Privacy policy

Version 1.1, valid from July 1, 2020.

This is the Privacy Policy for Puratos Canada Inc. (referred to herein as "Puratos", "we", "us", or "our"). This Privacy Policy informs you of Puratos’ personal information privacy policies and practices. Puratos and its affiliated entities around the world are referred to herein as the “Puratos Group.”

When used in this Privacy Policy, and consistent with applicable Canadian privacy laws, personal information means any information about an identifiable individual (“Personal Information”). Information that is aggregated and cannot be associated with an identifiable individual is not considered to be Personal Information.

This Privacy Policy explains the Personal Information we collect and receive about you, how we use and share your Personal Information, and your choices regarding our collection, use, and disclosure, both on this website, Puratos’ social media pages or accounts on third party social media websites, including, but not limited to, Facebook, Instagram, Pinterest, Twitter, Snapchat, and LinkedIn (“Social Media”), Puratos mobile applications (“Apps”), blogs (this website, Social Media, Apps, and blogs collectively, the “Sites”) and from certain offline sources, as described further below.

Puratos and our third-party business partners and service providers (which are third-party companies that work on our behalf) collect information about you from a variety of sources, including information you provide directly to us (e.g., when you send us an email, sign-up to become a member of one of our programs, or purchase products from us), and information we automatically collect from you when you access and use our Sites, as further described below.

A. Personal Information You Provide Us

When you utilize our Sites, purchase products, or contact us regarding our services and products, we collect the requested information that you provide in furtherance of these activities. The Personal Information that you provide may include, without limitation, the following categories:

• Identifiers (such as a real name, alias, date of birth, mailing address, mobile and home telephone and fax numbers, unique personal identifier, online identifier, account number, email address, account name, social security number, and driver's license information);

• Characteristics of protected classifications under California or federal law (such as your age, sex, credit, payment card and financial account information);

• Commercial information (such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and

• Professional or employment-related information.

You may choose whether or not to provide such Personal Information; however, the information may be required to utilize certain features of our website or to purchase products.

B. Personal Information Collected Automatically

Puratos and our third-party service providers collect information automatically from you when you visit our website or otherwise use our online services, including in connection with our emails, online advertisements, and social media pages, as described in this section. As discussed further below, we and our business partners and service providers may use a variety of technologies to assist in collecting this information. Such information may include, without limitation, the following categories:

• Identifiers (such as a unique personal identifier, online identifier or IP address);

• Commercial information (such as products or services purchased, obtained, or considered, purchasing histories or tendencies, including, but not limited to, those related to your use of certain online services,); and

• Internet or other electronic network activity information, such as:

- Usage information. We may collect information about how you interact with our online services. This includes information such as the dates and times that you visit our Sites, the pages you view, links clicked, referring / exit URLs, your browser type, non-sensitive text entered, mouse movements, and the number of clicks on our Sites. In some cases, we collect this information through cookies, web beacons, and similar technologies. To learn more about these technologies, please see our Cookie Policy; and

Device Information. We may collect information about the devices (e.g., computer, tablet, and mobile phone) you use to access our online services, including your device model, IP address, operating system, the temporary or persistent unique device identifiers (sometimes called UDID), and mobile network operator information.

C. Personal Information We Receive from Third Parties

With your consent, Puratos may receive the Personal Information listed above about you from third parties, such as our business partners and service providers, including payment processors and marketing service providers. We may also receive your personal information from other sources with your consent or when authorized by law.

We expect that you only communicate personal data about yourself to us. If you also communicate personal data about other people to us, then you must ensure that you are entitled to do so.

We also expect that the personal data that you communicate to us is correct and that, if specific data changes, you promptly inform us of this change.

The purposes for which we process your personal data depend on how you enter in contact with us.

You browse on our website

• We process information about your use of our website, in order to remember your choices, manage and improve our website. We refer to our cookie policy for more information about this.

You contact us (e.g. by filling in a form on our website, by sending us an e-mail)

• We process your personal data in order to answer and manage your request (e.g. request for information, subscription to our newsletter, complaint). This processing is based on your consent.

You create a personal account on our website

• We process your personal data for client management, based upon the performance of the contract to which you are a party. Without your personal data, we cannot perform this contract.
• We may also process your personal data for the direct marketing of our products/services, based upon our legitimate interests. We believe that it is important to keep you, as our client, informed about our products/services. This processing may involve compiling a profile. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience and personalized offers, which is an advantage for you. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).

