improve upon our Site(s), products and customer service.
2. Passing on Data to Third Parties
We will only pass on your personal information to third parties if you have expressly permitted us to do so. The contrary shall only apply as far as [CLIENT] is required or permitted to do in order to comply with law (including in connection with a court order) or if it is necessary for the assertion of our rights, in particular for the assertion of claims arising from the contractual relationship between you and [CLIENT].
From time to time, [CLIENT] may engage service providers to provide certain limited services such as hosting a Site or providing insurance. [CLIENT] will only provide those service providers with the personal information they need to deliver the service for which they are retained. [CLIENT] will also require those service providers, through contractual means, to safeguard such information, maintain its confidentiality and not to use that information for any purpose other than providing the services for which they were retained. Please note that such services providers may not be located in Canada.
[CLIENT] may disclose personal information in connection with a refinancing or the reorganization of either business, the sale, assignment, or other disposal of all or part of either business or its assets, including for the purpose of permitting a prospective purchaser or business associate to conduct the due diligence required to determine whether to proceed with a transaction. If we assign or sell all or part of our business or assets, we will take reasonable steps to limit the assignee or purchaser to using and disclosing Personal Information for substantially the same purposes as described in this Policy.
By using any Site, you consent to the uses of your personal information described in section 2.
Cookies do not do any damage to your computer's hard disc and they do not transmit any of your personal data to us.
Most Internet browsers accept cookies automatically. You may, however, configure your browser so that no cookies are stored on your computer or so that you receive a warning whenever you receive a new cookie.
Deactivating cookies may mean that you cannot use all of the functions of our Sites.
4. Google Analytics
We use Google Analytics - a web analysis service provided by Google Inc. ("Google") - to continuously streamline and optimise our Sites for users. For this purpose, pseudonymised user profiles are created and stored on your computer as cookies ('cookies', see section 3). They include following information about your use of this Site is:
- browser type and version,
- operating system used,
- referrer URL (the site previously visited),
- host name of the accessing computer (IP address), and
- time of server request.
This information is transmitted to servers of Google Inc. in the United States and stored there. This information is used by [CLIENT] in conjunction with the analytics tools provided by Google to: (i) evaluate the use of our Sites; (ii) compile statistics and reports on website activities; (iii) to provide other services connected with the use of the Sites and Internet; (iv) for purposes of market research; and (v) further develop the Sites. This information is also transmitted to third parties by Google to the extent that this is prescribed by law or if third parties process the data for Google.
Google will not link this data to Google's other data. IP addresses are anonymised to prevent them from being matched (IP masking).
You may configure your browser to prevent cookies from being installed; but we would point out that in this case it may not be possible to use all of the functions of this website to the full extent.
You can prevent data collection by Google Analytics by clicking this https://tools.google.com/dlpage/gaoptout. An opt-out cookie will be placed on your device. While that cookie remains on your device, it will prevent any future data collection by Google Analytics.
5. Data Security and transfer
The transmission of information via the internet is not completely secure, therefore we cannot guarantee the security of your data transmitted to any Site; any transmission is at your own risk. [CLIENT] expressly disclaims all representations, warranties and conditions (whether express or implied) that any information transmitted to or by [CLIENT] over the Internet will be completely secure. Still, [CLIENT] uses appropriate physical, technical and organisational security measures to protect your data stored by us against manipulation, complete or partial loss and unauthorised access by third parties. Our security measures are constantly updated in line with technical developments.
You should close the browser window when you have finished communicating with us, especially if the computer is also used by other people.
6. Social Media Plug-ins
Facebook social plug-ins (in the form of "LIKE" and "SHARE" buttons) are used on our Sites to make the websites a more personal experience. This is a service offered by Facebook Inc. (1601 Willow Rd, Menlo Park, CA 94025, USA).
When you call up a page of any Site that includes such a plug-in, your browser creates an automatic connection with the Facebook servers. The content of the plug-in is transmitted by Facebook directly to your browser and embedded from there into the Site that you are visiting.
By connecting the plug-in, Facebook receives information that your browser has called up the corresponding page of our Site, even if you do not have a Facebook account or are not at present logged in to Facebook. This information (including your IP address) is transmitted direct from your browser to a server of Facebook in the United States and stored there.
If you are logged in on Facebook, Facebook is able to match your visit to any Site directly with your Facebook account. When you interact with the plug-ins, for instance by using the "LIKE" or "SHARE" buttons, the relevant information is sent directly to a Facebook server and stored there. The information is moreover published on Facebook and displayed to your Facebook friends.
