Effective date: October 19th 2022
- the types of personal information we collect;
- when such collection occurs;
- how we use and share the personal information we collect;
- the steps we take to ensure your personal information is safeguarded appropriately; and
2. Definition of Personal Information
Our products and services do not address anyone under the age of 19. We do not knowingly collect information from anyone under the age of 19. If you believe we may have collected information about your children or about you and you are under 19, please contact us as indicated in the “Contact Us” section so that we can endeavour to delete it.
3. Categories of Personal Information Collected
We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. Depending on your interaction with us, we may collect:
- Personal identifiers, such as name, postal address, phone number, email address, account information, username or Internet Protocol (IP) addresses, signatures;
- Payment information, such as credit or debit card number when you make purchases;
- Professional or employment-related information and other information you submit to us when applying for an employment opportunity, which may include some of the information described above, as well as letters of motivation, your resume, references and any additional information provided by you in an application;
- Internet or other electronic network activity information (i.e. technical information when you visit our websites or use our mobile applications), including when you log in to use our products and services. This information is collected via automated means, such as cookies, authorized token, web beacons and similar technologies, and may include your IP address, device ID, browser type, data about the web pages you visited on our websites, time and duration of a visit, information about your location, your language preferences; and
- Account activity, including any purchase completed, comments and reviews, wishlist and any other information related to your preferences and products.
4. Collection of Personal Information
We will generally collect personal information directly from you when you purchase a product, browse a Site or interact with us directly, as deemed necessary for the purposes defined in Section 5 below.
a. Directly from you
We may collect your personal information directly from you such as:
- when you purchase a product in stores or on our Sites or make inquiries regarding your purchases or products, we may collect information about the transaction, payment or shipment (including information about the recipient of such shipment, if applicable);
- when you contact us or send us questions, comments, suggestions or complaints, we may collect contact information and information about your inquiry that is necessary in order to address it or to respond to you;
- when you apply for a position, we may collect contact information and other information to process your application for employment;
- when you create or access an account on our Sites, we may collect information to identify you;
- when you use (and install, when applicable) our Sites and/or applications, we may collect information about how you use the Sites and where you are located, as further discussed below; and
- we may collect any other personal information you voluntarily provide to us in connection with any other matter.
b. Through our website or other technologies
We or our service providers, that help us maintain and operate our websites and mobile applications, may also automatically collect the following information relating to your access to and use of our website and applications through cookies (small data files stored on your device used to access and use our Sites), Web beacons (small transparent images used to track Sites visits and effectiveness of advertising) and other similar technologies: your domain name; your browser type and operating system; your type of computer or mobile device; pages you view; links you click; your IP address; the length of time you visit or use the service, and how you use the service. However, please note that cookies and beacons might be necessary to access or use certain features of our Sites.
We may also collect information you share regarding Glenn’s on social media such as Facebook and Twitter.
We may also be collecting information about your approximate physical location when you use a mobile device to access our Sites. If you do not want us to collect such information, please adjust or modify the settings of your mobile device accordingly.
Please be aware that we may use cameras in certain of our stores to protect our rights, property and safety and those of our employees, customers and the public and in order to look for ways to improve our customers’ experiences. We do not use these cameras to identify people except when reasonably necessary for these purposes or as required by law. Where this is applicable, signs will be posted to indicate that cameras are in use.
5. Usage of Personal Information
We will generally use your personal information as part of our normal business operations in order to provide you with our products and services, in our stores or through our Sites, and to support our business, for research and development purposes, for marketing purposes or otherwise, with your consent or as permitted or required by law:
a. General business purpose
More specifically, we may use your personal information for the following business purposes:
- to process your purchases and related transactions;
- to provide customer service and to respond to your inquiries or requests;
- to elaborate and improve our product offerings and our services;
- to manage and improve our customers’ experiences and our Sites;
- to monitor, analyze and assess the access and use of our Sites, including the registration and authentication of your account, if applicable;
- to customize the content of our Sites and advertising;
- to help you locate nearby stores;
- to protect our rights, property and safety and those of our employees, customers and the public;
- to detect and prevent fraud;
- to maintain appropriate records for internal administrative purposes, including for staffing and management of personnel; and
- to comply with legal requirements.
b. Research and development purpose
We may use personal information to understand and assess your interests and changing needs with a view to improving our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our websites. For instance, we may use third-party web analytics services, such as Google Analytics, to help us analyze how visitors use our websites. When required by law, we will use anonymized information for these purposes.
c. Marketing purposes
We may use your personal information to provide you with personalized content and services, such as tailoring our products and services, our digital experience and offerings, and deciding which offers or promotions to show you on our digital channels.
