A. SCOPE & INTERPRETATION –
This policy applies to Tony Pappas inc. In this policy, we explain what Personal Information we collect, and how we use, share and manage it.
Please note that when you sign up for, participate in or purchase a specific product, service, program, contest, promotion or event available through Tony Pappas, additional terms and conditions may be provided regarding the collection, use or sharing of Personal Information in connection with that product, service, program, contest, promotion or event. Those terms and conditions will apply together with this policy.
“Personal Information” as used in this policy means information about an identifiable individual, such as the name and date of birth of that individual, and includes non-personal information that we link to Personal Information.
What Personal Information is not
This policy does not cover non-personal information, which is information that does not identify you. However, as stated above, when we collect non-personal information and link that non-personal information to an identifiable individual, then that information will become Personal Information and become subject to this policy.
B. CONSENT –
Unless permitted or required by law, Tony Pappas will not collect, use or share Personal Information without first obtaining consent. We will obtain consent when we want to use Personal Information for a new purpose or for a purpose other than those stated at the time of collection, in this policy or in the terms and conditions of a specific product, service, program, contest, promotion or event you signed up for, participated in or purchased.
Consent can be “express” through words or by specific acts or “implied” by the conduct of the individual whose Personal Information is being collected, used or shared. Unless we determine that we require an additional consent for specific products, services, programs, contests, promotions or events, you agree and consent that as a customer of Tony Pappas we may collect, use, share or otherwise process your Personal Information in accordance with this policy.
You may withdraw your consent for certain purposes. For example, you may choose not to receive: information addressed to you personally about products, services, programs, contests, promotions or events offered by Tony Pappas or invitations addressed to you personally to comment on the products, services, programs, contests, promotions or events that you use or that are available to you.
If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the products, services, programs, contests, promotions, events or information that you requested or that could be offered to you. Please also be aware that, even if you have withdrawn your consent to receive marketing communications from us, we may continue to contact you for certain non-marketing purposes necessary for the management of our businesses, as required by law or related to products, services, programs, contests, promotions or events that you had signed up for, agreed to participate in or purchased.
Please note that it may take some time for all of our records to reflect changes in your preferences. For example, if you request that you not receive personalized marketing communications from Tony Pappas, your preference may not be captured for a promotion already in progress.
C. HOW WE COLLECT PERSONAL INFORMATION –
Tony Pappas collects Personal Information in a variety of ways such as during the course of your purchase of, or application or request for a quote for, our products and services or your participation in one or more of our programs, contests, promotions or events. Tony Pappas limits the collection of Personal Information to what is reasonably required. Tony Pappas collects Personal Information in the following ways:
Directly From you. You may provide Personal Information to us in person, by mail, over the telephone, through our websites or in any other direct manner. From Third Parties. We may receive Personal Information from other sources.
Through Technology. We may collect Personal Information and non-personal information through various technologies directly from you or from third parties.
Point-of-Sale: We may receive non-personal information from sources such as our own and third party point-of-sale-systems and when we link that non-personal information to an identifiable individual it will become Personal Information.
Video surveillance: We may collect Personal Information through video surveillance in areas surrounding our stores, kiosks, pavilions, bank machines, parking lots and other locations for security purposes, to protect against theft, damage to property and fraud, and may use this information to help us better understand the flow of traffic in our stores.
Websites, Social Media, Applications and other electronic means: We may collect Personal Information and non-personal information electronically, directly from you or through third parties. For example, when you visit one of our social media sites, we may collect Personal Information that you choose to submit to us such as your name, contact information, opinions or any other information you choose to provide for the purposes of responding to an enquiry you have made, or for any other purpose disclosed to you at the time of the collection. Third parties may provide information about you to us, such as search terms you used, or refer you to us as a result of a search you conducted.
When you interact with us, such as when you visit our websites or click on our ads, we may use, and send to your device or computer, cookies, web beacons, single-pixel gifs and other technologies to help us collect and store Personal Information or non-personal information about you or to enable us to present offers to you, including interest-based ads. These technologies are used to help us understand what actions you take on our own and on third parties’ websites and applications. For instance, we may store Personal Information and non-personal information, such as your name, email address, province and language preference, on one of these technologies to enable us to populate entry fields that you have previously completed, or present you with content specific to your region and language preference. We may also record user and usage data, such as where users click on a page, the internet protocol (“IP”) address, operating system, which website or ad the user clicked on to reach our website and which search terms were used, to help us optimize our websites, generate reports, display interest based advertisements, or understand which key words result in visits to our websites. You may delete or disable certain of these technologies, such as cookies, at any time via your browser. However, if you do so, you may not be able to use some of the features of our websites.
