Last updated 24 Jan 2022
In general, you may visit our Site without providing any personal information. However, in order to use certain features of our Site, we may need to collect your personal information. For example:
We, our service providers and third party advertising partners also collect information about Site visitors automatically using cookies and other tracking technologies. See Cookies, tracking technologies and interest-based advertising below.
We generally use the personal information we collect to provide the product, service, feature or information you have requested and for our reasonable business purposes, including:
We, our service providers and third-party advertising partners use technologies that automatically collect information about Site visitors.
We automatically collect information about how you access, navigate and leave our Site, including the website you came from before visiting our Site, what browser type and operating system you are using, the internet protocol (IP) address you are accessing the Site from, your mobile device ID or Advertising ID if you visit our Site from a mobile device, the pages of our Site that you are navigating through, the date and time of your visit, how long you spend on our Site or certain pages of our Site, and what website you go to after visiting our Site. This information may be used to determine how many visitors visit our Site or certain areas of our Site, how long they remain on our Site, whether they use the hyperlinks we provide or respond to advertising and to tailor our advertisements to you. We may share this information with partners who referred you to our Site, and with advertising partners, who may use the information to optimize the traffic they send to us and for delivering targeted ads to you when you visit other websites.
We, our service providers and third-party advertising partners collect information about Site visitors using cookies and other tracking technologies (including browser cookies, pixels etc). We use these technologies to remember your preferences and facilitate your navigation of our Site. We and our service providers and third-party advertising partners also use these technologies to track your activities on our Site and other websites, including the websites and web pages that you visited, the ads or content that you clicked on, any items you may have purchased and the search terms you used, in order to deliver tailored advertising to you. We may also share a hashed or encrypted version of your email address or telephone number with advertising partners so that you may be served with tailored advertising on our websites or other third party websites. These advertising partners are not permitted to use your hashed or encrypted email address for any other purpose.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. If you don’t want us to share your hashed or encrypted email address with advertising partners, simply opt-out of our promotional communications. See Your Choices below.
At this time, we do not respond to browser “do not track” signals. However, you may also opt-out of network advertising programs that track your activities across multiple websites to deliver personalized advertising content to you. Please visit Digital Advertising Alliance of Canada Opt-Out Page, European Interactive Digital Advertising Alliance, NAI Opt-Out Page and the Ad Choices Opt-Out Page.
We use Google Analytics to help us understand how our Site visitors use the Site, and as well as certain features of Google Analytics Display Advertising to advertise online, sell advertising and to develop content. You can opt out of Google Analytics and customize Google’s Display Network ads. Please visit Google’s Ad Settings and Google Analytics Opt-out Browser Add-on. Please visit How Google uses data when you use our partners’ sites or apps for a description of how Google uses information sent by our browser and for ways you can control the information sent to Google.
We may share information we collect about you in the following circumstances.
We share information with our third-party advertising partners as described in the Cookies, tracking technologies and interest-based advertising section above.
We may use service providers (including affiliates acting in this capacity) to provide services to us or to you on our behalf. For example, our service providers may host our Site, analyze data collected from our Site, provide customer service on our behalf, administer our promotions, facilitate and process transactions and payments, provide marketing or promotional assistance, distribute emails and other communications, post our advertisements (including online through targeted advertising campaigns), and collect your feedback on our Site and advertisements. We share your personal information with our service providers solely for the purposes of providing services to you and to us. They are not permitted to use your personal information for other purposes. Some of our service providers are located outside of Canada, including in the United States. While your personal information is located outside Canada it will be subject to legal requirements applicable to our service providers, for example, lawful requirements to disclose personal information to national security agencies or government authorities in certain circumstances. For EU residents see Users from the European Union section below.
Aggregate or de-identified information
We may use your personal information to create aggregate statistics and de-identified data. We may use, share and sell this information for any purpose.
With your consent
We may disclose your personal information in other circumstances where permitted or required by law or other legal process. For example, we may disclose your personal information: (a) to collect a debt owed to us; (b) as necessary to comply with a subpoena, warrant, court order or other legal process; (c) if disclosure is requested by an investigatory body, law enforcement official or governmental authority which has lawful authority to request the disclosure of the information in respect of an investigation or other legal process; or (d) if we have reasonable grounds to believe that the information relates to a breach of an agreement or contravention of a law, or to protect the personal safety of our users or defend our rights or property.
Personal information is maintained on our servers (or those of our service providers). In an effort to protect your personal information against unauthorized access or disclosure. For example, accounts you create on our Sites are password protected. In identified parts of our Sites, we use SSL-encryption to protect data transmissions. We limit access to personal information to employees, representatives and service providers who require access in connection with their job responsibilities. Please note it is not possible to transmit data with absolute security over the internet, and we cannot and do not guarantee the security of your personal information.
Our Sites are not directed to and we do not knowingly request or collect personal information from children – persons under 13 years of age, or another age if required by applicable law – without prior verifiable parental consent. If we become aware that we have unknowingly collected personal information about a child without verifiable parental consent, we will delete this information from our records or, if that is not reasonable, we will take reasonable available steps to de-identify the information.
We encourage you to keep your personal information accurate and up to date. You can access and correct the information in your account or public user profile by logging in to your account or profile and making the necessary edits.
You can request access to or correction of your personal information in our custody or control by contacting us as set out below. We may take reasonable steps to authenticate your identity before providing you with access to your personal information or making corrections. Please also note that in some cases we may not be able to provide you with the personal information you have requested (for example, if the information is subject to solicitor-client privilege or contains personal information of others that cannot be severed).
PersonalCRMs is the data controller for processing of information defined as personal data under applicable data protection law (“Personal Data”).
Your personal information will be retained for as long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations, legal requirements and the duration of your use of our Site and receipt of our services.
Legal Basis for Data Processing
In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our website.
International Transfers of Personal Data
Our personnel and some of the third-parties to whom we disclose Personal Data (as set out above) may be located in countries outside of the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and, where required under law, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Data remains protected and secure.
You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.
If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, if you consider that our processing of your Personal Data infringes applicable law.
You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions included in each communication and/or by selecting your communication preferences in an account or profile.
You may be able to control the information we received from your device or from third parties (such as social media networks) by changing your device settings, browser settings or privacy settings.
You may withdraw your consent to our collection, use or disclosure of your personal information, subject to contractual or legal restrictions and reasonable notice. However, if you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to provide you with certain products or services.
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