- General principles
- Guiding principles
- Third-party social media
- Web analytics
- Responding to your concerns
1. GENERAL PRINCIPLES
Select Wine Merchants Ltd. (“Select Wines“, “we”, “us”) is aware of your legitimate concerns about privacy and is fully committed to maintaining the integrity, confidentiality, security, and accuracy of your Personal Information in accordance with applicable privacy legislation and best industry practices.
By using the Select Wines website and providing us with your Personal Information, you agree that Select Wines use the latter in accordance with the Privacy Act and this Policy. For purposes of this Policy, “Personal Information” means any information about an identifiable individual within the meaning of section 3 of the Privacy Act.
2. GUIDING PRINCIPLES
Our Policy rests on the following six guiding principles:
2.1 Identifying the purposes of use
The nature and scope of the Personal Information we need depends to a great extent on which products, solutions or services are of interest to you. Select Wines will collect Personal Information only in relation to its operating programs or activities for business purposes in order to:
- Identify you i.e. Personal Information such as your name, telephone number, personal address, date of birth, gender, and password helps us to identify you.
- Provide ongoing services i.e. Personal Information about you and/or your business allows us to communicate with you and respond adequately and promptly to your enquiries about our products, solutions and services.
- Protect you and us against errors and fraud i.e. All your activities are electronically logged, so that Select Wines can review them in case of any suspicious activity. Select Wines uses software to monitor site traffic and to detect unauthorized attempts to upload, change information, or otherwise cause damage.
- Promote our products, solutions and services to you i.e. When you specify your consent on any online Select Wines subscription or registration form, Select Wines may, from time to time, use your email or regular mailing address to send you information on Select Wines’ products, solutions and services, trends, business opportunities, or other topics and events of current interest. In order to do so, Select Wines may also collect the information that you provided on the subscription or registration form, such as your name, address, telephone and fax numbers, and your language of preference.
- Comply with legal, security, processing, and regulatory requirements
- Allow you to apply for jobs online
2.2 Obtaining your Consent
Your Consent can be express or implied (“Consent”). It can be expressed in writing, or electronically when, for example, you authorize us to check your employment.
Your Consent can be implied through your action or inaction. For instance, when you file an application, we conclude that you have consented to the collection, use, and disclosure of the Personal Information it contains for the intended purposes. The same conclusion may be drawn when you use one of our products, solutions or services.
Your Personal Information will be viewed by Select Wines employees or representatives for the purposes of their work or for which it was given, as outlined in section 2.1.
In some circumstances, Select Wines may collect, use, or disclose Personal Information without your Consent for legal, security, or processing reasons, or when it is impossible to obtain your Consent in cases contemplated by applicable privacy legislation. Examples of such circumstances include compliance with applicable laws or court orders, the protection of the public interest, Select Wines’s rights, administration of contests and fulfillment of any prize requirements, fraud detection and prevention, the use of Personal Information emanating from a third party, and the collection of overdue accounts.
You can withdraw your Consent at any time, provided Select Wines is given reasonable notice and there are no legal or contractual requirements preventing this.
2.3 Limiting collection, use, and disclosure of Personal Information
Select Wines will not, without your Consent, collect, use, or disclose Personal Information except for the purposes identified or for a use consistent with those purposes or as otherwise required or permitted by applicable law. With your Consent, Select Wines may obtain Personal Information from third parties, including through credit checks, or credit bureaus.
Select Wines may transfer (or otherwise make available) Personal Information to third parties who provide services on our behalf. For example, we may use service providers to process Personal Information, authorize and process payments, or host our website. Personal Information may be stored and processed outside of Canada, including the United States, by our third-party service providers. Our service providers are not authorized to use or disclose your Personal Information for any purpose other than providing the services on our behalf or as otherwise required by applicable law.
Select Wines is subject to various legal and business requirements in dealing with document retention, including electronic documents such as emails. Select Wines will retain the Personal Information only for such periods of time as may be prescribed by applicable laws and regulations, as deemed necessary for the identified purposes. In accordance with legal requirements and applicable guidelines, Select Wines will destroy, erase, render anonymous, or otherwise dispose of Personal Information after such period of time.
