Privacy policy

Introduction

We are committed to safeguarding the privacy of our website visitors; in this Privacy Policy we explain how we will treat your personal information.

Collecting personal information

We may collect, store and use the following kinds of personal information:

  1. information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
  2. information that you provide to us when registering with our website (including your email address);
  3. information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
  4. information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through our website (including your name, address, telephone number, email address and card details);
  5. information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
  6. any other personal information that you choose to send to us.

Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

Using personal information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

We may use your personal information to:

  1. administer our website and business;
  2. enable your use of the services available on our website;
  3. send you goods requested through our website;
  4. send you email notifications that you have specifically requested;
  5. provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
  6. deal with enquiries and complaints made by or about you relating to our website;
  7. keep our website secure and prevent fraud; and
  8. verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).

We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

Disclosing personal information

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors as well as trusted business partners insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (including our subsidiaries, affiliates, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

  1. to the extent that we are required to do so by law;
  2. in connection with any ongoing or prospective legal proceedings;
  3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
  4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
  5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

Retaining personal information

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to Section 5.2, we will usually delete personal data falling within the categories set out below at the date/time set out below:

  1. All personal data will be deleted twelve months after the completion of the promotion.

Notwithstanding the other provisions of this Section 5, we will retain documents (including electronic documents) containing personal data:

  1. to the extent that we are required to do so by law;
  2. if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
  3. in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Security of personal information

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password and firewall-protected) servers.

All electronic financial transactions entered into through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You acknowledge that your information may be stored, shared or disclosed outside of Canada.

Upon written request, we will inform individuals of the existence, use, disclosure and retention of their personal information and provide access to, or a copy of, that personal information, unless doing so would be prohibitively costly, the personal information contains references to other individuals, the personal information cannot be disclosed for legal, security, or commercial proprietary reasons, or the personal information is subject to legal privilege.

Our details

This website is owned and operated by Gristmill Marketing.

We are registered in Canada as “The Gristmill Marketing Company Limited”

Our principal place of business is at 85 Dickson Hill Road, Markham, Ontario, Canada L3P 3J3

If you have any questions about our management of personal information, this Privacy Policy or our compliance with this Privacy Policy, or would like to make a request for access to your personal information, you can contact us by post, using the postal address given above or by email, using info@hapromos.ca, Attention: Privacy Manager.

We may modify this Privacy Policy from time to time without notice.