D. HOW WE USE PERSONAL INFORMATION – PURPOSES –
We identify the purpose for which Personal Information will be used typically at or before the time the Personal Information is collected. Our use of Personal Information is limited to the purposes described in this policy, the purposes set out in the terms and conditions of any product, service, program, contest, promotion or event in connection with which Personal Information was collected, and purposes consistent with any of those purposes. As new purposes may develop over time, we may update this policy so we encourage you to review this policy periodically online.
Tony Pappas collects, uses and shares Personal Information for the following purposes, which involve, among other things, the activities described for each (headings are provided for convenience only): Provision of Products, Services, Programs, Contests, Promotions or Events
To provide products, services, programs, contests, promotions or events, which includes: Creating, administering, and maintaining accounts, such as for loyalty or warranty programs.
In order to manage our businesses, which includes:
Maintaining the security of the public and our customers, employees and property; Maintaining quality service levels and to assist in training our staff and service providers; Deploying and managing our information technology applications and systems, including to troubleshoot a problem or to test systems including before a change is deployed throughout a system (we use non-personal or anonymized information for such purposes as much as possible); and Managing and facilitating the use of our websites and mobile applications, which may include using cookies and other similar technology.
In order to communicate with you, which includes:
Informing you about special offers and promotions or products, services, programs or events that Tony Pappas reasonably believes may be of interest to you; Enabling your participation in contests, promotions, surveys, chats, seminars or workshops, including contests where entry is automatic; Taking or verifying instructions from you; Responding to your enquiries; Providing you with information about the products, services, programs, promotions, contests and events you currently have or are participating in; Recommending particular products, services, programs, promotions, contests or events to meet your needs; Providing you with offers or services based on the location provided by your mobile device (also referred to as location based advertising) or based on your interests; Establishing a record of the Personal Information you provide or that we receive about you; and Communicating changes to Tony Pappas policies or procedures that affect you, including this policy.
Unless you tell us otherwise or consent is required by law, we may contact you by any means for which you have provided contact information.
In order to understand current and future consumer interests, which includes:
Conducting market research by tracking and analyzing current or previously collected information (which is non-personal information to the extent possible) such as purchases, web activities (including offers viewed, opt-out preferences, bounces, click-throughs, content on social media and IP addresses) and other transactions (including the number and amount of transactions by type, location/store of purchase, product code information, brand, quantity purchased, date, time, payment method used, promotional offers used in connection with the transaction, etc.), shopping patterns, account balances, account numbers, payment history, account activity, use of mobile device (including use of features, and duration, frequency, type and location of calls and text messages), and the methods used to apply for or to access or use products, services, programs, promotions, contests or events; Using information (which is non-personal information to the extent possible) from these marketing, research and statistical analyses to improve or to develop new products, services, programs, promotions, contests or events, to better understand you and communicate with you as set out above.
Please note that certain financial information, such as account balances, are not shared among Tony Pappas for this purpose.
E. HOW WE SHARE PERSONAL INFORMATION –
We may share Personal Information about you with other organizations outside of Tony Pappas that help Tony Pappas provide products, services, programs, promotions, contests or events or help us with our business operations. These other organizations may include sub-contractors, third party service providers, third parties that offer products, services, programs, promotions, contests or events under one of our brands, or organizations that help us improve our products, services, programs, promotions, contests or events as well as our business and technology systems, procedures and infrastructure. When Tony Pappas shares Personal Information with any such party, we limit the use of such Personal Information to those purposes requested by us and we require that the party has appropriate safeguards for the protection of that Personal Information.
Other sharing. Canadian law permits or requires the use or sharing of Personal Information without consent in specific circumstances. These circumstances include situations when required by law or necessary to protect Tony Pappas, our employees, our customers, or others. Should this occur, Tony Pappas will not share more Personal Information than is required to fulfill that particular purpose.
Other than as stated in this policy or as stated in terms and conditions or as part of a consent in relation to a product, service, program, contest, promotion or event, Tony Pappas does not sell, trade or share for financial or other benefit any Personal Information with third parties.
F. RETENTION –
How We Protect Personal Information
Tony Pappas strives to maintain appropriate physical, procedural and technical safeguards with respect to its stores, pavilions, kiosks, offices and information storage facilities so as to prevent loss, misuse, unauthorized access, disclosure, or modification of Personal Information in Tony Pappas custody. Our safeguards also apply to our disposal or destruction of Personal Information. We also seek to ensure that any Personal Information in our custody is as accurate, current and complete as necessary for the purposes for which we use that Personal Information.
