Last Updated – June 2013
1. Reliure Concept’s Commitment to Privacy
2. What is “Personal Information”?
“Non-identifiable Information” is information that cannot be associated with, or traced back to, a specific person. Non-identifiable information includes: anonymous aggregated information, information about your visits to our Websites which is not linked to you, information about your computer’s operating system and web browser software. Your computer and its operating systems, browsers, and memory contain vast quantities of transaction data and records of your use of it. This Personal Information could be gleaned from these systems by outsiders if you do not take steps to protect your system. It is our policy not to associate this information with customers, even though we verify some kinds of technical information to ensure that our Websites are optimized to serve our customers.
When you interact with our Websites, we may use a browser feature, known as a “cookie”, to verify non-identifiable information about visitors to our Websites and measure visitor traffic patterns. We do this to maintain the best possible Websites. A cookie is a small computer file. When you first visit our Websites, the Website manager may have implemented a program that creates a small computer file stored on your computer’s hard drive. We ensure that the minimum information required is placed in the cookie only so that we can recognize returning Website visitors. The cookie does not contain Personal Information and we will not combine information in the cookie with Personal Information that would enable us to identify you individually. On subsequent visits to the Website, our server communicates with your computer, reads the cookie, recognizes and confirms that you are a returning visitor. Our server uses this information to provide you with a “short cut” that facilitates the quickest, most efficient and best possible Website experience.
Most browser software allow you to delete cookies. You should consult your Internet service provider for information on how to delete cookies. This may interfere with our ability to personalize your experience at our Websites and be recognized, or may slow down performance.
3. Collection and Use of Personal Information
We collect Personal Information in the following circumstances:
- When you join a club or become a member through this Website, by regular mail or by using SMS text messaging;
- When you enter a contest or other promotion through this Website, by regular mail or by using SMS text messaging;
- When you subscribe to our e-mail newsletter(s);
- When you respond to online questionnaires;
- When you participate in interactive online activities (including games, Kid’s Gallery, chat rooms or bulletin boards);
- When you shop online at our Websites; or
- When you contact us to make requests or comment on our services.
We take particular care in the collection of Personal Information from children under the age of 13. We do not require Personal Information from children to obtain access to, surf or view the content on any of the Websites of RELIURE CONCEPT Inc. However, certain Personal Information may be required for a child to participate in one of our contests or promotions. In these circumstances, we may collect the first and last name (or user name) of the child, the child’s e-mail address, home address, birth date and gender, as well as the name, home address, e-mail address and telephone number of the child’s parent or guardian.
We only collect the Personal Information from a child under the age of 13 that is reasonably necessary for the purposes of verifying the child’s age, administering the child’s participation in the contest or promotion and, if the child wins a prize, contacting the child’s parent or guardian. We will not use, maintain or disclose this Personal Information for any other purpose.
RELIURE CONCEPT Inc. strives to ensure that our Internet experiences for young people are safe and fun, and we urge parents and guardians to take an active role and explore where their children are roaming on the Internet.
This Website may include links to third party websites. These third parties have separate and independent privacy policies. Any personal information you share with these third parties through their websites will be administered under their privacy policies. RELIURE CONCEPT Inc. has no control over third party privacy policies and therefore has no responsibility or liability for the manner in which third parties may collect, use or discloses and otherwise treat your personal information.
Further details regarding our collection and use of Personal Information is set out below.
Clubs or Memberships
Many of our sites offer you the opportunity to become a member or belong to a club, so that you can participate on a regular basis in games, bulletin boards, contests and other activities offered on the site. We do collect Personal Information when you join in accordance with the following principles:
- We collect only the information necessary for the activities offered; and
- Access to our activities is never conditional upon you providing more Personal Information than is necessary for such activities.
When you enter a contest, you may be required to provide the following Personal Information: your name, address or province of residence, e-mail address, telephone number and, where an age eligibility requirement applies, your age range. This Personal Information is collected solely for the purpose of identifying and communicating with contest prizewinners. Personal Information from non-winners is destroyed, in accordance with applicable legal requirements. When an affidavit of eligibility and release is sent to the prizewinner’s parent or legal guardian, it must be signed and returned before the prize can be awarded. If the release is not returned within the specified time period, the winner forfeits the prize and an alternative winner may be chosen.
From time to time, we may request your feedback on an activity, product or service that we offer or provide or on content on our Websites. We ask for your name and e-mail address when you are providing us with feedback so that we may reply to you, but you always have the option of providing us the feedback without sharing this information.
Other Online Activities
When you visit our Websites and participate in other online activities, we may collect information such as your name, nickname, age category, preferences, opinions, etc. Whether or not you are required to join a club or become a member of the site to participate in these activities we always comply with the principles stated in subsection (a) above with respect to memberships or clubs.