In any case

• We may process your personal data for the management of compliance and disputes (eg prevention of unlawful activities, prevention of abuse of the Puratos group’s resources, defense of legal claims).
• We may anonymize your personal data and process aggregate data for research and development, based on our legitimate interests (eg statistics about sales, market analysis, development of products/services). Within the Puratos group, we believe that research and development can lead to enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services (such as customers, distributors, suppliers and end consumers). The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below). Research and development may involve compiling a profile. All identifying elements, such as your name, your address, etc., are eliminated. This profiling has no effect on you, except to the extent that this processing activity might lead to enhancement of customer experience, product improvement and innovation, which is an advantage for you.
• Puratos NV may also process your personal data as a controller, at a group level, for global management and global research, based on its legitimate interests, those of the other group entities and their stakeholders. We believe that this is necessary for the efficiency, consistency and continuity of the Puratos group operations and for the enhancement of customer experience, product improvement and innovation, which will help the persons concerned by our products/services and eventually contribute to safeguarding and promoting the economic, commercial, social and financial interests of the Puratos group. The provision of your personal data for this purpose is not a requirement and you can object to this processing (see article 8 below).
• We may process your personal data for the direct marketing of our products/services and of the products/services of other companies of the Puratos group, based upon your consent, to the extent that you give such consent.

We may share your Personal Information with:

• Companies that are a part of the Puratos Group, including but not limited to Puratos NV, for the purposes described in this Privacy Policy. Puratos Group companies may process your Personal Information for global management and global research, necessary for the efficiency, consistency and continuity of the Puratos Group operations and for the enhancement of customer experience, product improvement and innovation;

• third party service providers that process Personal Information in our name and on our behalf;

• scientific institutions in the context of statistical or scholarly research;

• other third parties when there is a legal obligation to do so;

• our commercial partners, for example when we partner with them to offer certain Products, provided that the necessary protections are in place; and

• the police or judicial authorities at their request if they are entitled to request the Personal Information.

We may also be obliged to disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of our business.

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information with third parties, in accordance with applicable laws.

We may share personal information within the Puratos Group, including in Canada, the United States and the European Union. Some of our service providers may also access, process or store your personal information outside of the country where we are located and where you reside. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored.

As a result, when your personal information is used or stored in a jurisdiction outside Canada, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

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  In particular, if your Personal Data is held or stored in the European Union, we can transfer your Personal Data to countries outside the European Union, including the United States or Canada. Each transfer will be based on appropriate safeguards (adequacy decision and/or standard data protection clauses of the European Commission). If you would like to know how to obtain a copy of the appropriate safeguards, you can contact us at the address stated below (article 12) or via info.canada@puratos.com.

We will store your personal information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

Third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to Facebook) on the Sites may use cookies to gather information on your use of the Sites. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. Puratos encourages you to review the privacy policies of third parties as well.

Third parties involved may use tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of our Sites with any other Personal Information they may have collected about you. We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content Puratos promotes.

By using our Sites or purchasing our Products, you are providing your consent to the collection, use and disclosure of Personal Information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information.

We will generally 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 Privacy Policy or in the terms and conditions of a specific Product you purchased. Your consent may be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us.

If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, you may not be able to use our Sites or we may not be able to provide you with the Products or services that you requested or that could be offered to you.

You can contact us to exercise the following rights, in accordance with the conditions laid down in the applicable legislation:

• Withdrawing your consent for the processing of personal data, to the extent that the processing of your personal data was initially based upon your consent.
• Seeking access to, or any correction, deletion or restriction of your personal data.
• Objecting to any direct marketing and/or research, development and improvement of our products.
• Seeking the portability of your personal data, which you have communicated to us.

You can exercise some of these rights via the settings in your personal account with us (if you have such a personal account).

You can exercise all of these rights by contacting us at the address stated above (article 2) or via info.canada@puratos.com.

If you make a request related to Personal Information about you, we will need to verify your identity.

If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

You also have the right to file a complaint with a data protection authority .

Because our business will continue to evolve, from time to time our policies will be reviewed and may be revised. We reserve the right to change this Privacy Policy at any time and to notify you by posting an updated version of this Privacy Policy, along with the date on which it was most recently updated, on our Sites. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. You will be able to tell when this Privacy Policy was last updated by the version number and “last update” date included at the top of this Privacy Policy. We recommend that you review this Privacy Policy from time to time during visits to the Sites and note any changes before your continued use of the Sites. Your continued use of the Sites after we post any updates to this Privacy Policy constitutes your acceptance of the revisions to our Privacy Policy. It is your responsibility to periodically check for updates to this Privacy Policy.

If you have any questions about how we handle your personal information, please contact us as indicated below. If you have any questions or concerns involving information held by a third party, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.

Puratos Canada Inc.

520 Slate Drive

Mississauga, ON

L5T 0A1

Telephone:  (905) 362-3668,

e-mail: info.canada@puratos.com.