Where We Keep Personal Information
We store, access and use Personal Information in Canada. Unless there is a legal or regulatory requirement to keep such information in Canada, Personal Information may also be stored, accessed, or used outside of Canada. For instance, when we engage a service provider outside of Canada, Personal Information may be stored, accessed or used in any country where the service provider is located, or from which it provides services, including the United States, Europe, and Asia. Where Personal Information is located outside of Canada, it is subject to the laws of that jurisdiction.
How Long We Keep Personal Information
We actively retain Personal Information only as long as it is required for our relationship and a certain period of time afterwards to respond to queries or as required by federal and provincial laws. When this period ends, Personal Information is scheduled for destruction according to our record retention policies. Depending on the nature of the Personal Information and the purpose for which it was collected, this schedule may vary.
G. ACCESS AND DISPUTE RESOLUTION – Depending on the product, service or program you receive, you may be able to access and verify most of the Personal Information we hold about you by reviewing your account statements or accessing your account online, or calling the applicable customer service telephone number.
For Personal Information not available online or via telephone, Tony Pappas provides a right of access and review in accordance with applicable laws, and will endeavour to provide the Personal Information in question within a reasonable time. You will be asked for identification so that we may verify your identity before providing you with your Personal Information. If you require the documents in an alternative format, we will make reasonable efforts to provide you with your Personal Information in that format. If there will be charges for us to retrieve or provide you with specific information that you have requested, we will advise you of the charges that you would be responsible for and obtain your authorization before proceeding.
Our policy is to respond to access requests as required by applicable laws. Tony Pappas may decline access to Personal Information in certain circumstances. These include where the information requested would reveal confidential information or Personal Information about someone else, or if legal or regulatory requirements prohibit providing access or permit not providing access to such information.
If you are concerned about how we treat your Personal Information, please contact the appropriate Privacy Office using the contact information set out below in “Answering Your Privacy Questions”.
If the Privacy Office is unable to address your concern to your satisfaction, arbitration may be an option recommended to you to settle the dispute. Arbitration is a form of dispute resolution. If the parties decide to pursue arbitration, then the parties would refer the dispute to an arbitrator who would take into account the evidence of each of the parties and render a decision.
If you remain unsatisfied, you may bring the matter to the attention of the appropriate Privacy Commissioner. Some of our activities are subject to the jurisdiction of the Office of the Privacy Commissioner of Canada; other activities are subject to the jurisdiction of the Privacy Commissioner of your province of residence.
H. ANSWERING YOUR PRIVACY QUESTIONS –
Tony Pappas encourages you to review this policy periodically. If you have any questions about how we treat your Personal Information, please contact the appropriate Privacy Office listed below.
1822 Mont-Royal E. Avenue
Montreal (Quebec) H2H 1J1
If you have a product, service, program, or are participating in a promotion, contest or event that is offered by a third party, the third party may hold certain of your Personal Information. Should you have any questions or concerns, we will direct you to the appropriate contact so that you may make enquiries as to that party’s privacy policies and practices.
At Tony Pappas, we understand the responsibility that comes along with collecting, using and sharing Personal Information. In adopting and adhering to this policy, we assure you that the Personal Information we collect will be used in an appropriate and responsible manner.
Last Update: 15 janvier 2015
We collect personal information from customers in the ordinary course of the company’s business.
We collect this information: name, address, postal code, phone, email address, gender, credit card number, credit card expiration date.
When you visit our website, we also collect:
- Information about your computer, including your IP address, the type of browser you use and the location of your computer.
- The pages you visit and the links you click
- What other sites you have visited
The main reasons for which we are collecting your personal information are as follows: complaints, contests and polls, credit check, the customer relationship management, service to the user, delivery, marketing, orders, returns, complement a sale or a transaction and guarantees.
Given our concern of privacy of children, our policy is that at any time we will not collect personal information from a child under 16 years.
For more information on the law on the protection of Quebec please follow the link below.
Commission d’accès à l’information du Québec
575 rue St-Amable
Québec, Québec G1R 2G4
Phone: (418) 528-7741
Call toll free: 1 (888) 528-7741 (Gratuit partout au Québec)
Web site: http://www.cai.gouv.qc.ca/index-en.html
Last update : October 1 2015