You must be 18 years of age (or any other applicable minimum age in your province of residence) or older to make an online purchase on our Websites. Our shopping Websites collect only basic ordering information, including your name and shipping address, telephone number and e-mail address, and credit card number. This is for the sole purposes of processing and delivering products or services that you buy online. We do not share this information outside RELIURE CONCEPT Inc., except with our approved agents, who help us to process your order. All of our approved agents are required to provide a level of privacy protection comparable to that provided in this policy and are not permitted to use your information for any other purpose, such as to market to you.
Contacting Customer Service
If you telephone, write or e-mail us to comment on one of our services or Websites, we will retain the information for our records during a certain period of time. Disclosure of your name and Personal Information is voluntary in this circumstance.
4. Disclosure of Personal Information
We will not disclose your Personal Information unless required by law. We must provide your Personal Information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. We use your Personal Information for internal purposes only. We do not sell, rent or trade in Personal Information. We may transfer information to third parties who need such Personal Information to provide services on behalf of RELIURE CONCEPT Inc. Any such service providers are contractually bound to maintain the confidentiality of such transferred Personal Information and are prohibited from using the Personal Information for any other purpose. Your consent to our use of Personal Information can be withdrawn at any time by following the directions at the end of this policy. We will obtain your consent before using your Personal Information for any purpose other than these above. Once your Personal Information is no longer required for the purposes above, it will be deleted.
5. Security and Safeguards
We know how important privacy is to you. That is why we protect and safeguard your Personal Information. Our security policies govern the protection of the information on our information systems, the way we protect our Websites from malicious attack, and the way in which we dispose of information no longer needed. We screen and train our employees carefully to ensure that they will always have the highest regard for you and your privacy, and we restrict access to your Personal Information to only those with a need to know.
We make best efforts to keep our servers in a safe environment and protect our information technology infrastructure from abuse. Security on the Internet is a continuously evolving problem and we hire experts who keep up with the latest trends. If you receive any electronic communication which purports to be from a member of the RELIURE CONCEPT Group that you have any questions or concerns about, please contact us. Spam, improper use, and pirating of domain names and email addresses is a growing problem, so we appreciate hearing about incidents in order that we may investigate them and provide you the best customer service.
6. Facebook Commenting
When a user chooses to log in to comment using their Facebook account, we request access to the information indicated in the Facebook acceptance screen and described below.
Users can click “Allow” to login using their Facebook account, or click “Don’t Allow” to close and return to the login options. If the user chooses not to login using Facebook, they can login using their Toogood Cases account — or create one if they don’t have one already.
When a user chooses to log in using their Facebook account, we request access to the following:
“Access my basic information: Includes name, profile picture, gender, networks, user ID, list of friends. And any other information I’ve shared with everyone.”
Access to basic user information is required by Facebook in order to use the Facebook login functionality. We will display the user’s name, and potentially their profile picture in future, to identify them as the person who posted the comment.
“Send me e-mail: The Toogood Cases may e-mail me directly at [user’s e-mail address]”
We require an e-mail address to match the user’s Facebook account with The Toogood Cases’s user database. We may contact the user directly regarding their use of the commenting feature, or to notify them if their comment might be used on our site. Unless the user has “opted in” elsewhere on the website, we will not send the user marketing or promotional material.
“Post to Facebook as me: The Toogood Cases may post status messages, notes, photos, and videos on my behalf”
We require this access to allow users to send comments made on our website to their own Facebook pages, allowing them to share links with their friends. Any postings sent to users’ Facebook pages are user-generated: We will not post promotional, informational or other unexpected messages. After allowing access for initial login, a user may Remove this permission on Facebook, under Privacy Settings | Apps and websites | Edit settings.
“Access my profile information: Activities, Interests, Birthday, Hometown, Current City”
This data will be used to target content and advertising, allowing us to display information on our website that is relevant to the user’s location, interests and age.
Services that use Facebook features are developed in accordance with the Facebook Platform Policy for Developers.
7. Contact Us With Concerns, to Update Your Personal Information, to Opt Out or To Complain
We have tried to anticipate and meet all of your expectations with respect to the treatment of your Personal Information and the privacy of your online experience with us. If you have any concerns or questions, please contact us at the address below. This is the address to contact if you:
Have questions or concerns about our treatment of your Personal Information;
- Wish to update or access your Personal Information;
- Want to withdraw your consent to the collection and use of your Personal Information, or the information of your child if you are a parent or guardian; or
- Wish to cancel an on line newsletter subscription.
Please contact:Jean-François Demers General Manager Reliure Concept inc 1390A, Newton Boucherville, Quebec Canada J4B 5H2 Phone : 450.655.2183 # 226 e-mail : email@example.com
Reference to RELIURE CONCEPT Inc. includes the corporate office and all the subsidiaries and all the business units controlled or operated by RELIURE CONCEPT Inc.