2. Our Commitment to Your Privacy
RON WHITE is responsible for all personal information under our control.
Contact information for our Chief Privacy Officer is set out below:
Chief Privacy Officer
RON WHITE is responsible for personal information in our possession or custody, including information that has been transferred to third parties for processing. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their possession or control.
4. Identifying Purposes
We will clearly identify and document the purposes for which we collect, use or disclose personal information at or before the time of collection. As part of our business operations, we collect and use certain personal information strictly for the following purposes (RON WHITE will not sell your personal information to third parties):
• to sell you RON WHITE products (e.g. you may pay for your purchases by credit card)
• in order to respond to requests for information that we receive via our website or otherwise
• in order to process any returns of products to RON WHITE you may need to make
Unless you advise us that you do not wish your personal information to also be used for the following purposes, RON WHITE may also use your personal information for the following purposes:
• to provide you with a more personalized RON WHITE shopping experience (detailed records of your purchase history will be maintained, enabling us to better understand your needs and preferences for future visits)
• to provide you with further or personalized information about upcoming RON WHITE events, promotions and products
If you do not wish RON WHITE to use your personal information for such limited RON WHITE specific marketing purposes, please advise us by sending an unsubscribe e-mail to: Privacy@RonWhiteShoes.com
The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances. As we continue to develop our business, we might sell or buy business assets. In such transactions, client information generally is one of the transferred business assets. Also, in the event that we sell all or substantially all of our assets, information regarding our customers will of course be one of the transferred assets.
If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose before such additional use. We will state the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.
5. Obtaining Consent
We will collect, use and disclose personal information only with the knowledge and consent of the individual, except where inappropriate.
We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information has been collected but before our use for that purpose.
We will not, as a condition of selling you RON WHITE products, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary.
In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by regulation; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; (v) for debt collection; or (vi) to comply with a subpoena, warrant or court order.
You may withdraw your consent with respect to a particular use or disclosure of your personal information at any time by sending written instructions to our Chief Privacy Officer at the address set out above.
6. Limiting Collection
We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.
We collect the following types of personal information from our customers:
• telephone number
• email address
• credit card information (when purchases are made by credit card)
• shoe size
7. Limiting Use, Disclosure and Retention
RON WHITE does not use or disclose personal information for purposes other than those for which it is collected, except with the express consent of the individual or as required by law. RON WHITE will retain personal information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements.
We will protect personal information with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We make our staff members and business partners aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
Our methods of protection include physical measures (for example, locked filing cabinets and restricted access to offices), organization measures (for example, limiting access on a “need to know” basis), and technological measures (for example, the use of passwords and encryption).
We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.
Upon written request addressed to our Chief Privacy Officer, we will inform an individual of the existence, use and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information under our control and have it amended as appropriate.
We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.
If you feel that your personal information we hold is inaccurate or incomplete you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the personal information. Any such request must be in writing.
In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.
If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.
12. Challenging Compliance
If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.
#1247639 | 4057042