We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information. For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us (“Applicable Privacy Laws”). We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
2. Collection and Use of Personal Information
We collect non-personal information through our Website. The types of information we collect depend on the nature of your interaction with us. Non-personal information does not identify you as an individual. For example: • we may collect certain non-personal data when you visit our Website, such as the type of browser you are using or the referring URL; or • we may collect and summarize customer information in a non-personal, aggregate format for statistical and research purposes. We may, for example, summarize our data to determine that a certain percentage of Deal purchasers are male, aged 18 to 25. You may choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the product, service, or information that you requested.
3. Use of Personal Information
We may use your personal information for a number of different business purposes, for example to: • provide customer support to assist you with your questions or complaints; • conduct surveys in order to improve our services; • measure and improve the effectiveness of our Website or our marketing endeavours; • detect and protect against fraud and error; • track and analyze your purchases and preferences to better understand your product and service needs and eligibility; and • for other purposes as described in this Policy. We will not collect, sell, distribute or use personal information for any other purposes without your further consent, as required by law or as authorized by Applicable Privacy Laws.
4. Your Consent
We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection. (a) Express Consent Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications. (b) Implied Consent Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, when you provide us with your email address in the course of contacting customer suppor. (c) Withdrawing Your Consent You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your information. We will accommodate your request subject to legal and contractual restrictions related to your transactions.
5. Information We Collect Automatically
In some cases, we automatically collect certain information. (a) Our Website When using our Website, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our Website, the Internet address of the Web site from which you linked directly to our Web Site, the operating system you are using, the sections of the Web Site you visit, the Web Site pages read and images viewed, and the content you download from the Web Site. This information is used for Web Site and system administration purposes and to improve the Website. (b) Cookies The Web Site uses "cookies", a technology that installs a small amount of information on a Web Site user's computer to permit the Web Site to recognize future visits using that computer. Cookies enhance the convenience and use of the Web Site. For example, the information provided through cookies is used to recognize you as a previous user of the Web Site, to offer personalized Web page content and information for your use, to track your activity at the Web Site, to respond to your needs, and to otherwise facilitate your Web Site experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Web Site and your ability to access certain features of the Web Site or engage in transactions through the Web Site. (c) Web Site Tracking Information We may use web beacons or pixel tags to compile tracking information reports regarding Web Site user demographics, Web Site traffic patterns, and Web Site purchases. We may then provide these reports to advertisers and others. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes we may link tracking information with personal information voluntarily provided by Web Site users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Policy. (d) Links to Other websites Our Web Site may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.
6. Supplementing Information
From time to time we may supplement information you give us with information from other sources, such as information validating your address or other available information you have provided us. This is to help us maintain the accuracy of the information we collect and to help us provide better service.
7. Disclosure and Sharing of Your Information
We do not sell or license your personal information to any other party. However, in the normal course of business we may share some of your personal information with our affiliates and with third parties acting on our behalf or as permitted or required by Applicable Privacy Laws. (a) Service Providers We may use third party service providers (for example, web hosting providers, data management providers and/or payment processers) to manage one of more aspects of our business operations, including the processing or handing of personal information. When we do use an outside company, we use contractual or other appropriate means to ensure that your personal information is used in a manner that is consistent with this Policy. Some of these operations may result in personal information collected by us being stored or processed in the United States and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA PATRIOT Act and other applicable laws of the United States. (b) Information Shared Amongst Our Affiliates, Subsidiaries and Divisions We may share personal information gathered on our Website with and amongst our corporate subsidiaries, affiliates or divisions for internal business purposes in accordance with this Policy. If we do, we will ensure that your information continues to be used only in accordance with this Policy and your expressed choices. (c) Legal Disclosure We may disclose your information as permitted or required by law. For example, we may be compelled to release information by a court of law or other person or entity with jurisdiction to compel production of such information. If we have reasonable grounds to believe information could be useful in the investigation of improper or unlawful activity, we may disclose information to law enforcement agencies or other appropriate investigative bodies.
8. Security of Personal Information
The security of your personal information is a high priority for us. We maintain appropriate safeguards and current security standards to protect your personal information, whether recorded on paper or captured electronically, against unauthorized access, disclosure, or misuse. For example, electronic records are stored in secure, limited-access servers; we employ technological tools like firewalls and passwords; and we ensure our employees are trained on the importance of maintaining the security and confidentiality of personal information. Reasonably secure methods are used whenever we destroy personal information. For example, we currently use SSL encryption with a 2048 bit digital certificate.
9. Requests for Access to and Correction of Personal Information
Applicable Privacy Laws allows any individual the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist the individual with the access request. This includes: (a) identification of personal information under our custody or control; (b) information about how personal information under our control may be or has been used by us; and (c) the names of any individuals and organizations to which the individual’s personal information has been disclosed. We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to. In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
10. Removal of Your Information
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.
11. Concerns or Questions regarding our Compliance
Questions or concerns regarding our compliance with this Policy may be directed to the Privacy Officer, Kim Kaplan, at . If an individual is not satisfied with our Privacy Officer’s response to their question or concern they may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.