Facebook may use this information for advertising and market research purposes and to make the Facebook pages more user-friendly. To this end, usage, interests and relationships profiles are created by Facebook, in order for instance to evaluate your use of our Sites with regard to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on our Sites and to provide further services related to your use of Facebook.
If you do not wish Facebook to match the data collected via our Sites to your Facebook account, you must log out of Facebook before visiting any Site.
To find out more about the purpose and scope of data collection and further processing and use of data by Facebook as well as your rights in this regard and how you can configure your account to protect your privacy, please refer to the Facebook data https://www.facebook.com/policy.php.
Pinterest social plug-ins (in the form of "Pin it" buttons) are used on our Sites to make the Sites a more personal experience. These social plugins are operated by Pinterest, Inc., (808 Brannan St, San Francisco, CA 94103, USA).
When you call up a page of any Site that includes a "Pin it" button, your browser creates an automatic connection with Pinterest's servers. The content of the button is transmitted by Pinterest direct to your browser and from there it is embedded in the Site.
By embedding the plugin Pinterest collects information, that your browser called up the corresponding Site, even if you do not have a Pinterest account or you are currently not logged in to a Pinterest account. This information (including your IP-address) is transferred by your browser directly to a Pinterest server in the United States where it will be stored.
If you are logged in with your Pinterest account and you click on the "Pin it"-button, Pinterest will collect the information that you called up the Site and may link your visit to your Pinterest account. If you do not consent to this, do not click on the "Pin it" button.
To find out more about the purpose and scope of data collection and further processing and use of data by Pinterest as well as your rights in this regard and how you can configure your account to protect your privacy, please refer to the Pinterest data privacy information https://about.pinterest.com/en-gb/privacy-policy-0.
Plug-ins (in the form of "tweet" buttons) by the short message network Twitter Inc. (1355 Market St, Suite 900, San Francisco CA 94103, USA) are integrated into the Sites. You can identify the tweet buttons because they display the Twitter logo. You can find an overview of information on the tweet button by clicking https://about.twitter.com/resources/buttons.
When you call up a page of any Site containing a tweet button, a direct connection is created between your browser and the Twitter server, and Twitter is informed that you have visited our Site from your IP address.
If you click on the tweet button while you are logged in to your Twitter account, you can link the content of our pages to your Twitter profile, which means that Twitter can match your visit to any Site to your user account with Twitter. If you do not wish Twitter to associate your visit to any Site to your account with Twitter, log out of your Twitter user account before visiting any Site.
We would point out that we, as the provider of the pages, have no knowledge of the content of the data transmitted or how it is used by Twitter. You can find out more information on this here https://twitter.com/privacy.
7. Right to information, correction, deletion of data
You may at any time request information about your personal information that [CLIENT] has stored and correct incorrect information or delete information. To make a request for access to, the correction of or the deletion of your personal information please contact [CLIENT] by one of the means set out below in the section on "Privacy support".
You may also at any time use the tools made available to you on the Sites to delete or correct information forming part of your user profile. You may also delete your entire user profile by sending us a request here.
Depending on the nature of an access request (for example, type and volume of information requested), a fee may apply to processing it.
Depending on what is deleted, you may no longer be able to participate in certain activities on the Sites.
[CLIENT] requires the consent of a parent or guardian before any child can register with any Site. Further, parents and guardians may: (i) review, edit, and delete information submitted to any Site by or on behalf of their child; (ii) choose to be notified when their child uses any Site to make changes to his or her personal information; and (iii) delete a child's personal information submitted through any Site using our account deletion tool.
8. Withdrawing consent to receive newsletter
You may unsubscribe from any [CLIENT] newsletter anytime by using the link provided at the end of the newsletter and following the instructions provided. You may also communicate a wish to unsubscribe by emailing [CLIENT] at info@[CLIENT].ca . Please type "UNSUBSCRIBE" in the subject line and set out the affected email address in the body of your email.
9. Method for Withdrawing Any Other Consent
If you wish to withdraw any consent (other than one related to newsletters), you may do so by emailing [CLIENT] at consumeraffairs@[CLIENT].ca . Please type "WITHDRAWAL OF CONSENT" in the subject line, and clearly describe the consent being revoked. Please note that by refusing to provide certain types of personal information or by denying or withdrawing consent to use or disclose personally identifiable information for purposes identified in this policy, you may be unable to use any Site or participate in certain activities on the Sites.
11. Effectiveness of the data privacy statement
12. Privacy Support
[CLIENT NAME AND ADDRESS]
Attention: Privacy Officer
Or click here to e-mail us.