2.4 Providing access and accuracy
Subject to legal requirements provided by the Privacy Act or the Access to Information Act, Select Wines will respect your right of access to your Personal Information by informing you of its procedures and requirements for responding to your request for access. Select Wines will act diligently to give you access, at minimal or no cost wherever possible. In certain exceptional circumstances, Select Wines may not be able to give you access to your Personal Information. For example, some Personal Information banks may contain references to other persons or to Select Wines’s proprietary information, or be covered by solicitor-client privilege.
You can challenge the accuracy of your Personal Information and request corrections if you believe there are errors or omissions. You may also require in certain circumstances that an annotation be attached to your Personal Information reflecting any correction requested but not made, or that such annotation or correction be notified to certain individuals.
Select Wines will take all reasonable steps to ensure Personal Information used on an ongoing basis is as accurate, up-to-date, and complete for the purposes in which it was collected; Select Wines will rely on you to inform it of any required corrections.
2.5 Responding to your privacy concerns
Select Wines will respond to your questions and investigate diligently any complaints with respect to your Personal Information.
2.6 Complying with applicable privacy legislation
Your and Select Wines’s rights and obligations regarding privacy are governed by applicable privacy legislation in Canada. The application and interpretation of this Policy and of our guiding privacy principles are subject to and will comply with such legislation.
A cookie is a small text file containing certain pieces of information that a website server creates and puts on your computer. Select Wines uses persistent cookies to enable us to better serve you when you visit our site.
Persistent cookies are written or stored on your hard drive until the expiry date (maximum two years). Select Wines’s persistent cookies are used, for example, to retain information that you provided so that the Select Wines website can be personalized accordingly, or to determine if a certain user has previously completed one of our surveys, so that he/she will not be surveyed again.
The cookies used by Select Wines are designed so they do not reveal any Personal Information on their own.
5. THIRD-PARTY SOCIAL MEDIA
The use of social media by Select Wines is an extension of its Web presence. Social media accounts are public and not hosted on Select Wines servers. Users who decide to interact with Select Wines through these media must read the conditions of service and privacy policies of these third-party providers of services and applications used in order to access them.
6. WEB ANALYTICS
Web analytics involves the collection, analysis, measurement and presentation of data on website traffic and on visits, for the purpose of understanding and optimizing Web use. The information collected by the cookies may be used by Web analytics to keep your interactions with Select Wines in memory.
Information used for the purpose of web analytics is collected pursuant to the Financial Administration Act. Select Wines uses the information for its own internal statistical and analytical purposes, to evaluate and enhance users’ experience of the website by identifying customer preferences and trends that we may use for marketing purposes and to further develop our business and operations.
When your computer requests a Select Wines Web page, Select Wines collects the following types of information, for web analytics, such as:
- the Internet Protocol (IP) address of your computer;
- the date and time of your request;
- the pages viewed and downloaded;
- the identifier attributed to registered users accessing restricted areas on the site;
- the type of operating system; and
- the type of browser & browser settings used.
Data collected for web analytics purposes will sometimes go outside of Canada to the United States of America and may be subject to the governing legislation of that country, such as the USA Patriot Act.
Select Wines uses Google Analytics, and the data gathered are sent to Google, an external service provider. Your IP address is anonymized before being saved on the Google server, in order to safeguard your Personal Information. The data gathered are anonymized by truncating your computer’s IP address. No Personal Information identifying you is saved or provided to Google.
Select Wines uses software to monitor site traffic and to detect unauthorized attempts to upload, change information, or otherwise cause damage. The software receives and records the Internet Protocol (IP) addresses of the computers that have visited this site, including the date and time of visits, the pages that were viewed and downloaded, and the identifier attributed to any registered user who accesses restricted areas on this site. The software also captures information regarding the type of browser and operating system. Select Wines does not attempt to link the IP addresses and the identifiers with the identity of users visiting this site unless there is an attempt to damage the site.
7. RESPONDING TO YOUR CONCERNS
For questions or comments regarding this Policy, for additional information about the management of Personal Information at Select Wines, or to consult or modify your Personal Information, contact us by phone at 604.687.8199 or by mail at 1122 Mainland Street, Suite 470, Vancouver, British Columbia, V6B 5L1.
To file a privacy complaint concerning the collection, use, disclosure, retention, and disposal of or access to Personal Information, please contact us by phone. Should we fail to resolve the complaint to your satisfaction, you or your authorized representative may contact the Office of the Privacy Commissioner of Canada.