We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online support services) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see “Your Privacy Rights“.
6. Retention of Personal Information
Please note that we will only retain your personal information for as long as reasonably necessary for the above purposes or as required by law. Once no longer required, your personal information will be securely destroyed or anonymized, in compliance with applicable laws.
7. Sharing of Personal Information
We shall not disclose or share your personal information without your consent to any company or person other than as authorized by law or as follows:
- with service providers who are assisting us with respect to any of the purposes stated in Section 5 above (who require such information to perform their services for us, it being understood that they will only be permitted to use the information as part of the performance of their work for us or when the disclosure of your information is required by law and that such third parties will have appropriate privacy standards in place;
- if we believe that the disclosure of personal information is required by law;
- if we believe that the disclosure of personal information will help us protect our rights, our property and our safety and those of our employees, customers and the public;
- if we believe that the disclosure of personal information is necessary in the investigation of suspected or actual illegal activity or in response to a request by law enforcement authorities;
- if such disclosure would be in a way that it would not directly identify you, such as through aggregate information as mentioned in Section 1 above; and
- when required in the context of a prospective or completed business transaction, such as a transfer of assets or shares or merger, in accordance with applicable legal requirements. For example, we may make your personal information available to advisors or (potential) buyers of our business if necessary for concluding the transaction and continuing operating the business.
8. Your Privacy Rights
You have choices about the way Glenn’s handles your personal information.
a. Changing your communication preferences
You can always choose not to receive marketing or promotional messages from Glenn’s by email by clicking on “unsubscribe” in any email you receive.
Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you important product information, service notification or recall). In addition, it may take up to ten (10) business days to register a change of preference across all our records.
b. Changing your browser settings on your device
We use technology to enhance your experience and present you with offers, including personalised advertising. Through technologies such as cookies, our websites recognize you when you use or return to them and can provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our websites.
Please refer to your browser instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device.
c. Withdrawal of consent
The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the product or services available to you. In some circumstances, legal requirements may prevent you from withdrawing consent and/or we may be required to retain some of your personal information as detailed in section 6.
9. Safeguards and Data Governance
We maintain policies and practices which ensure the protection of your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we implement a combination of measures to protect your personal information.
10. Cross-Border Transfers of Personal Information
Your personal information may be transferred, stored, accessed, or used in a jurisdiction outside your jurisdiction of residence (for example, outside your province or outside Canada) in connection with our use of third-party service providers engaged by us. We engage these third-party service providers to assist us in providing our services to you; for example, in order to process payment, fulfil product orders, provide e-commerce functions, or manage our communications with you.
We use our best efforts to ensure that all of our third-party service providers take reasonable security measures to protect your personal information (this includes technical, administrative, and physical safeguards to protect your personal information). We use our best efforts to ensure our service providers only use your personal information for authorized purposes we have made known to you or which are otherwise permitted by applicable law.
Where personal information is located outside of your province of residence or outside Canada, it is subject to the laws of that jurisdiction which may differ from those in your jurisdiction and any personal information transferred to another jurisdiction will be subject to law enforcement, regulatory, and national security authorities in that jurisdiction. Subject to these laws, we will to the best of our abilities use contractual measures to maintain protections that are at least equivalent to those that apply in Canada.
11. Accessing and Correcting your Personal Information
You may be entitled to access your personal information and request the rectification information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws.
Depending on the law applicable in the jurisdiction where you reside and subject to legal or contractual restrictions, you may also be entitled to:
- request that we stop or restrict processing your personal; and
- obtain a copy of the personal information we collected from you.
To submit a request, please contact us in writing using the relevant contact information listed in the “Contact Us” section below.
12. Contact Us
To ensure that your personal information is accurate, complete and up-to-date, you may contact us or log into your account (if applicable) if any changes or modifications are required. You may also send us a written request if you wish to access the personal information we have collected about you. Please be advised that in order for you to modify, access or review your personal information, we may ask you to provide us with sufficient identification.
In all cases, we will generally attempt to answer your request within thirty (30) days or we will advise you if we require a longer response time.
Attn: Privacy Officer